Wrexham Local Development Plan 2013 - 2028 KPD11c
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Sustainability Appraisal Report (Deposit Plan - Focussed Changes) November 2018
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Sustainability Appraisal and Strategic Environmental Assessment of the Wrexham County Borough Council Local Development Plan
Sustainability Appraisal Report (Deposit Plan – Focussed Changes) November 2018
The Deposit Plan SA (KPD11 and the Non-Technical Summary KPD11a) have been updated to take account of consultation responses received during consultation on the Deposit plan. Representations made directly on the SA are recorded in Appendix C with the Council’s response and any changes arising. Representations have also been made on the LDP that led to proposed changes to the LDP (Focussed and Minor Editing Changes KPD21), the focussed and minor changes have been assessed under the SA framework and these are recorded in Appendix J).
The Council invite representations on this SA (KPD11c and accompanying Non-Technical Summary Deposit Plan – Focussed Changes KPD11d). (For information, due to file sizes the appendices to the SA, including C and J referred to above, are contained within document KPD11e).
Please refer to section 1.4 on how to make representations.
Contents
1. Summary and outcomes 1.1 Non-technical summary (also a separate document). 1.2 An outline of the plan’s purpose and content and a statement of the likely significant effects of the plan. 1.3 Statement on the difference the SA process has made to date. 1.4 How to comment on the report.
2. Appraisal Methodology 2.1 Approach adopted to integrated assessment 2.2 When the assessment was carried out and who carried out the assessment 2.3 Who was consulted, when and how 2.4 Difficulties encountered in compiling information or carrying out the assessment 2.5 Legislative Requirements 2.6 Stages of Appraisal
3. Background 3.1 Purpose of the Assessment and SA / Environmental Report. 3.2 Plan objectives and outline of contents. 3.3 Compliance with the SEA Regulations.
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4. Sustainability objectives, baseline and context 4.1 Links to other policies, plans and programmes and sustainability objectives and how these have been taken into account. 4.2 Description of the social, environmental and economic baseline characteristics and the business as usual future baseline. 4.3 Main social, environmental and economic issues and problems identified. 4.4 Limitations of the information, assumptions made etc. 4.5 The assessment framework, including objectives, sub-objectives and indicators.
5. Appraisal of the Plan Vision and Objectives
6. Appraisal of Strategic Options 6.1 Main strategic options considered - how they were identified/rationale. Comparison of the social, environmental and economic effects of the options. 6.2 How consideration of the social, environmental and economic issues determined the choice of the preferred option. 6.3 Which other options were rejected. 6.4 Any proposed mitigation measures.
7. Appraisal of Strategic and Detailed Policies 7.1 Significant social, environmental and economic effects of the policies. 7.2 How social, environmental and economic problems were considered in developing the policies and proposals. 7.3 Proposed mitigation or enhancement measures. 7.4 Uncertainties and risks.
8. Appraisal of Candidate Sites
9. Overall Effects and Mitigation
10. Implementation and Next Steps 10.1 Links to other tiers of plans and programmes and the project level (EIA, design guidance etc.) 10.2 Proposals for monitoring the significant effects identified through the SA.
Appendices
A. Policy Review B. Baseline C. Consultees Responses D. Appraisal of LDP Vision E. Appraisal of LDP Objectives F. Appraisal of LDP Options (Growth, Spatial and Topic Based Policy Options) G. Appraisal of LDP Strategic and Detailed Policies H. Approach to Integrating LDP/SA Objectives I. Appraisal of Candidate Sites J. Appraisal of Proposed Focussed Changes (Arising from Deposit Plan Consultation)
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1. Summary and Outcomes
1.1 Non-technical summary
1.1.1 The Sustainability Appraisal (SA) Report tests the sustainability of the Wrexham County Borough Council Deposit Local Development Plan (LDP). An SA of LDPs is required by the Planning and Compulsory Purchase Act 2004 and the European Strategic Environmental Assessment (SEA) Directive. SA identifies the LDP's likely significant economic, environmental and social effects, and aims to minimise any negative effects and maximise positive ones.
1.1.2 Overall the Deposit Plan would have significant benefits in providing the housing and employment land that the current and future residents of Wrexham County Borough will need. It will help to improve access to good quality jobs, services and infrastructure. Residents' health should improve in response to better housing, access to open space, and walking and cycling facilities. But growth will impact on ecology, landscapes and natural resources.
1.2 An outline of the plan’s purpose and content and a statement of the likely significant effects of the plan.
1.2.1 The Deposit Plan for the LDP sets out: The plan purpose, background, how we have arrived at the Deposit Plan and context of the County Borough; The legislative framework, national, regional and local policy framework within which the Deposit Plan has been prepared; the key issues and drivers that have informed the Deposit Plan, which have been identified through preparation of the SA/SEA Scoping Report and a general review of social, economic and environmental evidence; the Council’s vision for the future development of Wrexham County Borough, its objectives for delivering sustainable development and addressing the key issues and drivers; the plan strategy, level of housing and employment growth, spatial locations for growth with main planning issues and key diagram; high level, strategic policies that seek to deliver the LDP vision, objectives and strategy with further supporting information about related areas of national planning policy, the supporting evidence base, supplementary planning guidance and / or masterplans, relevant monitoring indicators and also the wellbeing goals are provided after each policy reason justification; detailed policies used to asses and make decisions on all planning applications in conjunction with the strategic policies; proposals maps relevant to the detailed policies; a monitoring framework for an ongoing assessment of whether the underlying LDP objectives remain valid or whether the prevailing economic, social, environmental or cultural circumstances have significantly altered since the preparation of the plan;
1.2.2 This report: Summarises and updates the key aspects of the previously published Scoping Report (October 2014)1; Assesses the vision, objectives, strategic options, strategic sites and strategic policies for the Wrexham County Borough Council LDP, and the cumulative effects of the overall LDP;
1 http://www.wrexham.gov.uk/assets/pdfs/planning/ldp2/march_2015/sa_scoping_report_2013-2028.pdf Page 3 of 129
Where the Deposit Plan would have significant negative impacts, identifies possible methods to mitigate adverse impacts; Outlines the process of monitoring the LDP's actual impacts; and Provides appendices providing more detailed information on various aspects of this report.
Significant effects of the Deposit Plan
1.2.3 Overall the Deposit Plan would have significant benefits in providing the housing and employment land that the current and future residents of Wrexham County Borough will need. The position of Wrexham as a key settlement of national importance will be strengthened and the LDP will support regeneration of Wrexham town centre. It will help to improve access to good quality jobs, services and infrastructure. Resident’s health should improve in response to better housing, promotion of active travel, access to open space, and walking and cycling facilities. The LDP will deliver development resilient to climate change, avoiding areas at risk from flooding and not causing flooding elsewhere. To reduce carbon emissions the plan supports renewable energy generation and low carbon development and spatially distributes growth to reduce the need to travel.
1.2.4 But growth will impact negatively on the best and most versatile agricultural land and minerals of economic importance (mainly sand and gravel). There will also be negative impacts on assets of local value including ecology, landscapes and historic interest though features of international and national significance will be protected. Increased economic activity with a larger population will lead to increased transport movements, local congestion, increased waste generation and greenhouse gas emissions and also increased air and noise pollution (though a growing population would have the same impacts).
1.2.5 Strategic options to avoid the negative impacts have been considered, different growth options, spatial distributions and strategic sites but opportunities to strategically reduce impacts are very limited. However, the plan contains a number of mitigation measures with policies protecting local ecology, landscapes and historic assets. Mineral policies ensure that prior extraction is considered and that a supply of minerals is maintained during the life of the plan. Growth is focussed in and adjacent to Wrexham the most sustainable town with the largest range of services and other tier 2-3 settlements. This will help reduce the need to travel, encourage active and sustainable transport, reduce per capita carbon emissions and improve accessibility.
1.3 Statement on the difference the integrated process has made to date.
1.3.1 The planning team have been very open and responsive to the SA process, and the SA has resulted in many changes to the LDP which will help improve the sustainability of its outcomes: Rewording of several LDP objectives including; amending the flood resilience objective to include reduction of carbon emissions; making ‘improvement of public transport’ explicit in the transport objective; amending the natural environment objective to explicitly include landscape and the creation of a new objective to reflect the importance of Infrastructure for the plans sustainability (see Appendix E, table 4 for full details); The generation and testing of growth, policy and strategic site options to refine the preferred option (see section 5 and Appendix F). This led to an amendment to the spatial strategy to give greater flexibility to avoid natural environment effects and help deliver more viable development; and steered the choice of key strategic sites and employment land area of search towards more sustainable options; Greater emphasis in the strategic policies to reducing the need to travel by car, making facilities accessible by walking and cycling, providing transport infrastructure in advance of Page 4 of 129
developments being occupied to embed sustainable transport behaviour, and resilience to climate change (table 7.3); Amendments to policies SP2 (Infrastructure), SP5 (Environment) and SP8 (Location of Development) to ensure consistency with Habitat Regulations Appraisal; Steer development to settlements in close proximity to Wrexham town; Identified effects from the strategic policies that will need to be mitigated in the deposit plan (table 7.4); and Use of Wellbeing of Future Generations Act (Wales) 2015 goals as sub-sections of the strategic and detailed policy sections and embedding them within the SA assessment of the plan.
1.4 How to comment on the report.
Consultation 1.4.1 The consultation on the Deposit Plan and the Sustainability Report was open for 14 weeks between 9 April 2018 and 16 July 2018. The consultation on the ‘Focussed Changes’ runs from 7th January 2019 to 18th February 2019.
1.4.2 The easiest and most efficient way to view the Sustainability Appraisal, Deposit Plan and associated evidence base is via the Local Development Plan (LDP) Consultation Portal which can be found here www.wrexham.gov.uk/ldp.
1.4.3 If you need any further information please contact the Planning Policy Team at [email protected]
1.4.4 Responses to the consultation on the Sustainability Appraisal Report will inform the sustainability Appraisal Report submitted with the LDP to Welsh Government for examination.
Post adoption 'SEA statement' 1.4.5 Once the LDP is adopted, WCBC will publish an 'SEA statement' which explains how the sustainability appraisal influenced the LDP. Publication of such an SEA statement is required by the SEA Directive (Article 9.1b). Most of that information is already available in this SA report, but the SEA statement will also include information on how further rounds of SA, and consultation comments on this report and any further SA rounds, were taken into account by the planning team.
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2. Appraisal Methodology
2.1 Approach Adopted to SA Assessment
2.1.1 During the preparation of the Deposit Plan and the SA/SEA Assessment of the strategy, a revised LDP Manual introduced the requirement for a single set of integrated objectives2 to be used to assess development plans.
2.1.2 It was too late in the SA appraisal process to formally integrate the plan and SA objectives in time for the Preferred Strategy. However during consultation on the SA at the Preferred Strategy stage a methodology for integrating objectives and a new set of integrated objectives were proposed and consulted on3. These integrated objectives form the basis of the appraisal framework used to assess the LDP.
2.2 When the assessment was carried out and who carried out the assessment.
2.2.1 The assessment has been undertaken iteratively during the preparation of the Local Development Plan which commenced in the summer of 2015. This report was completed in February 2018 and revised in October 2018 following consultation on the Deposit plan.
2.2.2 The Council, as the ‘Responsible Authority’4, has undertaken the SA process in-house, using a team of officers from various departments across the Council including, Sustainability Officer, Planning Policy and Nature Conservation.
2.3 Who was consulted, when and how?
2.4.1 The Council has a duty to consult with ‘Authorities with environmental responsibility’, known as Consultation Bodies, in Wales these are Cadw and Natural Resources Wales. Due to potential trans-boundary issues (Pontcysyllte Aqueduct and Canal World Heritage Site) and ecological sites crossing national boundaries with England, English Heritage, Environment Agency and Natural England are also consultees. There is also a responsibility to consult with the ‘public’.
2.3.2 Consultation with Consultation Bodies and the ‘public’ on this report is open during the consultation on the Deposit Plan Focussed Changes from the 7th January to the 18th February 2019 (6 weeks).
2.4 Difficulties encountered in compiling information or carrying out the assessment.
2.4.1 Some difficulties were faced in carrying out the SA. First, a similar appraisal had been carried out for the 2010 version of the LDP which was subsequently withdrawn: care had to be taken to ensure that this round of appraisal was consistent with the 2010 appraisal whilst taking into account new data such as information on employment, population and the housing market.
2.4.2 The iterative nature of the SA and LDP processes makes it difficult to keep track of changes and the impact the SA had on the LDP. Whilst every effort has been made to ensure that this SA is consistent with the Deposit Plan, some discrepancies may remain. The back‐and‐forth nature of the appraisal, with SA comments being actively considered and acted upon by the planning officers
2 LDP Manual Edition 2, section 5.4, August 2015 3 Appendix H 4 The Responsible Authority is the body that prepares and/or adopts the plan or programme which is subject to SEA. Page 6 of 129
(which has helped to ensure that the SA findings really have informed the LDP), also made it difficult to ensure complete consistency between the plan and this SA.
2.4.3 In many cases assumptions had to be made about the type of development that would take place in response to the LDP and the type and usefulness of measures to reduce negative impacts (mitigation). Inevitably uncertainty will remain until detailed planning proposals are put forward by developers.
2.4.4 The nature of the Development Plan process and the SA appraisal process front loads the research and evidence base into the early stages of the plan. Consequently there is a risk that new emerging evidence or policy could have significant impacts on the issues and objectives of the plan or appraisal. Whilst every effort has been made to demonstrate that this SA is consistent with the evidence and policy base this does make it difficult to ensure complete consistency between the evidence and the plan.
2.4.5 The SA assessment process generates a huge amount of data to process, analyse and present, doing so in a format that is easy to follow but also meaningful is a significant challenge. Colour coding effects red, amber and green gives a quick and easy overview but can over simplify, quantitative/qualitative assessments can help supplement the coding.
2.4.6 The generation of options has been difficult to pitch, options for every conceivable policy would be unreasonable so options were generated where there were significant sustainability effects taking into account the objectives and geographic scope of the plan.
2.5 Legislative Requirements
2.5.1 Section 62(6) of the Planning and Compulsory Purchase Act 2004 requires the Council to appraise the sustainability of the LDP and prepare a report of the findings as an integral part of the process of plan preparation. The Welsh Government Local Development Plan Manual5 defines sustainability appraisal as a: “tool for appraising policies to ensure they reflect sustainable development objectives (i.e. social, environmental and economic factors)". Sustainability appraisal helps to demonstrate that the LDP is sound by ensuring that it reflects sustainable development objectives, and contributes to the reasoned justification of policies.
2.5.2 Welsh Government guidance indicates that sustainability appraisal must include the requirements of the SEA Regulations6. The SEA Regulations transpose into Welsh law the requirements of the European Union Directive 2001/42/EC (the SEA Directive) which requires formal environmental assessment during production of certain plans and programmes (including LDPs) which are likely to have significant effects on the environment. In preparing its LDP, the Council must comply with the SEA Regulations.
2.6 Stages of Appraisal
2.6.1 This SA report updates and builds on a Scoping Report7 which the Council produced in October 2014. The Scoping Report reviewed the policy context for the LDP and described the economic, social and environmental issues affecting Wrexham County Borough. It also proposed a
5 LDP Manual Edition 2 August 2015, Welsh Government 6 Assessment of Plans and Programmes (Wales) Regulations 2004 7 Sustainability Appraisal Scoping Report, March 2014, WCBC Page 7 of 129
Sustainability Appraisal Framework of Objectives which is used in this report to assess the impacts of the LDP policies. Figure 2.1 shows the stages of the Scoping Report.
2.6.2 After the Scoping Report was published the Welsh Government issued LDP Manual edition 2 August 2015 which requires a single set of integrated objectives (combining plan objectives and SA objectives). As a consequence, a set of Integrated Objectives superseding those in the Scoping Report were proposed in the Sustainability Appraisal that accompanied the Preferred Strategy and consulted on in Feb-April 2016. The set of Integrated Objectives from that report are now used as the basis for assessing the LDP.
2.6.2 This report then considers the impacts of the LDP vision and objectives, strategic options, strategic sites, strategic and detailed policies. Figure 2.2 shows the steps followed for this report. Table 3.2 shows how this report and the Scoping Report together meet the requirements of the Strategic Environmental Assessment Regulations. The legal requirements for Sustainability Appraisal and Strategic Environmental Assessment of the Wrexham County Borough Council LDP are fulfilled by the Scoping Report and this report, which have been prepared in accordance with the LDP Manual 2nd ed. and the Practical Guide to Strategic Environmental Assessment Directive (ODPM et al 2005).
Figure 2.1
Figure 2.2
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3. Background
3.1 Purpose of the Assessment and SA/ Environment Report
3.1.1This Sustainability Appraisal (SA) Report forms part of the Council’s deposit proposal documents for the Wrexham County Borough Council Local Development Plan (LDP). The purpose of sustainability appraisal is to identify the LDP's likely significant economic, environmental and social effects, and to suggest measures to minimise any negative effects and maximise the positive ones. Sustainability appraisal helps to foster a more inclusive and transparent process of producing a LDP, and helps to ensure that the LDP is integrated with other policies.
3.1.2 Section 121 of the Government of Wales Act 1998 and section 79 of the Government of Wales Act 2006 place a duty on the National Assembly to promote sustainable development. Section 39 of the Planning and Compulsory Purchase Act requires that the body producing an LDP (in this case Wrexham County Borough Council) must contribute to achieving sustainable development.
3.1.3 The Well-being of Future Generations (Wales) Act 2015 places a duty on public bodies that they must carry out sustainable development. In carrying out this duty, actions which public bodies must take include: setting and publishing objectives (“well-being objectives”) that are designed to maximise its contribution to achieving each of the well-being goals; and taking all reasonable steps (in exercising its functions) to meet those objectives.
3.1.4 The Act puts in place seven well-being goals to help ensure that public bodies are all working towards the same vision of a sustainable Wales: a globally responsible Wales; a prosperous Wales; a resilient Wales; a healthier Wales; a more equal Wales; a Wales of cohesive communities; a Wales of vibrant culture and thriving Welsh language.
3.2 Plan vision, objectives and outline of contents
The Local Development Plan
3.2.1 The LDP Deposit Plan sets out: The plan purpose, background, how we have arrived at the Deposit Plan and context of the County Borough (chapter 3); The legislative framework, national, regional and local policy framework within which the Deposit Plan has been prepared (chapter 3); the key issues and drivers that have informed the Deposit Plan, which have been identified through preparation of the SA/SEA Scoping Report and a general review of social, economic and environmental evidence (chapter 4); the Council’s vision for future development of Wrexham County Borough, its objectives for delivering sustainable development and addressing the key issues and drivers (chapter 4); the plan strategy, level of housing and employment growth, spatial locations for growth with main planning issues and key diagram (chapter 5); high level, strategic policies that seek to deliver the LDP vision, objectives and strategy with further supporting information about related areas of national planning policy, the supporting evidence base, supplementary planning guidance and / or masterplans, relevant monitoring indicators and also the wellbeing goals are provided after each policy reason justification (chapter 5);
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detailed policies used to asses and make decisions on all planning applications n conjunction with the strategic policies (chapter 6); proposals and constraints maps relevant to the detailed policies; a monitoring framework for an ongoing assessment of whether the underlying LDP objectives remain valid or whether the prevailing economic, social, environmental or cultural circumstances have significantly altered since the preparation of the plan (chapter 7);
3.2.2 LDP Vision;
‘By 2028, Wrexham will be an attractive, distinctive and accessible place where people will want to learn, live, visit and invest. Our economy will be strong, resilient and responsive to our gateway location within Wales. Wrexham County Borough will be a sustainable place where everyone feels safe and included and a place that enhances the quality and distinctiveness of our natural, built heritage and cultural assets’.
3.2.3 LDP Objectives; The LDP objectives set out what the Plan is trying to achieve and reflect the chosen Vision for the Plan area. They respond to spatial elements contained in the vision together with the economic, social and environmental strands set out in the strategic outcomes.
Objective SO1: Ensuring that the role of Wrexham Town as a key settlement of national importance in the Wales Spatial Plan Wrexham – Deeside – Chester hub is strengthened. This objective will be achieved by: Identifying Wrexham Town as the Primary Key Settlement within the County Borough which has a critical role to play in the success of the region, Making provision for new homes in the Primary Key Settlement of Wrexham Town through Key Strategic Site allocations in close proximity to the County’s strategic Employment Area at Wrexham Industrial Estate, Maximising the economic potential of Wrexham, Wrexham Town Centre and Wrexham Industrial Estate, Work in partnership to deliver enabling infrastructure to support a sustainable transport network for the benefit of the region and local area. Objective SO2: Support a vibrant, diverse and competitive local economy that provides a range of job opportunities to enable new and existing businesses to grow in Wrexham County Borough with strategic growth in Wrexham Town and Wrexham Industrial Estate. This objective will be achieved by: Protecting a range and choice of existing employment land and business premises at sustainable locations across the County Borough, Allocating a Key Strategic Site for employment at Wrexham Industrial Estate, Promoting the continued vitality, viability and accessibility of our retail and commercial centres, Improving the economy in rural areas by supporting the development of rural enterprise, diversification of the rural economy, sustainable tourism, broadband connectivity, and rural enterprises, Ensuring infrastructure is provided at the appropriate time to enable the delivery of development, Recognising the contribution that the County Borough’s Green Infrastructure and built and cultural heritage assets make in supporting economic development and wellbeing,
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Support the important role mineral extraction and waste handling can make to the economy. Objective SO3: Regenerate Wrexham Town as a multi-functional destination to include retail, education, civic, amenity, employment, leisure and residential uses. This objective will be achieved by: Enhancing the vitality, attractiveness and viability of the Town Centre as a major destination to shop, visit and live by placing Wrexham Town Centre at the top of the retail hierarchy, Putting in place the Wrexham Town Centre Masterplan framework to develop an environment that is attractive, distinctive and resilient, and Prioritising access for all to the Town Centre by a range of transport modes prioritising active travel and public transport. Objective SO4: Promote active travel and use of public transport by locating new development in the most accessible and sustainable locations; and seek to alleviate known highway infrastructure capacity constraints on the road network within the County Borough. This objective will be achieved by: Put in place a sustainable settlement hierarchy to ensure new development is located in the most suitable locations, Ensuring new development sites are located to maximise active travel and integrate with public transport opportunities, Ensure transport infrastructure is provided in a timely manner to enable and facilitate development and any subsequent phases, and Continued partnership working between the Council and key stakeholders to deliver enabling infrastructure.
Objective SO5: Facilitate mixed diverse communities by delivering housing, including affordable homes to meet the needs of the County Borough. This objective will be achieved by: Providing new homes in sustainable locations to support a growing economy and population, Ensuring a range and choice of tenures and house types that meet specific needs such as the provision of affordable housing, family accommodation, housing for the elderly, the disabled, students and pitches for the gypsy and traveller community; Putting in place a master-planning framework to improve the quality and design of new housing, recognising the role this plays in creating places that are resilient to the impact of climate change and which contribute to people’s health and wellbeing. Ensure new housing responds to the local character and context of the site contributing to the local distinctiveness of the area,
Objective SO6: Promote and encourage a healthy, active and safe lifestyle. This objective will be achieved by: Locating new developments in places where people can to walk and cycle to a range and choice of facilities, Creating accessible, permeable, connected and legible places and reduce predominantly car-based developments to encourage active travel and more people friendly spaces, and Providing high quality green infrastructure including open space, and protecting cultural, recreational, leisure and sports facilities.
Objective SO7: Conserve, enhance and promote the local culture, character and distinctiveness of Wrexham including the Welsh Language. Page 11 of 129
This objective will be achieved by: Respecting the character and distinctiveness of places, buildings and landscapes through the careful design and siting of development, Maintaining and enhancing the character and separate identities of the Borough’s towns and villages by designating Green Wedge boundaries that take into account the need to promote sustainable patterns of development and identifying landscapes of local value; Protecting, promoting and enhancing the Welsh language.
Objective SO8: Ensure all development is supported by the necessary provision of, or improvements to infrastructure, services and facilities in an effective and timely manner to make development sustainable and minimise its effect upon existing communities. This objective will be achieved by: Working in partnership with key stakeholders to ensure infrastructure is provided and funded in a timely manner to enable and support development; Producing an infrastructure plan which sets out the phasing, timing and delivery of infrastructure to support the delivery of growth in the County, Ensure that development contributes fairly and reasonably in scale and kind to the provision of infrastructure where this is required to make development acceptable in planning terms and is directly related to the development.
Objective SO9: Protect, manage and enhance the natural and historic environment and landscapes. This objective will be achieved by: Conserving and enhancing the natural, landscape and historic environment ensuring appropriate protection is given to designated and non-designated assets, including their wider settings, Sustainable management of natural resources, Respecting the character and distinctiveness of places, buildings and landscapes through the careful design and siting of development.
Objective SO10: Reduce carbon emissions and maximise our resilience to and mitigate and adapt to the impact of climate change. This objective will be achieved by: Promoting sustainable patterns of development, locating homes and jobs within close proximity to each other which are accessible by active travel modes, Prudently managing natural resources, Encourage sustainable use of resources and diversion of waste from landfill, Avoiding developing land that may be at risk from flooding and ensuring that development does not increase the risk of flooding elsewhere, and Support the use of renewable energy resources and low carbon technology,
Objective SO11: Ensure development meets the needs of society and industry, now and in the future, through ensuring adequate protection and supply of high quality minerals. This objective will be achieved by: Safeguarding surface mineral resources of economic importance; Maintaining a 7 year land-bank of sand and gravel throughout the Plan period; Providing for additional need for crushed rock in collaboration with Flintshire County Council; Promoting the recycling and use of secondary aggregates.
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Objective SO12: Facilitate the provision of an integrated network of waste facilities which enable waste to be managed in a sustainable way. This objective will be achieved by: Managing waste in the most sustainable and environmentally sensitive way possible through its prevention and utilisation as a resource, driving it up the waste hierarchy and through, where appropriate, providing and safeguarding waste management facilities.
3.2.3 LDP Structure: The LDP structure is shown at Table 3.1, and the key diagram is at Figure 1. The LDP is also supported by a range of technical papers, of which this Sustainability Appraisal is the first.
Table 3.1: LDP Contents 1. Foreword
2. How to comment on the Deposit Local Development Plan
3. Introduction Plan Purpose and Background How have we arrived at the deposit plan? Structure of this document The County Borough of Wrexham National, Regional ad Local Policy context
4. Key Issues, Vision and Objectives Key issues and drivers Vision and strategic objectives
5. Strategy & Strategic Policies
a. Plan Strategy Overview & Key Diagram b. Strategic policies Policy SP1: Housing Provision Policy SP2: Location of New Development Policy SP3: Key Strategic Sites Policy SP4: KSS1 Land at Lower Berse Farm, Ruthin Road, Wrexham Policy SP5: KSS2: Land East of Cefn Road, Wrexham Policy SP6: Planning Obligations Policy SP7: Green Wedge Policy SP8: Wrexham Town Policy SP9: Economic Growth Employment and Enterprise Policy SP10: Wrexham Industrial Estate
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Policy SP11: KSS3: Land to the north of Bryn Lane, Wrexham Industrial Estate Policy SP12: Transport and Accessibility
Policy SP13: Design Principles & Masterplanning Framework
Policy SP14: Health and Wellbeing
Policy SP15: Natural Environment Policy SP16: Historic and Cultural Environment Policy SP17: Minerals Supply and Safeguarding Policy SP18: Sustainable Waste Management Policy SP19: Climate Change Policy SP20: Green Infrastructure
6. Topic, Criteria and Area based Policies
General Development Management Considerations
Policy DM1: Development Management Considerations
Natural Environment
Policy NE1: European and Nationally Designated Nature Conservation Sites Policy NE2: Locally Designated Sites of Nature Conservation and Geological importance. Policy NE3: Trees, Woodlands And Hedgerows Policy NE4: Area of Outstanding Natural Beauty Policy NE5: Special Landscape Areas Policy NE6: Waste Water Treatment and River Water Quality
Built Environment
Policy BE1: Pontcysyllte Aqueduct and Canal World Heritage Site Policy BE2: Trevor Basin Masterplan Area
Housing
Policy H1: Housing Allocations
Policy H2: Affordable Housing
Policy H3: Affordable Housing Exception Sites
Policy H4: Gypsy and Traveller Sites
Policy H5: Gypsy and Traveller Accommodation Policy H6: Conversion of buildings to flats or Houses in Multiple Occupation Policy H7: Housing in the Open Countryside Policy H8 Replacement Dwellings in the Countryside Policy H9 Conversion of Buildings Outside of Settlement Limits to Residential Use
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Economy Policy EM1: Protection of existing employment land Policy EM2: Provision of supporting facilities for employees in business, industrial and warehousing developments Policy EM3: Alternative use of employment land and premises Policy EM4: Employment Development outside settlement limits Policy EM5: Visitor accommodation outside settlement limits Policy EM6: Pentre Maelor and KSS3 Housing Buffer Zone
Transport
Policy T1: Managing Transport Impacts Policy T2: Active Travel Policy T3: Passenger Transport Policy T4: Wrexham General Station Enhancements Policy T5:Safeguarding of Disused Railway Infrastructure Policy T6: Strategic Transport Infrastructure Improvements
Retail Policy R1: Retail, Leisure and Commercial Centre Hierarchy Policy R2: Development within the Wrexham Town Centre Masterplan Area Policy R3: Primary Shopping Streets Policy R4: Proposals Outside Primary Shopping Streets Policy R5: District, Local, Village and Neighbourhood Centres Policy R6: Retail Development (Edge and Out of Centre) Policy R7: Loss of Local Services
Community Facilities and Welsh Language
Policy CF1: Protection of Existing Open Space, Sport and Recreation Facilities Policy CF2: Provision of New Open Space Policy CF3: Regional Sports Stadia Policy WL1: Policy WL1 Welsh Language and the Social and Cultural Fabric of Communities Minerals, Waste and Renewable Energy
Policy MW1: Minerals Safeguarding Policy MW2: Buffer Zones Policy MW3: Sustainable Supply of Minerals Policy MW4: Secondary and Recycled Aggregates Policy MW5: Sustainable Waste Management Policy MW6: Waste Management Facilities Policy RE1: Development and Renewable Energy/Low Carbon Technology Policy RE2: Renewable Energy Scheme
7.Monitoring Framework; 8. Appendices; 9. Glossary of Terms
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Figure 1: Key Diagram;
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3.3 Compliance with the SEA Regulations.
3.3.1 The EU SEA Directive (Annex 1) requires certain information to be provided in the Environmental Report. This requirement is implemented into UK legislation through the SEA Regulations (2004).
3.3.2 Table 3.2 sets out how the requirements for SEA have been met and signposts where this information is found in the Initial Sustainability Report (February 2016) –and in accordance with section 3.2 of the LDP Manual, Edition 2, August 2015.
3.3.3 The Sustainability Report comprises a Scoping Report (October 2014), an Initial SA Report (2016) with a Non-Technical Summary (available separately, and including 8 appendices with technical details provided separately; this constitutes the Environmental Report for the purposes of the SEA Directive.
Table 3.2: Environmental Report Requirements:
Environment Report Requirements Where this is or will be considered What is the plan trying to achieve? ‘an Chapter 3 outline of the contents, main objectives of the plan…and relationship with the other relevant plans and programmes’ (Annex 1(A)) What’s the policy context? an outline of Chapter 3 and Chapter 4 (section 4.1) the contents, main objectives of the (Further detailed in SA Appendix A) plan…and relationship with the other relevant plans and programmes’ (Annex 1(A)) What are the key sustainability Chapter 4 Strategic Objectives, baseline objectives that need to be and context (Further detailed in SA considered? the environmental Appendix A & B) protection objectives, established at international, Community or Member State level, which are relevant to the plan…and the way those objectives and any environmental consideration have been taken into account during its preparation (Annex 1e) What is the situation now? ‘the Chapter 4 Sustainability Objectives, relevant aspects of the current state of baseline and context (sections 4.2-4.3) the environment and the likely evolution (Further detailed in Appendix B) thereof without implementation of the plan’(Annex 1c) ’ The environmental characteristics of the areas likely to be significantly affected’ (Annex IC)- What will be the situation without the Chapter 4 Sustainability Objectives, plan? ‘the relevant aspects of the current baseline and context (sections 4.2-4.3) state of the environment and the likely (Further detailed in Appendix B) evolution thereof without implementation of the plan’ (Annex 1b) What are the key issues including any Chapter 4 Sustainability Objectives,
Page 17 of 129 sustainability problems? ‘any existing baseline and context (sections 4.2-4.3) environmental problems which are (Further detailed in Appendix B) relevant to the plan…including, in particular, those relating to any areas of a particular environmental importance’(Annex 1d) What alternatives are there for dealing Chapter 6 Appraisal of Strategic Options with the environmental problems? ‘an (Further detailed in Appendix F) outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties encountered in compiling the required information’ What will be the situation with the Chapter 9 Overall Effects and Mitigation plan? ‘The likely significant effects on the environment including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage, landscape and the interrelationship between the above factors’ (Annex 1f) How can we mitigate adverse (and Chapter 9 Overall Effects and Mitigation enhance positive) effects? ‘the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan. (Annex 1g). How can we best monitor the plans Chapter 10 Implementation impacts? ‘a description of the measures envisaged concerning monitoring’ (Annex 1i)
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4. Sustainability Context, Baseline and Objectives
4.1 Links to other policies, plans and programmes and sustainability objectives and how these have been taken into account.
4.1.1 This section summaries and updates the main findings of the Scoping Report (see Figure 2.1), and explains how the LDP has taken these findings into account.
Identifying other plans, programmes and strategies (Task A1)
“an outline of the contents, main objectives of the plan and relationship with other relevant plans and programmes” (SEA Directive Annex I(a))
“the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan and the way those objectives and any environmental considerations have been taken into account during its preparation” (SEA Directive Annex I(e))
4.1.2 The Scoping Report's analysis of policies, plans, programmes and strategies relevant to the LDP included: an explanation of the methodology used; a list of the documents reviewed; and how the LDP accords with the guidance and regulations.
4.1.3 Since the Scoping Report was prepared in December 2013 the following significant policy and legal changes or omissions from the Scoping Report require consideration:
The latest version of Planning Policy Wales is now Edition 9, November 2016. The main changes since edition 6 in 2013 are; reflects Wellbeing of Future Generations Act; Welsh language provisions of the Planning (Wales) Act 2015; incorporates Welsh Government’s planning policy for minerals development; consolidates previous changes and gives strong and detailed emphasis to planning for sustainable buildings; changes related to Planning (Wales) Act 2015; updates following the Historic Environment (Wales) Act 2015; updates to national planning policy for retail; and a series of minor and factual updates. Planning Act 2015; sets out provisions for Strategic Development Plans; National Development Framework; Sustainable Development; Welsh Language; Local Development Plans and Joint Planning Boards; Heritage Act; Technical Advice Note (TAN) TAN1 Joint Housing Land Availability (2015); Technical Advice Note (TAN) 4: Retail and Commercial Development (2016); TAN11 Noise (Nov 2015); factual changes reflecting new legislation and standards; Technical Advice Note (TAN) 12: Design (2016); Technical Advice Note (TAN) TAN20 Planning and the Welsh Language (2017); Technical Advice Note 21: Waste (2014);
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Technical Advice Note 22: Sustainable Buildings; Cancelled, details incorporated into TAN 12 Design; Technical Advice Note 23 Economic Development (Feb 2014); Technical Advice Note (TAN) 24: Historic Environment; One Wales: One Planet (2011), Welsh Government Discussion Paper, signals the government's intention to give more impetus and leverage to accelerate progress toward sustainable development; Wellbeing of Future Generations Act (2015) makes sustainable development the central organising principle of the Welsh Government and most public bodies in Wales; Energy Wales: A Low Carbon Transition (Welsh Government 2012) states the Welsh Government’s commitment to ‘create a sustainable, low carbon economy for Wales’ featuring low carbon energy and energy efficiency; Planning for Renewable and low Carbon Energy – A toolkit for Planners (2015); North Wales Regional Technical Statement 1st Review (2014); sets out the regional need for aggregates; Towards Zero Waste, WG (2012); Collections, Infrastructure and Markets Sector Plan, WG (2012); Municipal Sector Plan (2011); Construction and Demolition Sector Plan (2012); Food Manufacture, Service and Retail Sector Plan (2014); Commercial and industrial sector plan (2013); National Transport Plan, Draft (2015); National Transport Finance Plan (2015); Active Travel (Wales) Act 2013; North Wales Joint Local Transport Plan (Taith, 2015); The State of Natural Resources Report (2016); Welsh Water Final Water Resources Management Plan (2014); Dee River Basin Management Plan 2015-2021; Tree and Woodland Strategy 2016-2026; AONB Management Plan Strategy 2014-2019; Local Housing Strategy 2013-2018; Council Plan 2017-2022; Our Joint Plan 2018-2024; End of Life Vehicles Directive (2000/53/EC) as amended by secondary legislation on ELV. Industrial Emissions Directive (2010/75/EU) on industrial emissions Packaging and Packaging Waste Directive (94/62/EC) Restriction of Hazardous Substances in Electrical and Electronic Equipment (2011/65/EU) The Batteries Directive (2006/66/EC) The Management of Waste from the Extractive Industries Directive (2006/21/EC) Environment Act (2016) North Wales Waste Monitoring Report (2016)
4.1.4 Appendix A & B shows the full, updated policy and evidence list. Table 4.1 below summarises, by topic, the key aims of the policy documents reviewed, how the LDP could assist in delivering these aims, and to what extent these considerations have been taken into account during its preparation.
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Table 4.1: Key messages of policy review (Source: Scoping Report)
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 1: Policy aims: Plan Vision: The plan vision seeks to enhance the quality Natural Air: Take account of the effects of development upon air quality and and distinctiveness of our natural heritage. Environment vice versa, and meet mandatory standards for air quality. (March 2014) Plan Objectives; Biodiversity, Flora, Fauna; Protect and enhance biodiversity, Objective SO7: Conserve, enhance and promote the local natural habitats and wild fauna and flora, including: culture, character and distinctiveness of Wrexham including (including Air International, national and local designated sites; and the Welsh Language; Quality, Protected species and species and habitat types identified Objective SO9: Protect, manage and enhance the natural Biodiversity, as priorities for biological conservation. and historic environment and landscapes; Flora, Fauna, Objective SO10: Reduce carbon emissions and maximise Water Landscape; Protect the countryside, designated landscapes and our resilience to and mitigate and adapt to the impact of Resources, areas of local landscape value, geological features, tranquillity, climate change; Flooding, natural greenspaces, local distinctiveness, ecosystem functions and Objective SO11: Ensure development meets the needs of Natural play areas. society and industry, now and in the future, through ensuring Resources and adequate protection and supply of high quality minerals; Landscape) Natural Resources; Minimise the use of non‐renewable resources and, where Strategic Policies necessary, use them efficiently, and encourage the use of SP6: Provides a hook to deliver mitigation explicitly for public renewal resources open space, green (and blue) infrastructure, ecological Promote urban regeneration and the re‐use of previously mitigation, preservation and enhancement of heritage developed land assets, the policy is flexible enough to support other impacts. Promote increased efficiency and demand management of SP7: Identifies strategic areas of Green Wedge that will be water resources protected. Minimise adverse impacts on water quality, the ecology of SP9: Protects a strategic ecological network for protected rivers and on groundwater species and habitats in Wrexham Industrial estate. SP11: Includes an ecological network in an extension to Ensure adequate water resources are available Wrexham Industrial Estate Safeguard mineral resources from sterilisation and SP13: Design principles and Masterplanning establishes a encourage their efficient and appropriate development framework applicable to all development should take into Safeguard soil resources and the best and most versatile account local characteristics and how innovative design can agricultural land enhance the quality of the natural environment. Development should not take place without an SP14: All development to improve health and wellbeing. understanding of contamination risk and appropriate SP15: Protects, conserves and enhances internationally and mitigation. nationally protected sites, protected species and habitats, Flooding the AONB, local wildlife sites and ecological networks, Ensure that, as well as not being at risk itself, development Special Landscape Areas, natural landscape features such does not increase the risk of flooding elsewhere. A as trees, hedges, woodland and green networks; the quality sustainable approach to flooding will involve the avoidance of natural services including water, air and soils, developing of development in flood hazard areas. green infrastructure links and protecting habitats and species of principal importance to Wales. Page 21 of 129
SP16: Protects Registered Historic Parks, Gardens and Landscapes SP17 Provides a supply of Minerals and safeguards resources SP19 Climate Change; maintains ecological resilience and ensures climate change adaptation SP20 Green Infrastructure; maintains or enhances the extent, quality and connectivity of green infrastructure
Detailed Policies DM1; provides a range of criteria relating to landscape, pollution control, energy efficiency and flood risk NE1: Protects internationally and nationally designated nature conservation sites. NE2: Protects Locally designated sites of nature conservation and geological importance. NE3: Protects trees, woodlands and hedgerows NE4: Protects the AONB NE6; Protects locally designated special landscape areas NE6: Protects the integrity of the River Dee SAC river water quality from waste water treatment BE1 and BE2 protect the World Heritage Site its buffer zone and important ecological and landscape features that contribute to it. H7 and EM5: Strictly controls housing and visitor accommodation in the countryside CF1 and CF2 protect existing open spaces and provide new ones MW1 and MW3 safeguards and supplies minerals RE1 promotes low carbon development in large sites RE2 Promotes renewable energy schemes.
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 2: Policy aims: Plan Vision Cultural Protect the historic environment including their settings, Establishes Wrexham as an attractive, distinctive and Heritage and archaeology, cultural heritage and foster local diversity accessible place where people will want to live, visit and invest. the Historic Strengthen Wrexham’s cultural identity, including the Welsh The plan vision seeks to enhance the quality and Environment language distinctiveness of our built heritage. historic environment must remain relevant to and be a vibrant (March 2014) Plan Objectives; part of the culture and economy of Wales whilst meeting and contributing towards the strategic objective of promoting Objective SO7: Conserve, enhance and promote the local sustainable development culture, character and distinctiveness of Wrexham including the There is a need to ensure new development acknowledges Welsh Language; Page 22 of 129
Welsh culture and seeks to retain and support sustainable Objective SO9: Protect, manage and enhance the natural and new uses for those assets with which local communities have historic environment and landscapes; strong cultural associations. Promote good design, the key elements are access, Strategic Policies character, safety, environmental sustainability and movement SP6: Provides a hook to deliver mitigation explicitly for The need to accommodate new development must be preservation and enhancement of heritage assets, the policy is balanced against the need to protect, conserve and enhance flexible enough to support other impacts. the historic and natural environment of the County Borough SP7: Identifies strategic areas of Green Wedge that will be particularly where there are multiple designations of protected. international, national and local significance. SP13: Design principles and Masterplanning establishes a framework applicable to all development should take into account local characteristics and how innovative design can enhance the quality of the built environment. SP16: Protects listed buildings, conservation areas, World Heritage Site, Registered Historic Parks, Gardens and Landscapes, Scheduled Ancient Monuments and archaeological remains;
Detailed Policies DM1; provides a range of criteria relating to character, local distinctiveness BE1 and BE2 protect the World Heritage Site its buffer zone and important ecological and landscape features that contribute to it. W1: Protects areas of language sensitivity from development of a scale and type that would not be typical for the area and provides opportunities for mitigation.
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 3: Policy Aims; Plan Vision: The plan vision addresses the determinants of Health, An objective for planning policies, decisions and proposals is health in providing economic opportunities, new homes, safety, Recreation & to contribute to the protection, and where possible, the inclusiveness and enhances or natural, built environment. Wellbeing improvement of people’s health and well-being as a core (March 2014) component of sustainable development. Consider the Plan Objectives possible impacts of developments on people’s health at an Objective SO2: Support a vibrant, diverse and competitive
early stage. local economy that provides a range of job opportunities to
Promote healthy lifestyles (diet, physical activity, walking, enable new and existing businesses to grow in Wrexham cycling, leisure) County; Address social and community influences (neighbourliness, Objective SO4: Promote active travel and use of public sense of belonging, local pride, local distinctiveness, social transport by locating new development in the most sustainable isolation, inequality, exclusion); locations, and seek to alleviate known highway infrastructure Address living and environmental conditions (built capacity constraints on the road network within the County environment, neighbourhood design, housing, walking and Borough; Page 23 of 129
cycling routes, noise, air and water quality, land with Objective SO5: Facilitate mixed diverse communities by contamination, crime, community safety, road and injury delivering housing, including affordable homes to meet the hazards, quality and safety of play areas); needs of the County Borough; Address economic conditions (unemployment, income, Objective SO6: Promote and encourage a healthy, active and economic activity, type of employment, workplace conditions, safe lifestyle; child poverty); Objective SO7: Conserve, enhance and promote the local Improve access and quality of services (medical and caring culture, character and distinctiveness of Wrexham including the services, shops and commercial services, public amenities, Welsh Language; education and training, information technology); Objective SO8: Ensure all development is supported by the Address macro-economic, environmental and sustainability necessary provision of, or improvements to infrastructure, factors where there is local scope to do so (government services and facilities in an effective and timely manner to policies, climate change, economic growth). make development sustainable and minimise its effect
Strategic Policies SP1: Provides new, modern and sustainable housing improving living conditions SP2: Locates development in the most accessible locations with the most services and facilities. SP3, 4, and 5: Identifies key strategic housing sites on the edge of Wrexham while ensuring infrastructure to enable and deliver the sites is provided e.g. education, open spaces, community facilities, active travel and transport. SP6: Provides a hook to deliver mitigation explicitly for education, active travel, public open space, green (and blue) infrastructure, community facilities, affordable housing, the policy is flexible enough to support other impacts. SP8: Confirms Wrexham as a settlement of national importance, focussing development here which has accessibility and health equality benefits. SP9: Promotes economic development in accessible locations throughout the County Borough. SP11: Promotes active travel at the WIE extension site SP12: Promotes sustainable transport to the benefit of active lifestyles, safety enhancements, improve access to employment, homes, services, healthcare and facilities; SP13: Design principles and Masterplanning establishes a framework applicable to all development which can be applied to health matters e.g. housing design, connectivity. SP14: Ensures all development reduces health inequalities and provides opportunities for healthy lifestyles and improving health and wellbeing. SP15 and SP16: Protects and enhances the natural and built environment SP19 ensures development mitigates and adapts to the effects Page 24 of 129
of climate change
Detailed Policies DM1: Provides a range of criteria relating to character, local distinctiveness, amenity, pollution, safety, accessibility, sustainable transport, flood risk, needs of a diverse population, risks from coal mining NE1 to NE6: Protect and enhance the natural environment H2 and H3: Provides affordable housing; H4 and H5: Provides pitches for G&T community EM1: Safeguards employment land across a range of accessible locations throughout the County Borough EM6 Protects amenity of residents in Pentre Maelor from employment development T1-T6 Promotes active travel and sustainable transport as priority over cars and provides infrastructure to enable it R1-R6 Promote existing centres as the focus for retail and commercial development, thus promoting active travel CF1 and CF2 Protect existing open spaces and provide new spaces to benefit healthy lifestyles W1: Protects areas of language sensitivity from development of a scale and type that would not be typical for the area and provides opportunities for mitigation. MW2 and MW3 Protects residential amenity from mineral development MW6 Protects residential amenity from waste development
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 4: Policy Aims Plan Objectives Waste (March Promote the waste hierarchy: reduce, reuse, recycle, recover Objective SO2: Promotes a diverse economy, waste handling 2014) energy and only then landfill would be one aspect of this Proximity principle and self-sufficiency – waste should be Objective SO12: Facilitates the provision of waste facilities recovered or disposed of as close as possible to where it has been produced and where possible there should be sufficient Strategic Policies capacity to manage wastes produced in any given area SP6: Provides a hook to deliver mitigation, the policy is flexible Meet targets set by European and national legislation enough to support other impacts which could include waste. Manage waste without endangering human health and the SP10: Focuses B class and other ancillary development (which environment includes waste) primarily to WIE SP18: delivers sustainable waste handling
Detailed Policies DM1: Provides a range of criteria including contribution to a low Page 25 of 129
carbon society by minimising waste in construction and use, EM1: Protects a diverse range of employment sites throughout the County Borough and identifies the range of uses appropriate for the site. MW4: Promotes re-cycling of secondary aggregates outside settlement limits where proposals meet criteria MW5: Promotes sustainable waste management by requiring developments to minimise waste, where appropriate provide facilities and avoid conflict with sensitive land uses. MW6: Directs waste handling to employment sites and locations identified in the policy.
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 5: Set out the broad strategy for mineral working and provide a Plan Objectives Minerals clear guide as to where mineral working is likely to be Objective SO11: Ensure development meets the needs of (March 2014) acceptable and identify those areas where mineral working society and industry, now and in the future, through ensuring will not be acceptable. adequate protection and supply of high quality minerals; Protect areas of importance from mineral development. Contribute towards meeting the local, regional and UK needs Strategic Policies; for minerals, to safeguard mineral deposits which society may Policy SP17: Minerals will be sustainably managed through: need for future working, address inactive sites, and ensure the protection of minerals from unnecessary sterilisation; the impact of mineral extraction on the environment and avoiding conflict between mineral working and sensitive alternative land uses is minimised. development; contributing towards meeting the regional need Ensure security of supply of UK coal reserves for aggregate minerals and supporting proposals for mineral Minimise the use of non-renewable resources and, where extraction within the County Borough which contribute towards necessary, use them efficiently, and encourage the use of maintaining an adequate supply of minerals renewable resources Detailed Policies Minimise the unnecessary sterilisation of minerals DM1: protects against risks arising from past coal workings Safeguard mineral resources from sterilisation, plan positively MW1 safeguards minerals by identifying their location and to provide minerals in line with WCBC minerals controlling development that may compromise extraction; apportionment MW2 protects existing workings from development that would The County Borough has an industrial and mining history and compromise extraction some areas still require reclamation from former uses. MW3: identifies important resources and creates extraction Reduce the environmental impact of mineral extraction exclusion areas, mineral development outside of these areas is Set out restoration and after-use requirements supported subject to criteria MW4: Promotes re-cycling of secondary aggregates outside settlement limits where proposals meet criteria
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 6: The Wales Spatial Plan (WSP) (2004) and 2008 update Plan Vision Economy, identify Wrexham Town as a Key Settlement of National Promotes Wrexham as a place to visit and invest responsive to Importance, located within the Wrexham, Chester, Deeside its gateway location within Wales. Page 26 of 129
Employment & Hub. Wrexham Town is also a Key Regeneration Area and Retail (March the Wrexham Industrial Estate is identified as a Key Business Plan Objectives 2014) Sector Area. Objective SO1: Ensuring that the role of Wrexham Town as a Strengthening key hubs as a focus for investment in future key settlement of national importance in the Wales Spatial Plan employment, housing, retail, leisure and services Wrexham – Deeside – Chester hub is strengthened. Developing sustainable accessibility between hubs, coastal Objective SO2: Support a vibrant, diverse and competitive and border towns and rural parts of the Area local economy that provides a range of job opportunities to Improving the quality and diversity of the economy, with a enable new and existing businesses to grow in Wrexham focus on high value manufacturing and services, including a County Borough with strategic growth in Wrexham Town and high quality year-round tourism sector; Wrexham Industrial Estate. Developing, in a focused and strategic manner, the skills and Objective SO3: Regenerate Wrexham Town as a multi- education of the current and potential workforce. functional destination to include retail, education, civic, amenity, Promoting sustainable development, is in part driven by the employment, leisure and residential uses; wealth of natural and built heritage within the area. Objective SO4: Promote active travel and use of public Improve the wellbeing of communities through social, transport by locating new development in the most accessible physical and economic improvements. For North East Wales, and sustainable locations; and seek to alleviate known highway identified regeneration settlements include communities infrastructure capacity constraints on the road network within within Wrexham County Borough (such as Plas Madoc, the County Borough. Queensway, Caia Park and Gwenfro Objective SO11: Ensure development meets the needs of Wellbeing of Future Generations aims for a prosperous and society and industry, now and in the future, through ensuring equal Wales adequate protection and supply of high quality minerals. Objective SO12: Facilitate the provision of an integrated LPA’s should adopt a positive approach to farm network of waste facilities which enable waste to be managed diversification , and small scale tourism/ business in a sustainable way. development in rural areas in recognition of the contribution
they can make to the rural economy Strategic Policies LDP employment land targets should aim to ensure that SP1 establishes a level of housing growth that will support the planning meets the demand for land so that economic growth sustainable communities is not constrained by lack of land, land provision targets may SP2: Directs development including employment to defined need to be higher than anticipated demand, to allow for settlement limits flexibility and the chance that the assessments are too low SP8: Wrexham town will be the focus for new development and to ensure that opportunities are not missed including employment, retail, leisure, tourism and services. There are four main priorities towards achieving economic SP9, allocates land at WIE, safeguards employment land in 25 prosperity within Wrexham: Investment, Employment, Wealth sites, provides a level of employment growth, and promotes and Quality of life. tourism, culture and leisure development Develop a clear strategy for retail development. Set a SP10; focuses employment into WIE framework for the future of town, district and village centres. SP11: allocates employment land at WIE and infrastructure Establish the existing hierarchy of centres and identify clear needed to deliver it; roles. Identify changing pressures and opportunities with SP12 identifies key transport infrastructure needed to support appropriate responses to them. growth; Retail should underpin town centres but policies should SP17; safeguards mineral supplies encourage a diversity of uses in centres. Mixed use SP18; makes provision for waste management developments of retail, entertainment, restaurants and housing should be encouraged. Detailed Policies Page 27 of 129
BE1 and BE2; Provides criteria by which visitor attractions could be provided to support the World Heritage Site. EM1: Protects a diverse range of employment sites throughout the County Borough and identifies the range of uses appropriate for the site. EM2: Allows for the provision of supporting facilities to help sustain employment areas EM3: Sets out criteria by which employment land can be used for alternative uses EM4: Sets out criteria by which employment development outside settlement limits could be supported EM5: Sets out criteria by which visitor accommodation outside settlement limits could be supported T1-T6 establishes transport infrastructure needed to support development including Wrexham general station as a transport hub, improvements to the A483 junctions and improved connectivity to the Mersey Dee Area; R1-R6 sets out a retail hierarchy with town centres first, the mix of uses appropriate in centres, criteria for out of centre development, CF3 safeguards regionally important sports stadia MW1-MW7; provide support for mineral and waste handling development RE1-RE2: Support renewable and low carbon energy development SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 7: Provide for an adequate, available and continuous supply of Plan Vision Population & land for development to meet the needs of current and future Establishes Wrexham as an attractive, distinctive and Housing residents – including homes, infrastructure, investment and accessible place where people will want to live, visit and invest, (March 2014) jobs -in a sustainable manner a sustainable place where everyone feels safe and included Ensure that everyone has good quality housing sufficient for and a place that enhances the quality and distinctiveness of our natural, built heritage and unique culture. their needs, and good access to employment, the full range of services and facilities, and open space Set out a settlement strategy Plan Objectives Identify requirements for market and affordable housing, Objective SO1: Ensuring that the role of Wrexham Town as a taking into account household projections key settlement of national importance in the Wales Spatial Plan Allocate housing land on the basis of a sequential search Wrexham – Deeside – Chester hub is strengthened. starting with previously developed sites or buildings for re- Objective SO3: Regenerate Wrexham Town Centre as a use or conversion before greenfield sites multifunctional destination for retail, education, civic, amenity, Take into account accessibility to jobs, shops and services; employment, leisure and residential uses; availability of infrastructure and the physical and Objective SO5: Facilitate mixed diverse communities by environmental constraints when choosing development sites. delivering housing, including affordable homes to meet the Ensure that sufficient land is genuinely available or will needs of the County Borough; Page 28 of 129 become available to provide a 5 year supply of land for Objective SO6: Promote and encourage a healthy, active and housing. safe lifestyle; Objective SO8: Ensure all development is supported by the necessary provision of, or improvements to infrastructure, services and facilities in an effective and timely manner to make development sustainable and minimise its effect upon existing communities.
Strategic Policies SP1 establishes a level of housing growth to meet housing needs, maximises affordable housing, provides a mix of housing types, needs and tenures, improves quality of housing stock SP2: Directs development to defined settlement limits based on a hierarchy determined by factors including access to services, range of services, employment function; SP3, 4, and 5: Identifies key strategic housing sites on the edge of Wrexham while ensuring infrastructure to enable and deliver the sites is provided e.g. education, open spaces, community facilities, active travel and transport. SP6: Provides a hook to deliver mitigation related to development, the policy is flexible enough to support other impacts. SP8: Wrexham town will be the focus for new development including employment, retail, leisure, tourism and services. SP12 identifies key transport infrastructure needed to support growth; SP13: Design principles and Masterplanning establishes a framework applicable to all development, especially housing to create well designed places
Detailed Policies DM1: Criteria based policy to ensure development enhances character, protects amenity, has regard to safety, is accessible, encourages active travel, contributes to low carbon development, is not at risk from flooding and considers the needs and diverse characteristics of the population H1; Allocates sites for housing development H2 establishes affordable housing thresholds and quotas H3: Provides for affordable housing exception sites H4-H5: Allocates land and criteria for G&T needs H6: sets criteria by which HMO’s are supported H7: sets the criteria by which housing in the countryside is permitted Page 29 of 129
H8: Allows for replacement dwellings H9: Allows for conversion to residential uses
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 8: Ensure that key infrastructure is adequate to accommodate Plan Objectives Infrastructure proposed development so as to minimise risk to human Objective SO8: Ensure all development is supported by the (March 2014) health and the environment and prevent pollution at source necessary provision of, or improvements to infrastructure, Take into account the capacity of existing infrastructure, and services and facilities in an effective and timely manner to the need for additional facilities, in the preparation of make development sustainable and minimise its effect upon development plans existing communities. Maximise the use of existing infrastructure and consider how the provision of different types of infrastructure can be co- Strategic Policies ordinated. SP4-5: Establishes the infrastructure needed to deliver and Develop a strategic and long-term approach to infrastructure enable development at the two key strategic sites provision. SP6: Provides a hook to deliver mitigation related to Consider how the provision of infrastructure can be co- development, the policy is flexible enough to support ordinated to avoid a lag between the provision of infrastructure beyond those explicitly listed development and the need for supporting infrastructure SP8: Identifies Wrexham as the focus for new development including infrastructure SP11: Establishes the infrastructure needed to deliver and enable development at the extension to WIE SP12: identifies key transport infrastructure needed to support growth; SP13: Design principles and Masterplanning establishes a framework applicable to all development, would capture infrastructure design requirements SP14: Promotes infrastructure needed to support healthy living SP15: Supports development that develops and maintains green infrastructure
Detailed Policies NE6: Manages the delivery of housing where there are issues related to water treatment works capacity T1: Establishes the transport hierarchy from which appropriate transport infrastructure mitigation would flow. T2: Promotes active travel and associated infrastructure T3: Promotes delivery of passenger transport related infrastructure T4: Promotes development of Wrexham General as a transport hub T5: Safeguards dis-used railway lines T6: Supports strategic transport infrastructure and explicitly lists projects Page 30 of 129
CF1-CF2: Protects open spaces and provides new spaces related to development
SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper 9: • Climate change and energy security are key priorities for both the Plan Objectives Climate UK and Welsh governments. Objective SO4: Promote active travel and use of public Change & • A legally binding target of at least a 34% cut in greenhouse gas transport by locating new development in the most sustainable Energy (March emissions by 2020, and at least an 80% cut by 2050, against a 1990 locations, and seek to alleviate known highway infrastructure 2014) baseline. capacity constraints on the road network within the County • The UK Government is committed to meeting the EU target of 15% Borough; of energy from renewable sources by 2020. Objective SO10: Reduce carbon emissions and maximise our • Optimise renewable energy generation, low carbon energy resilience to and mitigate and adapt to the impact of climate generation and facilitate combined heat and power change; • Plan for climate change by minimising the causes of climate change (moving to a low carbon economy, reducing demand for energy, Strategic Policies minimising emissions of greenhouse gases, reduce need to travel) SP2: Location of New Development; Location of and planning for the consequences of climate change. development in the most sustainable and accessible locations • Promote energy efficiency and plan positively for renewable energy to reduce the need to travel with opportunities to use production sustainable transport • Locate and design development so as to minimise travel demand, SP13 Sustainable Design Principles: Requires all particular by motor vehicles, and promote accessibility by a range of development to be of high quality sustainable design forms of transport other than the car SP15: Natural Environment: development to develop and • Larger strategic sites should be assessed for opportunities to maintain green infrastructure require higher sustainable building standards based on evidence of SP19 Climate Change: development to mitigate and adapt to what is technically and viably possible. the effects of climate change • Ensure new development in location and design has regard to the SP20: Green Infrastructure: Protect and enhance green and potential risk, causes and consequences of flooding blue infrastructure • Ensure that existing communities, infrastructure and other assets (including those alongside new developments) are considered with Detailed Policies regard to potential risk, causes and consequences of flooding. DM1: Criteria policy for all development, criteria to avoid • Development proposals to include features that provide effective increasing the risk of flooding and creation of low carbon adaptation to and resilience to the effects of climate change for communities. example sustainable urban drainage systems, integrated urban H1 and EM1: Allocates housing sites and safeguards greening and tree protection. employment sites in the most sustainable locations which can • There needs to be greater integration of resilience measures in help reduce the need to travel and support sustainable design of new buildings, infrastructure and communities which can transport limit impact and speed up the recovery process from flooding events T1: Manages transport impacts with a transport hierarchy putting active travel and sustainable transport before cars, provides opportunities to reduce the need to travel. T2, T3 and T4: Promotes active travel and sustainable transport which would reduce carbon emissions. T6: Identifies strategic transport infrastructure needed to support development, includes sustainable transport options Page 31 of 129
R1-R6: sets out a retail hierarchy with town centres first, which can help reduce the need to travel and support sustainable transport CF1-CF2: Protects open spaces and provides new spaces related to development, these spaces have multi functional benefits for climate change adaptation MW1-3: Provides a sustainable source of materials reducing the need to travel MW4-6: Provides a sustainable network of waste handling facilities reducing waste and the need to travel RE1-RE2: Encourages low carbon and renewable energy development with the large development sites in the plan and supports renewable energy schemes SA/SEA Topic Policy aims Considerations included in the LDP Topic Paper Extend choice in transport and extend accessibility in a way Plan Vision: Directly states that Wrexham will be an accessible 10: Transport which supports sustainable development and help tackle the place where people will want to live, visit and invest. (March 2014) causes of climate change. Encouraging a more effective and efficient transport system. Plan Objectives Greater use of the more sustainable and healthy forms of Objective SO1: Ensuring that the role of Wrexham Town as a transport key settlement of national importance in the Wales Spatial Plan Minimise the need to travel. Wrexham – Deeside – Chester hub is strengthened; In relation to new development, priorities wherever possible, Objective SO2: Support a vibrant, diverse and competitive is that they are accessible first by walking and cycling, then local economy that provides a range of job opportunities to by public transport, and finally by car enable new and existing businesses to grow in Wrexham County Borough with strategic growth in Wrexham Town and Wrexham Industrial Estate. Objective SO3: Regenerate Wrexham Town as a multi- functional destination to include retail, education, civic, amenity, employment, leisure and residential uses. Objective SO4: Promote active travel and use of public transport by locating new development in the most sustainable locations, and seek to alleviate known highway infrastructure capacity constraints on the road network within the County Borough; Objective SO6: Promote and encourage a healthy, active and safe lifestyle. Objective SO8: Ensure all development is supported by the necessary provision of, or improvements to infrastructure, services and facilities in an effective and timely manner to make development sustainable and minimise its effect upon existing communities. Objective SO10: Reduce carbon emissions and maximise our resilience to and mitigate and adapt to the impact of climate
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Strategic Policies SP2: Location of development in the most sustainable and accessible locations to reduce the need to travel with opportunities to use sustainable transport SP4: KSS1 requires highways improvements to A483 J4 prior to development and requires active travel with public transport infrastructure SP5: KSS2 requires highways improvements to Greyhound roundabout, active travel and public transport improvements. Connectivity between the north and south sites is to be delivered SP6: Provides a hook to deliver mitigation related to development including Active travel, public transport and highway improvements, the policy is flexible enough to support infrastructure beyond those explicitly listed SP8: Wrexham will be the focus for development including transport and infrastructure SP11 Allocates land at WIE for an employment site, requires infrastructure for public transport, active travel and safe access. SP12: Strategic transport policy developing Wrexham’s transport network in a safe, efficient and sustainable manner SP13 Requires all development to be of high quality sustainable design SP14: Promotes improving health and wellbeing, identifies active travel as one means of achieving this
Detailed Policies DM1: Criteria policy for all development including issues related to access, parking and highway safety, maximising sustainable transport, H1 and EM1: Allocates housing sites and safeguards employment sites in the most sustainable locations which can help reduce the need to travel and support sustainable transport T1: Manages transport impacts with a transport hierarchy putting active travel and sustainable transport before cars, provides opportunities to reduce the need to travel. T2, T3 and T4: Promotes active travel and sustainable transport which would reduce carbon emissions. T6: Identifies strategic transport infrastructure needed to support development, includes sustainable transport options R1-R6: sets out a retail hierarchy with town centres first, which Page 33 of 129 can help reduce the need to travel and support sustainable transport MW1-3: Provides a sustainable source of materials reducing the need to travel MW4-6: Provides a sustainable network of waste handling facilities reducing the need to travel
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4.2 Description of the social, environmental and economic baseline characteristics and the business as usual future baseline.
Collecting baseline information (Task A2)
“The relevant aspects of the current state of the environment and the likely evolution
thereof without implementation of the plan” “the environmental characteristics of areas
likely to be significantly affected” “The relevant aspects of the current state of the
environment and the likely evolution thereof without implementation of the plan” (SEA
Directive Annex I(b and c))
4.2.1 Section 7 of the Scoping Report sets out how baseline information about Wrexham was collected, and a list of the indicators that will be used to monitor change over time. The baseline shows how the indicators perform when compared to local, regional or national targets. Alternatively, where comparators are not available, historical trends are used to show how an indicator is performing. An explanation is also given of the quality of the data: for example an indicator that uses good quality local data will carry more weight than an indicator that uses national data as a proxy source. Figure 4.1 summarises the key constraints to development in Wrexham.
4.2.2. Updates to baseline data have been reviewed with the most significant sources of new data listed in Appendix B to this report.
Fig 4.1: Constraints Map
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4.3 Main social, environmental and economic issues and problems identified.
Identifying sustainability issues and environmental problems (Task A3)
Any existing environmental problems which are relevant to the plan including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC (SEA Directive Annex I(d))
4.3.1 Section 7 of the Scoping Report set out the key issues affecting Wrexham and the methodology used to identify them. Table 4.2 summarises the main sustainability issues affecting Wrexham (source; SA Scoping Report, 2014).
Table 4.2: Key Sustainability Issues (SA Scoping Report; October 2014)
Topic Paper 1 - Natural Environment The County Borough has several European Designated sites including the River Dee SAC, Berwyn SPA, Berwyn and South Clwyd Mountains SAC that require conservation and enhancement. There are a number of nationally important priority habitats published under the NERC Act present locally, several of which are under threat from development, these include rivers and streams, bogs and ponds. Many protected species are present in the County Borough including Salmon, Great Crested Newts and bats which are under threat from development. An extensive network of green infrastructure provides a multi-functional role; these are at risk from development but could also be conserved and enhanced by development with benefits for human health, wellbeing, local character and ecology. Trees, including ancient veteran trees, provide an important element of local distinctiveness; contribute to biodiversity and climate change resilience. The main identified threats to wildlife are climate change, habitat destruction and degradation, pollution, development, changes in farming practice, non- native invasive species and wildlife crime. The ecological and chemical status of water bodies is improving but needs to continue. Reasons for failure that Planning Authorities can and should address through the planning process are: Artificial barriers to fish migration; abandoned mines and contaminated land; Sewage discharges; Flood protection & land drainage and urban and transport development. There are two nitrate vulnerable zones in the County Borough; the planning system must not exacerbate the problem of nitrate pollution. Current pressures on water quality come from water abstraction, sewage, diffuse water pollution, nitrate, phosphate, invasive species, metals, sediments and transport pollution. The pressure to supply water for residential and commercial purposes must not harm designated sites or species. River flooding occurs fairly frequently in the upper catchments of the River Dee, River Alwen and River Alyn. In the remainder of the River Dee catchment, floodplains are generally wider, with flooding zone C2 affecting large areas of agricultural land around Bangor on Dee and parts of urban
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areas such as Wrexham. Surface water flooding is the main cause of flooding in the County Borough. Locally significant flood risk areas are concentrated around Wrexham, Llay Industrial Estate, Wrexham Industrial Estate and urban villages of Gwersyllt, Rhosllanerchrugog, Ruabon, Coedpoeth, Cefn Mawr, Acrefair, Chirk and Glyn Ceiriog. Climate change increases the risk of flooding in the borough, with a particular impact in areas of socially vulnerable groups, community buildings, businesses, homes and infrastructure. It will also impact on habitat and species, water demand, supplies and quality. The design and location of development can contribute to increased flood risk. There are no Air Quality Management Areas in the County Borough, this should be maintained; levels of other air pollutants are within current standards. Acid deposition in the upland areas and southern Maelor exceed critical loads. There is a small pocket of grade 1 agricultural land around Holt with grades 2 and 3 largely surrounding Wrexham. Land with contamination is frequent in the county Borough, a legacy of its former heavy industrial past. Tranquillity is an important element of the local landscape and should be protected. Noise can be detrimental to human health, quality of life, tranquillity and to wildlife. Designated landscapes (AONB and World Heritage Site) are resources to be preserved for future generations. Green Barriers are extensive and require review. There are local landscapes (SLA) that require review All landscapes are important and matter for the health, wealth and well-being of society, for our cultural identity for our economy and for the diverse habitats that exists as part of them. There are important natural heritage features such as ancient woodlands, commons and village greens that have landscape, habitat and climate change value within designated and non-designated landscapes that do not have statutory protection in the planning system but have value in delivering sustainable development. Urban extensions into the countryside will lead to some degree of harm to the landscape; the significant of impact and capability for appropriate and effective mitigation will vary. Topic Paper 2 – Built and Historic Environment Good design can protect and enhance environmental quality, can mitigate and help prevent climate change, helps attract business and investment, promotes social inclusion and improves the quality of life. The Clwydian Range and Dee Valley Area of Outstanding Natural Beauty requires conservation and enhancement for its natural beauty. Pontcysyllte Aqueduct and Canal World Heritage Site and its Outstanding Universal Value are of international importance and require protection together with its buffer zone and attributes of value within the buffer zone. There are many recorded assets of historic value that require protection and potentially many more unrecorded. There are also cultural assets e.g. Bangor Racecourse, ‘Stiwt’, Chirk Castle, Wrexham Racecourse Ground and
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Pontcysyllte Aqueduct. The borough's listed buildings contribute positively to the historic environment, but some of these heritage assets are in a state of disrepair through lack of maintenance and neglect. There are 18 registered historic parks and gardens and historic landscapes in the County Borough. There are 23 Conservation areas that require protection There are currently 1040 Listed Buildings in the County Borough, of which 17 are Listed Grade I, 78 Grade II* and the remainder, Grade II. Key visitor destination hubs (World Heritage Site, Erddig, Chirk Castle and Wrexham) present opportunities for sustainable tourism development. There are a number of areas and types of development where design needs to be particularly sensitive; Clwydian Range and Dee Valley AONB and Special Landscape Areas; historically sensitive sites (WHS, Conservation Areas, Listed Buildings etc); transitional areas between urban and rural fringes; sites adjacent key gateways and landmarks e.g. along the A483; public realm; and key destination hubs such as Erddig Hall and Chirk Castle. Topic Paper 3 – Health, Recreation & Wellbeing Over half of Wrexham’s adult population are overweight or obese, likewise over a quarter of children are, this presents a significant health risk particularly with regards to obesity in children. Fast-food outlets in proximity to schools present a temptation to children with 60% of schools near to one. There is a growing older population that will impact on the demand for health services in the future. Physical activity levels need to increase to achieve wider health benefits. A holistic approach to the provision of recreation space is required recognising the multi-functional role of greenspaces. Natural greenspace is important for improved health and wellbeing, at an authority wide level we are achieving national standards but local provision within 300m of where people live is deficient with 43.8% of the population not having accessible natural greenspace. The location, quality, security, accessibility, type and functions of play areas are deficient in the county borough. Social cohesion, including integration of migrants, particularly in our most deprived areas is important for wellbeing. The Welsh language is a key element of local and Welsh identity, sense of place and culture. There are pockets where the Welsh language is significant but at risk. Economic prosperity is a key priority in the Council Plan (2012). There are pockets of significant deprivation within the County Borough which fall within the 10% most deprived in Wales. In 2008, 13.7% of children were living in workless households in Wrexham. There are two Community First clusters, Caia Park and Hightown and the Urban Villages Cluster. Crime and community safety is a key priority of the Council Plan (2012). Citizenship, Community Spirit and Social Responsibility is another key priority in the council plan with cultural diversity and the Welsh Language key elements in developing community spirit. Education and skills are a key priority in the Council Plan and Single Plan with a view to increasing prosperity, reducing economic inactivity and improving wellbeing. There has been a progressive decline in the number of accidents, deaths, and serious injuries on roads in North Wales.
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Topic Paper 4 – Waste It is not viable or sustainable to rely on landfill to dispose of waste, need to reduce waste, reuse, recycle and then recover before landfill. Waste should be treated or disposed of as close to the point of origin as possible with regional self-sufficiency. There needs to be sufficient infrastructure to provide the full suite of waste facilities needed for the various waste streams. Wrexham has a growing population which will increase the amount of waste. There is likely to be a regional requirement for additional landfill capacity based upon current deposition rates. Topic Paper 5 - Minerals Ensure a sustainable supply of minerals. Safeguard resources to prevent the unnecessary sterilisation of resources from development. There is a potential conflict between Local Development Plan allocations for non-mineral development and mineral development and/or safeguarding. A decision will then need to be taken as to whether the need to protect the resource outweighs the need for the development and vice versa. There is conflict between the extraction of minerals and landscape and environmental protection designations e.g. AONB, SPA, SAC, minerals development in these sensitive areas is not prohibited but proposals need to be carefully considered against national policy. The Development Plan should encourage the efficient use of minerals by promoting the appropriate use of high quality materials and by minimising the production of waste by maximising the potential for re-use and recycling where environmentally acceptable. Topic Paper 6 – Economy, Retail and Employment Wrexham is identified as a key settlement of national importance, being part of a key hub, business sector and regeneration area. Diversify the local economy and attract businesses and visitors to the County Borough; improve the quality of the employment land provision (e.g. Western Gateway) to help move towards high quality employment opportunities; The economy and employment growth should be supported alongside social and environmental considerations. The levels of employment and housing growth should be coherent to achieve sustainable patterns of development and to reduce the need to travel. Economic regeneration is required to rejuvenate some of the more deprived areas of the County Borough and to manage change. There is a need for more employment land for business development, but also a need to protect environmental assets and promote a sustainable economy Investment in the key destination hubs of the World Heritage Site, Erddig Hall, Chirk Castle Chirk and the Ceiriog Valley and Wrexham; an events strategy for the town of Wrexham; visitor accommodation development; improve a sense of place and visitor management. The district centres perform important roles in sustaining local communities, meeting local needs and reducing the need to travel. The role of the centres should be supported and should not be undermined Rural Wrexham is rich in heritage capable of supporting tourism development, with a number of important Scheduled Ancient Monuments and Listed Buildings.
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Topic Paper 7 – Population and Housing The population of Wrexham County Borough has grown from 128,500 in 2001 to 134,800 in 2011. Driven by a reduction in household size (ageing population, divorces etc.) and by an increase in migration (from within the UK and abroad) the demand for new housing and associated facilities and services is growing. Providing accessible housing to meet the diverse needs of the local population including meeting the needs of an ageing population, affordable and market housing and gypsy and travellers will be a key sustainability issue. Make efficient use of land prioritising previously developed land and the re- use/conversion of existing buildings before using greenfield sites unless previously developed sites score poorly in sustainability terms. New housing should be built with low environmental impact reducing carbon emissions associated with constructing and living in them. Opportunities to co-locate development so as to further reduce carbon emissions should be sought. Accessibility to jobs, shops and services by modes other than the car are key sustainable considerations. The potential to upgrade accessibility should also be considered. Housing should be well designed, barrier free and accessible, attractively landscaped, provide public open space and respect biodiversity and flooding issues. The capacity of existing and potential physical, environmental and social infrastructure to absorb further development is important for community sustainability. The provision of affordable housing is important for the social and economic sustainability of communities. There is a shortage of affordable housing, generally across the entire County Borough. More supported and general housing is needed for older persons throughout the County Borough. Previously developed sites which are commonly found in Wrexham and the former industrial urban villages may not be viable if they are expected to deliver affordable housing. Greenfield sites especially in market popular areas for example around Wrexham and the villages to the north east of Wrexham were generally found to be more viable and potentially capable of delivering some affordable housing. There is a need to meet the housing needs of Gypsy & Travellers. Topic Paper 8 – Infrastructure Locating development where there is insufficient infrastructure capacity or an ineffective mechanism to address capacity constraints is unsustainable. Development can make a positive contribution to community sustainability by facilitating new infrastructure previously lacking. Due to viability issues, development may not be able to fund all necessary infrastructures to support the development or local communities. Where development is not capable of supplying all the desired infrastructure needs a set of priorities will be required to ensure the most important infrastructure can be supplied. Infrastructure should be resilient to severe weather events arising from climate change.
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Education is a key priority for the County Borough and the Council, consequently the provision of and accessibility to education facilities is a key issue for land use planning. Access to health care facilities and natural greenspaces are key elements in people’s health and wellbeing. There is a shortfall in primary school places in Wrexham town centre with expansion in many schools constrained. Access to Wrexham Maelor Hospital is difficult from rural communities and from some of the deprived communities particularly in the Cefn Mawr area. Broadband is an essential tool for social inclusion and economic development. Access in more rural areas is limited. Need to balance the demand for water supply and the need to protect the environment. Topic Paper 9 – Climate Change and Energy Climate change is the greatest threat facing humanity, energy efficiency and renewable energy sources can make important contributions to reducing the causes of climate change. The per capita carbon emissions in the County Borough are significantly higher than the Welsh and UK averages; this figure is skewed by industrial outputs as Wrexham has a disproportionate amount of industry. Transport is a significant contributor to carbon emissions and road transport accounts for almost all transport carbon emissions in the County Borough. Promoting more sustainable travel modes can significantly reduce these emissions. Driving to work is the most popular mode of transport in the County Borough and its popularity has increased between 2001 and 2011. The proportion who drive to work is higher than the national average and the proportion who use sustainable modes of transport (walking/cycling/public transport) is lower than the national average. The numbers of people who use sustainable modes of transport to work has increased between 2001 and 2011 but the numbers who drive has increased even more. Renewable energy generation can contribute to a reduction in carbon emissions, national government is committed to a significant contribution to energy supply from renewable sources and the planning system is tasked with optimising renewable energy production. Topic Paper 10 – Transport Improve access to employment opportunities; improve connectivity within the County Borough within the region; improve the efficient, reliable and sustainable movement of people and freight; and improve access to visitor attractions to improve economic sustainability. Improve access to healthcare, education, training, lifelong learning, shopping and leisure facilities; encourage healthy lifestyles; improve the actual and perceived safety of travel. To improve environmental sustainability increase the use of more sustainable materials; reduce the contribution of transport to greenhouse gas, air pollution and other harmful emissions; adapt to the impacts of climate change; improve the impact of transport on the local environment, on our heritage, transport and biodiversity. Encourage and enable a shift to more sustainable forms of travel by improving public transport and facilities for cyclists and pedestrians. People are proportionately using cars more and are walking and cycling less
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Journeys to work and school create morning and evening peak flows which in places leads to congestion Access to essential public services is significantly longer by public transport than by private car, with some areas of the County Borough, the Ceiriog Valley, rural West and Maelor, unable to access a hospital within an hour. Wrexham town is the key centre for employment, retail and services and is the transport hub for the County Borough. Accessibility to and within Wrexham will be a key element to transport sustainability. Accessibility to Wrexham from the outlying service centres such as Cefn Mawr, Chirk, Coedpoeth, Gresford, Gwersyllt, Overton, Penley, Rhos, Ruabon and Rossett will be important for the sustainability of these communities. Many of the urban western villages and north eastern villages have good public transport links to Wrexham but many parts of the Maelor and Ceiriog Valley have poor or no public transport.
4.4 Limitations of the information, assumptions made etc.
4.4.1 There are a number of indicators that could identify trends but are currently unavailable due to a lack of data. These indicators are included as they highlight areas that need to be considered in the future. There will be a need to review and update as new issues arise and new data becomes available. The indicators will be updated at regular intervals in accordance with the monitoring requirements.
4.5 The assessment framework, including objectives, targets and indicators - Developing SEA and SA objectives (Task A4)
“the environmental protection objectives, established at international, community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation” (SEA Directive Annex I(e))
4.5.1 Section 8 of the Scoping Report sets out the sustainability appraisal framework and the methodology used to develop it. As discussed in Chapter 1 of this paper, since the Scoping Report was produced a revised LDP Manual introduced the requirement for Integrated Objectives, the methodology and revised objectives are contained in Appendix H.
4.5.2 The framework consists of 12 objectives and related sub‐objectives and indicators. The sub‐ objectives provide further information on how to interpret the headline objectives and are designed to guide the assessment. Table 4.3 shows the integrated objectives and sub‐objectives.
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Table 4.3: SA Objectives
Integrated Objective Sub-Objective Indicators Objective 1: Ensuring that the role Support economic development and regeneration Employment land supply of Wrexham as a key settlement of Promote Wrexham as part of a key economic hub; national importance in the Wales Regenerate Wrexham Town Centre; Employment Land Completions Spatial Plan Wrexham – Deeside – Promote Wrexham Industrial Estate as a key Chester hub is strengthened; employment area; UK competitiveness index Objective 2: Support a vibrant, Promote a successful retail sector supporting diverse and competitive local communities and existing town and district centres Gross Value Added per capita economy that provides a range of vitality, viability and accessibility; job opportunities to enable new and Enhance accessibility to employment and business Visitor numbers & Spend existing businesses to grow in opportunities; Wrexham Develop transport network in support of economic Number of business start-ups Objective 3: Regenerate Wrexham development and regeneration; Town Centre as a multifunctional Ensure there is a supply of quality employment Number of recorded businesses destination for retail, education, land to meet the needs of the area; Increase in household incomes civic, amenity, employment, leisure Providing a framework to facilitate physical social and residential uses; and environmental regeneration & economic Economic Inactivity development (diversify the economy, provide
higher quality, better paid and more skilled Youth unemployment employment; improve the quality of employment
opportunities, secure excellent education facilities Town centre voids / vacancies (e.g. empty to meet the needs of the population and workforce; shops) and regenerate deprived areas)
Protect and enhance natural, historic, design and Confidence of town centre businesses landscape assets; Support minerals development and a network of waste management facilities. Support the rural and agricultural economy, diversification and provision of rural retail and employment needs; Promote tourism and the key tourism destinations, (World Heritage Site, Erddig Hall, Chirk Castle and the Ceiriog valley and Wrexham); Support investment in new communication technologies to allow home working and e- technology e.g. broadband. Objective 4: Promote active travel Reduce the need to travel and promote sustainable Modal split (travel to work) and use of public transport by transport options locating new development in the Locate development in the most sustainable Transport Volumes Page 43 of 129 most sustainable locations, and locations that first reduce the need to travel and seek to alleviate known highway promote active travel, then promotes sustainable Number of new developments making infrastructure capacity constraints public transport and then finally by private car; contributions towards the improvement of on the road network within the Ensure development addresses highway public transport, walking or cycling County Borough; constraints; infrastructure through planning conditions/ Build homes close to employment, retail, services S106 agreements (and CIL if implemented) and recreation facilities, with Wrexham a key hub for development; Slight Road Accidents Accessibility needs for all the population have been considered; Improve accessibility to key services and facilities such as education, health, employment and shopping (especially in deprived and rural areas); Provide balanced housing, employment and retail growth so as not to cause unsustainable commuting patterns into and out of the county; Promote and enhance public transport services and infrastructure e.g. railway stations; Improve access to Wrexham town centre and the district centres; and Transport supports economic development and regeneration; Objective 5: Facilitate mixed Meet the housing needs of the community Number of houses built each year diverse communities by delivering Meet the housing needs of the community housing, including affordable (including rural community, elderly, Gypsy and 5 year land supply homes to meet the needs of the Traveller community) in terms of housing types, County Borough; numbers, sizes and tenures No. of affordable homes delivered per annum Ensure that the substantial majority of development and the % of eligible residential planning is provided in sustainable locations with access to permissions where affordable housing has services, employment, retail and leisure; been negotiated Enabling vulnerable and older people to live independently, longer; Number of Extra Care schemes approved Promote healthy and active lifestyles; Deliver mixed diverse communities supported by Population & Mid-year population estimates infrastructure (health, social, recreation, education, Average property price compared against transport, IT, water, waste and energy) and average earnings opportunities for healthier lifestyles (parks, recreation, green spaces, cultural activities) Take up of pitches allocated for Gypsy and Connectivity between new and existing Travellers neighbourhoods is enhanced; and New development is well designed, energy efficient, sustainably built and meets the access needs of all society Page 44 of 129
Objective 6: Promote and Improve health and well-being Proportion of adults and reception year encourage a healthy, active and Promote healthy lifestyles (diet, physical activity, children who are overweight or obese safe lifestyle; walking, cycling, leisure), provide and enhance children’s play experiences and access to natural Proportion of adults who meet physical greenspace; activity guidelines Address social and community influences (neighbourliness, sense of belonging, local pride, Life expectancy local distinctiveness, social isolation, inequality, exclusion); Proportion of households not living within Address living and environmental conditions (built 300m of their nearest natural green space environment, neighbourhood design, housing, walking and cycling routes, noise, air and water % Number of people killed or seriously quality, land with contamination, crime, community injured in road traffic accidents safety, road and injury hazards, quality and safety of play areas); % of Peoples Voice respondents stating that Address economic conditions (unemployment, they feel very or fairly safe in Wrexham income, economic activity, type of employment, County Borough in the day workplace conditions, child poverty); Improve access and quality of services (medical % of people who feel that they belong to: and caring services, shops and commercial services, public amenities, education and training, Their neighbourhood, their local area and information technology); Wrexham County Borough Address macro-economic, environmental and sustainability factors where there is local scope to % of people who feel that their local area is a do so (government policies, climate change, place where people from different economic growth). backgrounds can get on well together
% of people satisfied that the design of new development preserves or enhances a local sense of identity Educational achievement on leaving secondary school:
% of pupils achieving the Level 2 Threshold including English or Cymraeg and Mathematics (roughly equivalent to 5 GCSEs A*-C)
No of people participating in community learning (top 25 most deprived communities)
No. of recorded crimes per 1000 residents
% of pupils leaving Yr11 who remain in full Page 45 of 129
time education Objective 7: Conserve, enhance Protect and enhance local character and % of learners choosing to enter Welsh and promote the local culture, distinctiveness of places, buildings and landscapes medium education – character and distinctiveness of e.g. through good design and siting of Wrexham including the Welsh development; and % pupils sitting full GCSE in Welsh as a Language; Promote the Welsh language, distinctiveness and second language - culture. Objective 8 Ensure all Ensure infrastructure is available to support Number of obligations secured through development is supported by the development planning applications necessary provision of, or Locate development to make the most efficient use improvements to infrastructure, of existing infrastructure (including health, Number of services or facilities lost through services and facilities in an education, open spaces, sports provision, utilities & change of use effective and timely manner to transport); make development sustainable and Work with infrastructure providers to ensure that minimise its effect upon existing infrastructure to support the community is provided; communities. where there is insufficient infrastructure, make provision to address this e.g. through direct developer contributions, CIL, Section 106 agreements or through existing investment plans (e.g. AMP). Infrastructure is delivered without a time lag when the need for it arises; Infrastructure important in sustaining communities is protected. Objective 9: Protect, manage and Protect and enhance biodiversity, fauna & flora Designated sites in favourable condition enhance the natural and historic Maintain or enhance internationally, nationally or environment and landscapes; locally protected sites or species (including those in Number and % of protected species whose the LBAP) and undesignated sites of as yet conservation status is favourable unknown value; Protect trees, woodlands, hedgerows, parks and Number of permissions granted contrary to gardens with individual and group local amenity NRW advice that development would be value harmful to favourable conservation status of Preserve and enhance green infrastructure, protected sites ecosystems and the multi-functional values of green spaces and green networks to the benefit of Number of developments granted planning ecology, landscape, connectivity, flood permission that have an adverse effect on control/mitigation and health/wellbeing the qualifying features of statutory designated sites of nature conservation, unless approved by NRW for site management
Number of applications granted which incorporate wildlife and geological features in the design Page 46 of 129
Water abstraction levels from the River Dee
Estimated household water consumption (litres per head per day)
Priority Habitats and Species whose condition has declined or improved
Urban Tree coverage –
Ancient Woodland Coverage
Surface-water Ecological Status
Surface-water Chemical Status
Groundwater Overall Status
Groundwater Quantitative Status
Groundwater Chemical Status
Lakes Ecological Status -
Reasons for Failure for Water Bodies in Wrexham -
River Habitat Survey Sites
Ecosystem Services Protect and enhance landscapes and green spaces Development harmful to the statutory Protect and enhance internationally and nationally purposes of the AONB designated and registered landscapes and features (e.g. conserve and enhance the AONB’S Natural Development harmful to non-designated Beauty, the Outstanding Universal Value of the landscape that is locally sensitive World Heritage Site and its Buffer Zone and Historic Parks and Gardens and Landscapes); Development harmful to Historic landscapes Protect and enhance regional and locally designated landscapes and features (e.g. Special Development harmful to the function and Landscape Areas, land identified as serving the integration of green networks purpose of Green Wedges, RIGS); Protect and enhance landscape features of local Open Space lost to development
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and undesignated interest (e.g. green spaces, trees, woodlands, hedgerows and water features); Protect and enhance landscape values (which can include the following; natural beauty, sense of place and distinctiveness, scenic quality, landscape quality, integrity, perceptual qualities including tranquillity and wildness, important associations, evidence of importance, rarity and conservation interest); Maintain and enhance the character and separate identities of the County Boroughs towns and villages Promote access to natural greenspaces; Promote high quality design in keeping with the landscape context; Preserve and enhance ecosystems and the multi- functional values of green spaces and green networks to the benefit of ecology, landscape, flood control/mitigation and health/wellbeing; Protect landscape of value to economic regeneration; Protect landscapes and green spaces of value to health and wellbeing. Use natural resources efficiently and safeguard their Number of air quality management areas quality Address and reduce the local causes of air, light, Particulate concentrations PM10 ug/m3 noise, water pollution (including ecological and chemical status of rivers, lakes and groundwater’s, Acid and nitrate deposition diffuse and water pollution from surface water runoff and waste water and development in former % of development (residential) on previously mining areas) and all other forms of pollution and developed land contamination (including nitrate pollution in nitrate vulnerable zones); Planning permissions granted on 1,2 or 3A Ensure water abstraction levels are sustainable agricultural land and of no harm to the River Dee SAC, conserve water resources and increase water efficiency; Soil Quality Ensure nutrient levels do not harm the River Dee; Safeguard soil quality and function and the best Number of nitrate zones and most versatile agricultural land; Promote efficient land use; Water Resource zone meeting its target Re-use and remediate previously developed land headroom requirements within settlement limits in sustainable locations; Avoid the spread of invasive species; Page 48 of 129
Ensure Wrexham County Borough is using only its fair share of the earth’s resources; Protect and enhance historic & cultural heritage Number of applications approved that are Protect and enhance Pontcysyllte Aqueduct and harmful to the World Heritage Site and its Canal World Heritage site including its Outstanding Buffer Zone Universal Value and the value and features in its buffer zone; Number of applications approved that are Protect and enhance listed buildings; harmful to Historic Landscapes Park and Protect and enhance archaeological heritage Gardens (scheduled ancient monuments and features of local historic value), listed buildings, historic parks Number of applications approved that are and gardens, historic landscapes and gardens and harmful to assets of local cultural and historic conservation areas; value Protect and enhance local character and distinctiveness of places, buildings and landscapes Number of applications harmful to the setting e.g. through good design and siting of of Listed Buildings development; Promote the Welsh language, distinctiveness and Number and percent of listed buildings ‘at culture; and risk’ Support the ability of historic and cultural heritage to contribute to economic regeneration Loss of listed buildings
% of Conservation Areas with a Character Assessment
Appeals allowed against refusal of conservation area or listed building consent – Data gap
Number of Conservation Areas adversely affected by plan proposals
Buildings of Special Local Interest
Developments harmful to Scheduled Ancient Monuments or setting
Developments harmful to features of (currently unrecorded) archaeological features Objective 10: Reduce carbon Reduce carbon emissions Annual CO2 emissions per capita arising emissions and maximise our Promote the following; from domestic, industry, commerce and resilience to and mitigate and adapt Development in sustainable locations that reduce transport to the impact of climate change Page 49 of 129
the need to travel Average household energy consumption Active travel; Per capita road transport emissions Sustainable transport modes; Sustainable use of resources; Number and type of renewable and low Energy efficiency; carbon energy schemes granted planning Renewable energy production and low carbon permission per annum energy such as wind, biomass, district heat networks and hydro-power; and Change in soil organic carbon Opportunities to impose higher building standards Tonnage of non-hazardous waste going to landfill
Tonnage of local authority collected biodegradable waste going to landfill. Address and reduce flood risk now and in the future Number of properties at risk of flooding) Avoid development in areas at flood risk (e.g. zone C2 flood risk areas); % of properties at risk of flooding Ensure developments are not at risk from or cause surface water and groundwater flooding; Amount of development permitted in C1 and Development is resilient to changes in the C2 flood plain areas not meeting all TAN 15 environment arising from climate change tests (paragraph 6.2 i-v) (temperature, extreme weather, drainage capacity); Number of Indicative Flood Risk Areas Avoid increasing risk to vulnerable development and infrastructure such as housing, schools, % of new developments with Sustainable hospitals and vulnerable social groups such as Drainage Systems (SuDS) incorporated, or children and the elderly; similar solution, where suitable Promote SUDS to manage surface water run-off and water attenuation (green roofs, permeable surfacing etc.); Preserve and enhance ecosystems and the multi- functional values of green spaces and green networks to the benefit of ecology, landscape, flood control/mitigation and health/wellbeing; Promote non culverting of watercourses Objective 11: Ensure development Provide a framework for the sustainable The extent of primary land-won aggregates meets the needs of society and management of mineral resources balancing the permitted in accordance with the Regional industry, now and in the future, conflict between mineral development and Technical Statement for Aggregates through ensuring adequate environmental sensitivities (natural, historic and expressed as a percentage of the total protection and supply of high human) capacity required as identified in the Regional quality minerals; Provide buffer zones to protect resources Technical Statement Land-banks for crushed Prevent unnecessary sterilisation of mineral rock and sand and gravel; resources from development Identify and safeguard sufficient mineral resources Number of planning applications approved Page 50 of 129
for working resulting in the sterilisation of mineral of Protect mineral resources from development that economic importance would preclude extraction Identify where mineral working would not be acceptable Ensure suitable aftercare and restoration of minerals sites to beneficial after use Objective 12: Facilitate the Increase sustainable waste management Waste: Remaining Landfill Capacity and provision of an integrated network Promote waste reduction, re-use, recycling and Landfill Inputs of waste facilities which enable recovery. Municipal Solid Waste Arisings waste to be managed in a Promote resource efficiency and the use of Kilo’s of household waste collected per head sustainable way. secondary and recycled materials. Total amount of Commercial and Industrial Provide adequate waste facilities Waste % of Municipal Solid Waste Landfilled % of Commercial and Industrial Waste Landfilled/Land Recovered % of Municipal Solid Waste Recycled and Composted % of Municipal Solid Waste sent for Energy Recovery % of Commercial and Industrial Waste Recycled Uptake of Employment Land by waste management facilities Total waste collected by the local authority % of waste recycled % of Local Authority collected waste recycled % of commercial and industrial waste recycled % of construction and demolition waste recycled Tonnage of non-hazardous waste arising in Wrexham deposited in landfill Tonnage of inert waste arising in Wrexham disposed of
4.5.3 Appendix B shows how the indicators perform when compared to local, regional or national targets.
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5. Appraisal of the Plan Vision and Objectives
“the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (SEA Directive Annex I(f))
“the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme” (SEA Directive Annex I(g))
5.1 This is the first of four chapters which appraise, respectively, the sustainability impacts of the LDP vision and objectives, strategic and spatial options considered for the LDP, strategic sites for development, strategic and detailed policies. The SA framework of Table 4.3 was used as the basis for each appraisal. For the strategic options and candidate sites, the appraisal helped to inform the decision of which options to choose. For the vision, objectives, strategic and detailed policies, the appraisal helped to fine‐tune each element of the LDP.
5.2 The Practical Guide to the Strategic Environmental Assessment Directive8 states that the purpose of the appraisal at this stage is to predict the likely economic, environmental and social effects of the options being considered. The Guide states that “predictions do not have to be expressed in quantitative terms ... quantification is not always practicable, and qualitative predictions can be equally valid and appropriate”.
5.3 This chapter discusses the appraisal of the Deposit Plan Vision and Objectives ‐ which were shown at Chapter 3.
Sustainability Appraisal of the LDP Vision
5.4 The appraisal of the LDP vision showed that the vision would primarily have positive impacts. It highlighted a number of issues that were not explicitly addressed through the LDP vision (reducing carbon emissions, climate change resilience and adaptation, regenerating Wrexham Town Centre, promoting healthy active lifestyles, infrastructure provision, mineral and waste management). Furthermore there are internal conflicts with the vision that need to be resolved in the LDP, in particular resolving tensions between growth and accessibility/highway capacity; and tensions between mineral and environmental protection. The detailed assessment of the LDP vision can be found in Appendix D.
Sustainability Appraisal of the LDP Objectives
5.5 Following the changes instigated by LDP Manual edition 2 August 20159 the objectives for the LDP have been combined with the SA objectives. Appendix E shows the full appraisal and Table
8 A Practical Guide to the Strategic Environmental Assessment Directive (ODPM 2005) Chapter 5 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/7657/practicalguidesea.pdf 9 http://gov.wales/topics/planning/policy/policy-and-guidance-on-development-plans/ldpmanual/?lang=en
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5.6 below summarises the results of the appraisal of the LDP objectives and changes arising from the assessment.
Table 5.1: Summary of LDP Objectives Appraisal and Changes Arising
Objectives Prior to SA Objectives Refined after SA Objective 1: Ensuring that the role of Wrexham as No change a key settlement of national importance in the Wales Spatial Plan Wrexham – Deeside – Chester hub is strengthened; Objective 2: Support a vibrant, diverse and Need to be more explicit where growth will competitive local economy that provides a range of be, end of the last sentence changed job opportunities to enable new and existing to…‘with strategic growth in Wrexham businesses to grow in Wrexham Town and Wrexham Industrial Estate’. Objective 3: Regenerate Wrexham Town Centre as No change a multifunctional destination to include retail, education, civic, amenity, employment, leisure and residential uses; Objective 4: Promote active travel by locating new Promote active travel and use of public development in the most sustainable locations, and transport by locating new development in seek to alleviate known highway infrastructure the most sustainable locations, and seek to capacity constraints on the road network within the alleviate known highway infrastructure County Borough; capacity constraints on the road network within the County Borough; Objective 5: Facilitate mixed diverse communities No change by delivering housing, including affordable homes to meet the needs of the County Borough; Objective 6: Promote and encourage a healthy, No change active and safe lifestyle; Objective 7: Conserve, enhance and promote the No change local culture, character and distinctiveness of Wrexham including the Welsh Language; No objective for infrastructure needed to deliver and enable development, this is essential to the sustainability of communities. New Objective SO8 - Ensure all development is supported by the necessary provision of, or improvements to infrastructure, services and facilities in an effective and timely manner to make development sustainable and minimise its effect upon existing communities. Objective 8: Protect, manage and enhance the Protect, manage and enhance the natural natural and historic environment; and historic environment and landscapes; Becomes objective 9. Objective 9: Maximise our resilience to and Reduce Carbon emissions and maximise
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mitigate and adapt to the impact of climate change; our resilience to and mitigate and adapt to the impact of climate change. Becomes objective 11. Objective 10: Ensure development meets the No change needs of society and industry, now and in the future, through ensuring adequate protection and supply of high quality minerals; Objective 11: Facilitate the provision of an No change integrated network of waste facilities which enable waste to be managed in a sustainable way.
5.7 Rewording was suggested for several objectives; Be more spatially specific for employment growth locations; Amend the transport objective to explicitly promote use of public transport. Introduce an additional objective for infrastructure; Make landscape an explicit element of the objective for the natural environment; Make reduction of carbon emissions an explicit objective; and Merge the new Carbon reduction objective with the climate change objective to create a single carbon reduction and climate change resilience objective;
5.8 The appraisal of the Integrated Objectives in Appendix E contains an assessment (table 2 and 3) of internal consistency between objectives which identified the following issues; Safeguarding of minerals conflicts with the role of Wrexham as a nationally important town, minerals of economic importance surround the town of Wrexham; Similarly supplying minerals may conflict with protection of natural, historic and landscape assets dependent on how this strategic objective is delivered; A concentration of growth within Wrexham (SO3) may impact on infrastructure capacity (roads, schools) with impacts on natural resources (air, noise, pollution) dependent on how this strategic objective is delivered; Expansion of Wrexham may impact on local distinctiveness especially if settlement limits converge; Expansion of Wrexham may impact on ecology and landscapes; Expansion of Wrexham will impact negatively on the best and most versatile agricultural land; The impact of economic growth on historic assets is dependent on its location; There are opportunities to use local character and distinctiveness as a tool to facilitate town centre regeneration but regeneration may also threaten local character. The LDP will need to ensure the most sensitive assets are protected; The promotion of green networks for active travel reinforces the value of these multi- functional natural assets; The impact of the housing objectives on the natural and historic environment depends on the location of development and appropriate mitigation; The impacts of housing on climate change and resilience depend on detailed design and siting issues that the LDP will need to address; The potential conflict between housing and minerals objectives is dependent on the location of housing and distribution of mineral resources; Reducing carbon emissions can positively impact on climate change though the local effects are minor;
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The extraction of mineral resources can impact negatively on the landscape/biodiversity and habitat interests in the short to medium term with the potential for long term restoration. The LDP can help avoid adverse impacts by directing mineral development to less sensitive areas, thereby protecting the most sensitive areas.
5.9 These observations need to be considered when preparing the strategic and detailed policies and selecting development sites.
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6. Appraisal of Strategic Options This section brings together the appraisal of strategic options, more detailed information is contained in Appendix F. The Welsh Assembly Government's LDP Manual explains that: "The purpose of this task is to predict the social, environmental and economic effects of the options being considered in the LDP preparation process. The main technique is to predict both positive and negative effects of each option on the environmental baseline and objectives set out in the SA framework. The performance of each option can then be compared, taking account where necessary of the “business as usual” scenario i.e. how sustainability would change under the current development plan" (Sec. 6.4.1).
“the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (SEA Directive Annex I(f))
“an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know‐ how) encountered in compiling the required information” (SEA Directive Annex I(h))
6.1 Main strategic options considered - how they were identified/rationale - Comparison of the social, environmental and economic effects of the options.
6.1.1 Three types of options were considered, growth, spatial and key strategic policy options.
Section 1: Appraisal of Growth Options
6.1.2 Growth
6.1.2.1 Growth options contained in the ‘Vision, Objectives and Strategic Growth and Spatial Options for consultation with key Stakeholders’ (March 2015) were assessed against the SA objectives and the results recorded10.
6.1.2.2 Growth Options for the Preferred Strategy were assessed against the SA objectives and the results recorded11. The following colour coding system is assessing the various policies against the SA framework. Very Positive Effects
Positive Effects
x Some aspects of the
policy have positive effects
and some negative
x Negative Effects
xx Very Negative Effects ? Uncertain/Insignificant
10 Initial Sustainability Appraisal of the Wrexham Local Development Plan Vision, Objectives and Strategic Growth and Spatial Options http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd 11 Initial Sustainability Appraisal of the Wrexham Local Development Plan (Preferred Strategy) February 2016 http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd
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6.1.2.3 Following the Preferred Strategy in February 2016, the Welsh Government published (September 2016) a new set of Local Authority Population projections based on the 2014 mid-year population estimates. Consequently growth projections based on previous population projections (options discussed in paras 6.1.1.1-2) have been superseded by more up to date evidence.
6.1.2.4 This document assesses growth options based on the most up to date population projections12 and the outcomes from stakeholder engagement at Preferred Strategy13 using the Integrated Objectives.
Section 2: Appraisal of Strategic Growth Options
6.1.2.5 Table 1 sets out the growth options considered;
Table 6.1: Options for Growth
Option Housing Employment Growth Option 1: 2014 based 5 6000 (plus slippage 2700 jobs (19ha) year migration trend allowance) = 6600 (Sept 2016)
Option 2: 2014 based 10 7750 (plus slippage 4700 jobs (33ha) year migration trend allowance) = 8525 (Sept 2016)
Table 6.2: Summary appraisal findings for the strategic growth options
)
nt
e
Welsh
m
ha
x
Communities Affordable)
re
Local & Character
1.of Role W 2. Economy Centre 3. Town Wrexham 4a.Travel Active 4b.Capacity Highways 5. ( aHousing 5b. ( Housing 6.Living Healthy 7. Language 8. Infrastructure 9a. & Ecology Habitats 9b. Resources Natural 9c.Environm Historic 9d. Landscape emissions 10a. Carbon Resilience 10b.Change Climate 11. Minerals 12. Waste Option 1: 2014 based 5 year ? x x x ? x x ? x x ? x x migration trend Option 2: 2014 based 10 year ? x x x ? xx xx ? xx xx ? x x migration trend
12 BP01b - Population and Household Projections with Dwelling and Employment Impacts Revised (March 2018) http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd 13 KPD011 – Preferred Strategy Consultation Report of Findings (March 2018) http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd
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6.1.2.6 Option 2 with higher growth performs better than option 1 in addressing socio‐economic issues (including housing need and economic development) within the County Borough, including the need for affordable homes.
6.1.2.7 However, option 2 performs less well than option 1 against objectives for ecology and habitats, natural resources, landscape and carbon emissions. Both options have negative impacts but with a greater land take required for option 2 the impacts are greater. However, impacts are of a local scale and detailed mitigation and avoidance has not been considered at this level of assessment, these are matters to be considered in preparing detailed planning policies (including allocations) and at the planning application stage.
6.1.2.8 Both options are likely to increase the need to travel due to increased transport and economic activity with resultant increases in carbon emissions, air pollution and potentially loss of carbon sinks. The impact on carbon emissions and increasing active travel is dependent on the location of development (access and distances to services) and the effectiveness of mitigation (promotion of active travel and sustainable transport, and retention of carbon sinks), matters to be considered in forming policy and assessing applications.
6.1.2.9 Waste production is also likely to increase with increased population and economic activity. However, detailed policy mitigation can help reduce per-capita waste and energy usage.
6.1.2.10 Development of greenfield sites could lead to the loss of natural resources (high quality agricultural land, and result in the loss/sterilisation of mineral reserves) but much will depend on site selection and mineral mitigation policies.
6.1.2.11 The two options have the potential to impact negatively on historic environment, local character and Welsh language. However the impact is location specific, and therefore it is uncertain how differing levels of growth may impact on those assets. These impacts will be identified in the assessment of allocated sites policy (Appendix G).
6.1.2.12 The options could impact on the County Borough’s ability to adapt to flood risk as green space aids in land drainage and increased urbanisation has the potential to increase surface water flood issues. However there are opportunities to mitigate or adapt to flood risk; for example through the provision of sustainable urban drainage systems, and through directing development away from flood risk areas.
6.1.2.13 Both growth options impact on infrastructure requirements (highways, transport, education, health and open space) with impacts potentially greater with higher growth. However impacts are uncertain, much will depend on the spatial location of growth, locally specific capacity constraints and the ability of sites and the LDP to mitigate impacts. These are matters for consideration with detailed policies and site applications (Appendix G).
6.1.2.14 The impact of growth options in supporting the role of Wrexham and Wrexham Town centre are dependent on site selection and spatial distribution of growth. Growth in close proximity to Wrexham will have the greatest impact in supporting these objectives.
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Section 3: Spatial Options
6.1.3 Spatial
6.1.3.1 The spatial options considered and the evidence base underpinning the options are detailed in ‘Vision, Objectives and Strategic Growth and Spatial Options for consultation with key Stakeholders’ March 201514; the appraisal of the spatial options was presented in the accompanying ‘Initial Sustainability Appraisal of the Wrexham Local Development Plan Vision, Objectives and Strategic Growth and Spatial Options, March 2015’15 paper.
6.1.3.2 The spatial options under consideration for the Preferred Strategy were assessed for the SA16. As discussed in section 1 above a new set of Integrated Objectives have been derived to assess the plans performance, therefore for transparency the assessment has been re-done to align with the new integrated objectives. 6.1.3.3 The three spatial options are:
Option 1 Primary Key Settlement (Wrexham Town) Focussed – including Key Strategic Sites: Wrexham County Borough has one of the largest concentrations of population in any Local Authority area within North Wales. Approximately 34% of the population of the County Borough reside in Wrexham Town, the main social, retail, office, leisure, residential and education centre, with further commercial and economic activity concentrated in the Wrexham Industrial Estate (WIE). Accessibility to regional and national transport links from both settlements are excellent.
Option 2 Primary Key Settlement (Wrexham Town) and Key Settlements Focus: This option spreads development between the Primary Key Settlement of Wrexham Town and the Key tier 2 Settlements of Acrefair / Cefn Mawr, Chirk, Coedpoeth, Gresford / Marford, Gwersyllt and Rhosllanerchrugog as identified in the Settlement Hierarchy Background Paper (January 2015) within the County Borough. Wrexham Town would remain the focus for new development through Key Strategic Sites however there would also be a proportion of new development in the Key Settlements where capacity exists for accommodating new development.
Option 3 Primary Key Settlement (Wrexham Town), Key Settlements and Local Service Centres: The main difference in Option 3 is that this strategy includes the potential to spread new growth around the Local Service Centres (tier 3) which help to sustain the more rural areas of the County Borough appropriate to the settlement size, function and character whilst also concentrating development in the most sustainable, Primary Key Settlement of Wrexham Town.
Table 6.3: Summary appraisal findings for the strategic spatial options
14 http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd 15 http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd 16 Initial Sustainability Appraisal Report (Feb 2016) http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd
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)
m
ha
Welsh Language Welsh
x
Communities Affordable)
emissions
re
1.of Role W 2. Economy Centre 3. Town Wrexham 4a.Travel Active 4b.Capacity Highways 5. ( aHousing 5b. ( Housing 6.Living Healthy 7. Character& 8. Infrastructure 9a. & Ecology Habitats 9b. Resources Natural 9c.Environment Historic 9d. Landscape 10a. Carbon Resilience 10b.Change Climate 11. Minerals 12. Waste Option 1 (Wrexham) x x x x x x x x ? x x ? x x Option 2 (Key Settlements) x x x x x x x x x ? x x ? x x Option 3 (Dispersed) x x x x x x x x x x ? x xx ? x x
6.1.3.4 Focusing growth in Wrexham will help support the objectives for Wrexham and the town centre, while dispersal may weaken the potential benefits but much will depend on the scale of growth dispersed to lower tiers.
6.1.3.5 The impact of the spatial strategy on the economic objective is dependent on how much growth is dispersed and where. Wrexham and Wrexham Industrial Estate are key economic drivers and for the best economic benefits to be realised they need to be central to the spatial strategy while allowing for growth in the lower tiers to support local and rural growth17.
6.1.3.6 Option 1 in locating development within and adjacent to Wrexham Town with the widest range of services, employment, best accessibility and best sustainable transport network has the greatest potential to encourage active travel and reducing the need/distances to travel. Dispersing development away from Wrexham would increase the need to travel and reduce active travel opportunities. However, it is acknowledged that much will depend on site specifics and policy details to mitigate the impacts.
6.1.3.7 The impact of the spatial options on highways capacity is dependent on site allocations and detailed transport policies. Broadly, wherever development is located in the County Borough it will impact on key A483 junctions into Wrexham.
6.1.3.8 The viability of development and its ability to fund necessary and enabling infrastructure to support communities is dependent on spatial variations in market value as evidenced by the Wrexham Viability Study Update (March 2018)18. Development in and adjacent to Wrexham is viable but Option 2 includes some settlements with poor viability (Cefn Mawr, Rhos.) while option 3 would include some of the most viable areas in the County Borough (Holt, Overton, Penley and Rossett) and provide more equitable distribution of benefits.
17 Joint Employment Land Review Report (Oct 2015) http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd 18 http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd
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6.1.3.9 Option 1 would provide housing to meet need in Wrexham Town and areas adjacent but it would not meet housing needs elsewhere in the County Borough. Option 2 would result in development in the key settlements, as well as Wrexham Town. This would have the benefit of spreading housing (including affordable housing) across a wider area. This effect would be increased further by Option 3.
6.1.3.10 The impacts of spatial options on Health & Wellbeing, Local Character and the Welsh language and infrastructure are dependent on site specific details and mitigation measures.
6.1.3.11 It is difficult to draw broad conclusions on the impact of spatial options on infrastructure as capacity, viability and the means of mitigation will vary site by site and by infrastructure type.
6.1.3.12 All three options have potential negative local environmental effects, including loss of habitats and disruption of habitat connectivity. All options are likely to have negative impacts on some local landscape settings within the County Borough.
6.1.3.13 Related to the issues in 6.1.3.6 above, locating development near existing services would have the benefit of reducing the need to travel and the associated reduction in carbon emissions. Option 3 would seek to disperse development throughout the County Borough. This is likely to result in an increase in the need to travel, and the subsequent increase in carbon emissions unless a modal shift occurs.
6.1.3.14 All three options would result in the loss of agricultural land, most of which is the best and most versatile agricultural land. Large scale development also has the potential to impact upon air and water quality, and existing mineral resources. Option 1 would impact on agricultural land but Options 2 and 3 have some potential to improve on this outcome but with natural resources still present in many of these areas much will depend on the dispersal of development to least constrained areas and site specifics.
6.1.3.15 The potential impact on listed buildings and historic assets and their settings is site specific, and therefore it is uncertain how the approximate locations of growth may impact upon those factors. Negative impacts to the historic environment could be mitigated by ensuring that developments are sympathetic to local character and distinctiveness, and by ensuring that thorough archaeological investigations are carried out.
6.1.3.16 All options could have an impact on reducing the County Borough’s ability to adapt to flood risk as green space aids in land drainage. Increased urbanisation also has the potential to increase surface water flood issues. However there should be opportunities to mitigate or adapt to flood risk; for example the provision of sustainable urban drainage systems and by directing development away from flood risk areas.
6.1.3.17 All options would increase the number of households and business premises and therefore the absolute quantity of waste generated, however, there is potential to decrease per capita arising through the integration of recycling and composting facilities into new developments.
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Section 3: Appraisal of Strategic Policy Options
6.1.4.1 Strategic Policies form the framework for implementing and delivering the LDP’s vision, objectives and strategy. Where strategic policies may have spatial options in how the policy could be delivered, or where they have numeric targets that could be varied these are considered in this appendix.
6.1.4.2 However policies such SP13 Health & Wellbeing are general statements of policy, reasonable alternative options for these policies would be best considered as variations in policy wording, this is undertaken as part of the policy review in Appendix G of the SA report.
Table 6.4 Strategic Policy Policy Option
SP1 Housing Provision See above Section 1 SP2 Location of Development See Table 5 below SP3 Key Strategic Housing Sites See above Section 1 SP4 KSS1: Land at Lower Berse See Table 6 below Farm, Ruthin Road Wrexham SP5 KSS2: Land east of Cefn Road, See Table 6 below Wrexham SP6 Planning Obligations See Appendix G SP7 Green Wedge See Appendix G SP8 Wrexham Town See Appendix G SP9 Economic Growth Employment See Table 7 below and see appendix G and Enterprise SP10 Wrexham Industrial Estate See Appendix G SP11 Transport and Accessibility See Appendix G SP12 Design Principles & See Appendix G Masterplanning Framework SP13: Health and Wellbeing See Appendix G Policy SP14: Natural Environment See Appendix G Policy SP15: Historic and Cultural See Appendix G Environment Policy SP16: Minerals Supply and See Appendix G Safeguarding Policy SP17: Sustainable Waste See Appendix G Management Policy SP18: Climate Change See Appendix G
6.1.4.3 Alternative options have been generated for the following strategic policies; SP2 Location of New Development; SP3 Key Strategic Sites SP11 (Wrexham Industrial Estate Extension). The reasoning underpinning the choice of options (and rejection of unrealistic options) and assessment is contained within the commentary.
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Appraisal of Strategic Policy Options
Table 6.5 LDP Option Strategic Policy SP2: Location of New Development – Commentary on option generation. The following options were generated to help us understand what other sustainability trade-offs would result from reasonable alternative approaches. While a variety of national policies, plans and programmes and evidence bases have informed option generation it is worth noting that Background Paper 2 Settlement Hierarchy and Development Potential and the Candidate Site Register have been key sources of evidence.
BP2 has been used to help identify development opportunities in settlements (settlement function and services, potential sites to accommodate growth and broad constraints). From which many of the smaller tier 4-5 settlements have little development potential (limited or no candidate sites, site constraints etc.) and can be dismissed at a strategic level alone or in combination with other settlements.
Option 1 - Spatial strategy focussed on settlements in tiers 1-3
Option 2 – The growth strategy has environmental impacts, this option considers ways in which these can be reduced. Spatial strategies based on end of spectrum environmental options (e.g. focus development entirely in areas with low or no environmental constraint – low BMV value, low mineral, ecological, landscape or heritage constraint) are unrealistic, the areas in which these constraints are low are isolated and largely rural, they don’t have sufficient development opportunities (social, economic infrastructure) or candidate sites to meet the housing and employment growth figures.
However, using an environmental led option within the constraint of meeting the growth strategy is a realistic option. This option will help reveal if there are opportunities to provide environmental benefits e.g. spatial options that are less damaging to ecology, natural resources, landscape or character.
Option 3 - The last option to consider is a market viability led approach, this approach responds to viability and the best opportunities to extract development gain to fund requirements for affordable housing, education and highways infrastructure needs. The areas in descending order of viability (highest first) are Rural East, North Wrexham/Gresford South Wrexham, North West Settlements, Cefn Mawr & Rhos. Integrated Objective Option 1 – Settlement Hierarchy Option 2 – Environmental led Option 3 – Viability led tiers 1-4 Objective 1: Ensuring that This option could help deliver this In general the areas with low environmental In general the areas with low the role of Wrexham as a objective but much will depend on constraint are isolated rural villages with low environmental constraint are isolated key settlement of national how much development is delivered development opportunity. Development in rural villages with low development importance in the Wales outside Wrexham. these areas would provide limited strategic opportunity. Development in these Spatial Plan Wrexham – housing opportunities areas would provide limited strategic Deeside – Chester hub is housing opportunities strengthened; x x Objective 2: Support a The spatial strategy would support In general the areas with low environmental In general the areas with highest vibrant, diverse and the economic objectives of the plan; constraint are isolated rural villages with low viability rural villages with low competitive local economy building on the sub-regional role of development opportunity. Development in development opportunity. that provides a range of job Wrexham; help support Wrexham these areas would provide limited strategic Development in these areas would opportunities to enable new town centre regeneration building on employment opportunities but could assist provide limited strategic employment and existing businesses to VVP investment; support WIE and rural development. opportunities. grow in Wrexham town and support district and local centres. It Wrexham Industrial Estate; can also help deliver regeneration in Acrefair/Cefn Mawr. Page 63 of 129
x x Objective 3: Regenerate The spatial strategy would support In general the areas with low environmental In general the areas with highest Wrexham Town Centre as a the economic objectives of the plan; constraint are isolated rural villages with low viability would provide limited support multifunctional destination help support Wrexham town centre development opportunity. Development in for Wrexham town centre. for retail, education, civic, regeneration building on VVP these areas would provide limited support for amenity, employment, investment Wrexham town centre. leisure and residential uses; x x Objective 4a: Promote Spatial strategy focusses In general the areas with low environmental This approach would pull in Bradley, active travel and use of development in the primary constraint are isolated rural villages with low Bronington and Marchwiel as viable public transport by settlement of Wrexham, key development opportunity. Development in areas with moderate development locating new development settlements (tier 2) and local service these areas would increase the need to travel opportunities, all have limited facilities in the most sustainable centres (tier 3) – areas with the best and increase emissions. so would increase the need to travel. locations, and seek to opportunities to reduce the need to However, both have moderate or good alleviate known highway travel and promote sustainable Areas with moderate development sustainable transport options and in infrastructure capacity transport but much will depend on opportunities and low to moderate the case of Bradley and Marchwiel constraints on the road the scale of growth within the lower environmental constraint (Bradley, Bronington, they are close to Wrexham thereby network within the County tiers. Marchwiel, Rhosrobin & Southsea) are lower some mitigation is possible. Borough; tier 4 settlements with fewer services, these would increase the need to travel particularly Other viable areas, Bettisfield, Burton, by car. However, all have moderate to good Cross Lanes, Hanmer, Horseman’s sustainable transport options and all bar Green, Tallarn Green and Bronington are close to Wrexham, these Worthenbury have low development circumstances provide some mitigation. potential and are largely isolated settlements and with the exception of While transport mitigation may be possible on Cross Lanes have poor sustainable balance an environmental approach will travel options. increase the need to travel, particularly by car. x x x Objective 4b: Promote In principle a focus on Wrexham and By increasing the need to travel this option By increasing the need to travel this active travel and use of key settlements with the most would add to highway congestion. option would add to highway public transport by locating services and public transport would congestion. new development in the help reduce the need to travel but most sustainable locations, much will depend on site specific and seek to alleviate impacts and mitigation. known highway infrastructure capacity constraints on the road network within the County Borough; x x x Objective 5a: Facilitate This approach can meet the In general the areas with low environmental This approach would pull in Bradley, mixed diverse required housing demand but it also constraint are isolated rural villages with low Bronington and Marchwiel as viable communities by includes some areas of poor development opportunity. areas with moderate development
Page 64 of 129 delivering housing, viability; Acrefair/Cefn Mawr, opportunities. including affordable homes Penycae and Rhos together with The main opportunities are in Southsea, to meet the needs of the some areas of relatively average Bradley, Bronington, Marchwiel and Other viable areas in south west County Borough; viability (rural west, Chirk and the Rhosrobin, while all can supply housing, Wrexham (Bettisfield, Burton, Cross NW settlements). Consequently the Marchwiel and Bronington offer the best Lanes, Hanmer, Horseman’s Green, ability of development to deliver opportunity to supply wider housing needs Tallarn Green and Worthenbury) have housing and certainly to fund wider (relatively higher viability) followed by Bradley. low development potential but could community needs in these low contribute towards meeting wider viability areas is limited. In general an environmental approach would housing needs. draw in villages mainly but not only from more viable areas best able to fund wider community In general a viability led approach needs. would draw in villages from more viable areas best able to fund wider community needs. x Objective 5b: Facilitate The ability to meet affordable In general an environmental approach would In general a viability led approach mixed diverse communities housing needs will be constrained draw in villages mainly but not only from more would draw in villages from more by delivering housing, by the need to balance viability and viable areas best able to fund affordable viable areas best able to fund including affordable deliver infrastructure. housing. affordable housing. homes to meet the needs of the County Borough; x Objective 6: Promote and Spatial strategy focusses In general the areas with low environmental This approach would pull in Bradley, encourage a healthy, active development in the primary constraint are isolated rural villages with Bronington and Marchwiel as viable and safe lifestyle; settlement of Wrexham, key limited facilities and low development areas with moderate development settlement and local service centres opportunity. Development in these areas would opportunities, all have limited facilities – areas with the best opportunities reduce access to health facilities and would so would reduce access to health to access health facilities and take reduce opportunities to promote facilities. However, they have advantage of sustainable transport walking/cycling. moderate or good sustainable including walking/cycling. transport options and in the case of There are some exceptions, Bradley, Bradley and Marchwiel they are close On balance this option is positive in Marchwiel, Rhosrobin & Southsea, all are to Wrexham thereby some mitigation terms of access to health facilities close to Wrexham with good sustainable travel is possible. but neutral in terms of impact on options. Bronington is in relatively close open space capacity (dependent in proximity to Hanmer GP. Other viable areas, Bettisfield, Burton, mitigation). Cross Lanes, Hanmer, Horseman’s On balance this option is negative in terms of Green, Tallarn Green and access to health facilities and promoting Worthenbury have low development walking/cycling (except Bradley, Rhosrobin, potential and are largely isolated Southsea and Marchwiel) and neutral in terms settlements and with the exception of of impact on open space capacity (subject to Cross Lanes have poor sustainable mitigation by providing new spaces with travel options. development). On balance this option is negative in terms of access to health facilities and Page 65 of 129
promoting walking/cycling (except Bradley and Marchwiel) and neutral in terms of impact on open space capacity (subject to mitigation by providing new spaces with development). x x Objective 7a: Conserve, Site specific constraints and Site specific constraints and mitigation are Site specific constraints and mitigation enhance and promote the mitigation are critical critical are critical local culture, character and distinctiveness of Wrexham including the Welsh Language; x x x Objective 7b: Conserve, The strategy would impact on areas This option would put a larger proportion of This option would put a larger enhance and promote the of language sensitivity (Rhos, growth into rural villages in the west of proportion of growth into rural villages local culture, character and Coedpoeth, Glyn Ceiriog, Penycae), Wrexham, these rural areas (Glyntraian, in the east of Wrexham, while these distinctiveness of Wrexham mitigation may be required, subject Llanarmon Dyffryn Ceiriog etc.) are language areas are not language sensitive, including the Welsh to the scale of growth, to manage sensitive areas. Mitigation may be required, opportunities to sustain Welsh Language; the integration of development into subject to the scale of growth, to manage the speaking villages through new communities. integration of development into communities. development would be lost. x x x Objective 8 Ensure all Strategic highways, recreation, In general the areas with low environmental This approach would pull in Bradley, development is supported health, education and waste water constraint are isolated rural villages with low Bronington and Marchwiel as viable by the necessary provision constraints are key issues for development opportunity. areas with moderate development of, or improvements to Wrexham but viability is relatively opportunities. infrastructure, services and good therefore mitigation could be The main opportunities are in Southsea, facilities in an effective and possible. Bradley, Bronington, Marchwiel and Other viable areas in south west timely manner to make Rhosrobin, while all are in viable areas, Wrexham (Bettisfield, Burton, Cross development sustainable Elsewhere (Gresford/Marford, Marchwiel and Bronington offer the best Lanes, Hanmer, Horseman’s Green, and minimise its effect upon Overton, Penley, Rhostyllen & opportunity to supply wider infrastructure Tallarn Green and Worthenbury) have existing communities. Rossett) infrastructure constraints needs (relatively higher viability) followed by low development potential but could are in education (except Rossett), Bradley. contribute towards meeting wider recreation, health and local highway infrastructure needs. capacity, but again viability is In general, education and local highways relatively good so mitigation may be capacity are the biggest constraints in these Including the most viable areas would possible. areas, with recreation provision in Bronington enhance the potential for development and Marchwiel a potential constraint. to mitigate impacts on infrastructure However this option includes some provision. areas of poor viability which will If these areas are to be included in the spatial impact on the ability to deliver wider strategy then the LDP will need to demonstrate infrastructure; these areas are how these issues can be addressed. Acrefair/Cefn Mawr, Penycae and Page 66 of 129
Rhos together with some areas of relatively average viability (rural west, Chirk and the NW settlements. Particular constraints are; Acrefair/Cefn Mawr/Rhos – recreation capacity, waste water, education and local highways constraints; Broughton/ Brymbo/Chirk/Gwersyllt/ /Ruabon – recreation capacity, education and local highways constraints; Coedpoeth/Glyn Ceiriog – recreation and local highway capacity; Llay - education and local highway capacity; Penycae – Recreation and education.
The LDP will need to demonstrate how these issues can be addressed.
The ability to meet affordable housing needs will be constrained by the need to balance viability and deliver infrastructure. x x x Objective 9a: Protect, Largely the settlements in tiers 1-3 The main opportunity is in Southsea which has This approach would pull in Bradley, manage and enhance the have moderate ecological low ecological constraint. Bronington and Marchwiel with natural and historic constraints, some habitat mitigation moderate development opportunities. environment and may be required in association with Other villages with low ecological constraints landscapes; specific species e.g. newts; or have limited development opportunities, even Other viable areas, Burton, Cross protected sites near to settlements. cumulatively. Lanes, Hanmer, Horseman’s Green, Tallarn Green and Worthenbury have Potential cumulative impacts arise Bradley, Bronington, Marchwiel and Rhosrobin low development potential and from developments in newt rich have moderate ecological constraint, as the moderate ecological constraint areas (north and east of Wrexham LDP and detailed constraint assessments (Bettisfield has high constraint); and WIE); and recreation impacts on emerge these areas may be more ecologically mitigation may be possible and could SAC advantageous than other settlements/sites in provide ecologically better outcomes tiers 1-3. Subject to further consideration a than other settlements/sites in tiers 1-3 Development in Rhosllanerchrugog more positive effect could emerge. subject to detailed assessment. could potentially impact on the Johnstown Newt SAC site, This option would give flexibility in choosing This option would give flexibility in avoidance measures required. more ecologically advantageous areas or sites. choosing more ecologically advantageous areas or sites.
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x Objective 9b: Protect, Using the latest 2017 Predictive Focussing development into areas with the Bradley, Bronington and Marchwiel manage and enhance the Agricultural Land Quality Maps and least natural resource constraint would not be would be elevated into the spatial natural and historic actual survey results, tier 1 realistic, these areas are mainly small isolated strategy, but all have BMV constraint. environment and Wrexham and many of the tiers 2-3 settlements and lack development capacity. landscapes; settlements are surrounded by BMV. Other viable areas in north and south There are no villages outside tiers 1-3 with Wrexham and rural east have low There are some settlements within development opportunities and are free from development potential and high these tiers, Brymbo, Chirk, Llay and BMV constraint. Some sites in Marchwiel have mineral constraint. Coedpoeth with fewer BMV low BMV but score poorly on other constraint but development sustainability criteria (see Appendix I). A viability led approach would broadly opportunities may be limited. have a high impact on natural Limited potential to reduce impact on BMV but resources. Therefore it can be concluded that this is site specific. at a broad level this spatial option Limited potential to reduce impact on would be detrimental to BMV, there Increased development in smaller settlements BMV but this is site specific. is some flexibility between will increase the need to travel and increase settlements but wider transport related air pollution. sustainability/deliverability arguments need to be considered. x x x Objective 9c: Protect, In focussing development into the Directing all development to areas without Bradley, Bronington and Marchwiel manage and enhance the top three tiers it’s almost inevitable heritage constraints would not be realistic, would be elevated into the spatial natural and historic that these will be the largest and these areas are mainly small isolated strategy, the latter has moderate built environment and richest in terms of heritage. settlements and lack development capacity. environment constraint and the two landscapes; Consequently the majority of the former have low constraint. settlements have low/moderate However of the settlements outside tiers 1-3 constraints which will require with development capacity, Bradley, Other viable areas in north and south detailed consideration and mitigation Bronington and Rhosrobin have low built Wrexham and rural east have low as sites come forward. heritage constraint, Marchwiel and Southsea development potential and are largely have moderate constraint. Including these of low constraint with some moderate However at this level of assessment (subject to detailed site considerations) could constraint (Hanmer, Tallarn Green, no significant impacts on assets of provide some flexibility in site selection to Worthenbury). international or national value or avoid the worst environmental and heritage Welsh language have been impacts. Including these with mitigation where identified which could not be required on balance would not harm avoided by detailed consideration of heritage assets and could substitute sites. for areas/sites where there is harm. x Objective 9d: Protect, None of the growth areas are within An environmental led approach avoiding areas A viability led approach would focus manage and enhance the nationally designated landscapes of landscape constraint would help bring some development in the Maelor, east of natural and historic but development within flexibility into site selection by avoiding the Wrexham and other viable areas. This environment and Acrefair/Cefn Mawr, Chirk and most constrained sites. Though tiers 4-5 are would also pull into consideration tiers
Page 68 of 129 landscapes; Penycae (adjacent to the AONB) will largely rural in nature which would not be 4-5 settlements mainly in the Maelor. need to be mindful of the AONB appropriate in landscape terms for significant setting. growth and there would still be negative local Though tiers 4-5 are largely rural in impacts. nature which would not be appropriate Green barriers and SLA are subject in landscape terms for significant to review for the Deposit Plan. Some of the least constrained and accessible growth and there would still be tier 4 settlements (Bradley, Bronington, negative local impacts. Impacts will be of local significance Marchwiel, Rhosrobin & Southsea) are which may have some impact on relatively less constrained in landscape. Some of the least constrained, viable Green Barrier and SLA subject to and accessible tier 4 settlements detailed consideration of sites at (Bradley, Bronington, Marchwiel, Deposit stage. Rhosrobin & Southsea) are relatively less constrained in landscape. x x x Objective 10a: Reduce The scale of development prevents In general the areas with low environmental This approach would pull in Bradley, carbon emissions and placing all development in constraint are isolated rural villages with low Bronington and Marchwiel as viable maximise our resilience to Wrexham, the most accessible and development opportunity. Development in areas with moderate development and mitigate and adapt to sustainable location, there isn’t these areas would increase the need to travel opportunities, all have limited facilities the impact of climate sufficient capacity or sites to meet and increase emissions. so would increase the need to travel. change all the growth. However, the strategy However, both have moderate or good does focus on the most accessible Areas with moderate development sustainable transport options and in settlements in tiers 1-3 which can opportunities and low to moderate the case of Bradley and Marchwiel mitigate impacts on carbon environmental constraint (Bradley, Bronington, they are close to Wrexham thereby emissions with the best Marchwiel, Rhosrobin & Southsea) are lower some mitigation is possible. opportunities to reduce the need to tier settlements with fewer services, these travel and promote sustainable would increase the need to travel particularly Other viable areas, Bettisfield, Burton, transport thereby helping reduce per by car. However, all have moderate to good Cross Lanes, Hanmer, Horseman’s capita emissions. sustainable transport options and all bar Green, Tallarn Green and Bronington are close to Wrexham, these Worthenbury have low development There could also be co-locational circumstances provide some mitigation. potential and are largely isolated benefits to promote CHP and District settlements and with the exception of heat networks. While transport mitigation may be possible on Cross Lanes have poor sustainable balance an environmental approach will travel options. increase the need to travel, particularly by car. While transport mitigation may be possible on balance a viability led approach will increase the need to travel, particularly by car. x x Objective 10b: Reduce Broadly development is focused into Directing all development to areas with a low This approach would pull in Bradley, carbon emissions and areas with a moderate flood risk flood risk would not be realistic, these areas Bronington and Marchwiel with maximise our resilience to score where there is either an are mainly small isolated settlements and lack moderate development opportunities and mitigate and adapt to identified surface water risk and/or development capacity. (see left for impacts).
Page 69 of 129 the impact of climate limited areas of the settlement and change adjacent areas that fall under the However villages which could demonstrate Other viable areas in north and south fluvial C1/C2 flood category. sustainability benefits, Bradley, Bronington, Wrexham and rural east have low and Rhosrobin have a low risk, while development potential and are largely Rossett, Bangor and elements of Marchwiel and Southsea have a moderate of low risk with some at moderate risk Wrexham have a high flood risk flood risk. Including these villages in the spatial (Burton, Marchwiel, Worthenbury). score (though development potential strategy would reduce the overall flood risk in Bangor is low). profile. This option would have either a neutral impact on flood risk (including However, this does not imply that This option would have either a neutral impact settlements with the same risk profile specific sites in these areas have on flood risk (including settlements with the as the tier 3 settlements) or could offer flood risk. In some areas there may same risk profile as the tier 3 settlements) or opportunities to reduce risk. be a flood risk that does not impact could offer opportunities to reduce risk. on specific sites or mitigation /avoidance is possible.. x x x Objective 11: Ensure Potentially significant sand and Focussing development into areas with the This option gives small opportunities to development meets the gravel and coal resources around least mineral resource constraint would not be reduce impact on mineral resources needs of society and Wrexham would be sterilised. realistic, these areas are mainly small isolated industry, now and in the Extraction of mineral prior to the settlements and lack development capacity. future, through non-mineral development could ensuring adequate mitigate the loss but is likely to be Bronington has low mineral constraint, This protection and supply of limited due to the need to deliver option gives small opportunities to reduce high quality minerals; housing within the plan period and impact on mineral resources due to the need to create an appropriate landform. x Objective 12: Facilitate the Focusing employment growth on the Could result in a more dispersed distribution of Could result in a more dispersed provision of an integrated WIE enables waste facilities to be housing, further away from strategic waste distribution of housing, further away network of waste facilities closer to the source of the arisings facilities. from strategic waste facilities. which enable waste to be (Wrexham Town and WIE), thereby managed in a sustainable reducing the need to travel and way. enabling economies of scale to be achieved. x x Summary - An environmental led option would draw into the spatial strategy some settlements outside of the top 3 tiers with fewer facilities. Consequently this would increase the need to travel which would also impact on carbon emissions and reduce accessibility (health impacts); but some mitigation is possible in Bradley, Marchwiel, Rhosrobin and Southsea by their close proximity to Wrexham and with the availability of moderate or good sustainable transport options (which would also mitigate Bronington).
However, in other aspects an environmental led approach would have a neutral to positive effect; in terms of meeting housing needs Bradley, Bronington, Marchwiel and Rhosrobin have relatively good viability to help meet community needs (Southsea is viable but less so); In ecology, there are some limited
Page 70 of 129 opportunities to focus on lower constrained areas (Southsea) but more significantly areas with moderate ecological constraint, Bradley, Marchwiel and Rhosrobin could, subject to detailed site consideration, offer opportunities to swap with higher tier sites that are more ecologically harmful; in flooding, the impact would be neutral to a positive reduction of flood risk; impact on heritage would be positive (areas with low constraint – Bradley, Bronington, Rhosrobin) to moderate (Marchwiel and Southsea) which would require mitigation; in terms of natural resources there are limited opportunities to reduce impacts on mineral resources (Bronington) while other settlements would have a neutral to negative impact on BMV (Bradley, Marchwiel, Rhosrobin, Southsea) subject to further investigation; finally the impact on infrastructure provision is mixed, the more viable areas (Bradley, Bronington, Marchwiel) offer potential mitigation but in general there would be education, recreation and local highways issues to resolve.
However, much would be dependent on site specific assessments.
A viability led approach would have a similar impact as the environmental focus, drawing into the spatial strategy lower tier settlements that do not perform as well in reducing carbon emissions, accessibility and reducing the need to travel.
This option is the best performing in meeting the wider housing needs (e.g. affordable housing) and in being able to mitigate the impacts on infrastructure. Broadly the impact on the other objectives would be similar to the environmental option.
However, much would be dependent on site specific assessments. SA Issues Recommendations for the LDP
Pursuing an environment led spatial option would lead to increased If this option was to be pursued in the LDP then mitigation measures enhancing carbon emissions and traffic with reduced access to services. But this walking, cycling and public transport need to be considered. could offer positive effects for ecology, natural resources, landscape and heritage. However, opportunities to disperse development in this way are minor in scale. A viability led approach would also lead to a more dispersed development If this option was to be pursued in the LDP then mitigation measures enhancing pattern with similar effects as above. walking, cycling and public transport need to be considered.
Table 6.6 LDP Option Policy 2: Strategic Housing Sites (Policy SP3) – Commentary on option generation.
The option of not having a strategic housing site has been dismissed as unrealistic; Wrexham is the most sustainable location for development but there is an insufficient supply of land (viable and deliverable candidate sites and brownfield land) within the town to sustain its strategic role. Nor are there any other submitted candidate sites (small or large) adjacent to Wrexham that could cumulatively serve as an alternative.
The two Wrexham sites are the only sites of sufficient scale (>500 units) that could be considered to be strategic. However, a range of candidate sites have been submitted, by different representors, along the northern edge of Wrexham between Gwersyllt, Bradley and Rhosrobin. Collectively these sites could make a strategic contribution and as such will be considered here as a strategic option.
Integrated Objective Option 1 – Cefn Road (WR19CS) Option 2 – Lower Berse Farm (WR20CS) Option 3 – North West Wrexham (amalgamation of WR25, 26 & 27CS; GWE06CS GWE01 & 02OS; RR01 & 02CS; WR04, 06, 13 &22CS)
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Objective 1: Ensuring that Would positively support the role of Would positively support the role of Wrexham Would positively support the role of the role of Wrexham as a Wrexham and could help unlock development at the Wrexham. key settlement of national Western Gateway Business Park if the importance in the Wales development funded upgrades to the A483 Spatial Plan Wrexham – junction 4. Deeside – Chester hub is strengthened; Objective 2: Support a Provides a source of labour to The delivery of additional employment growth Provides a source of labour to support vibrant, diverse and support economic development and at the adjacent established Western Gateway economic development and Western competitive local economy Wrexham Industrial Estate. Business Park is constrained by the capacity Gateway. that provides a range of job at the A483 junction. This site could contribute opportunities to enable new to a solution to the junction and help unlock and existing businesses to employment opportunities. grow in Wrexham; Objective 3: Regenerate Adjoining Wrexham it will aid Close proximity to Wrexham town centre will Support for Wrexham Town Centre Wrexham Town Centre as a regeneration. support Wrexham Town Centre regeneration. regeneration. multifunctional destination Provides a local source of labour to support for retail, education, civic, economic development at the Western amenity, employment, Gateway. leisure and residential uses; Objective 4a: Promote Adjacent to Wrexham, a tier 1 Adjacent to Wrexham, a tier 1 settlement, with Adjacent to Wrexham and Gwersyllt, active travel and use of settlement, with access to all main access to all main functions (education, retail, tier 1&2 settlements, with access to all public transport by functions (education, retail, employment, health etc.). Opportunities to main functions (education, retail, locating new development employment, health etc.) but more promote active travel and sustainable employment, health etc.). in the most sustainable distant than option 2. Opportunities transport. Locally there is potential to link with Opportunities to access facilities in locations, and seek to to promote active travel and Western Gateway Business Park, Maelor Wrexham by foot or cycle are alleviate known highway sustainable transport. Locally there hospital and adjacent secondary school. constrained by the A483 and railway. infrastructure capacity is an existing link with WIE and constraints on the road adjacent secondary school. network within the County Borough;
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Objective 4b: Promote Development here will impact on Development here could contribute to Development here will impact on local active travel and use of local highway network, mitigation upgrading the strategic A483 junction 4 but highway network, mitigation will be public transport by locating will be required to deliver significant development could not proceed required to deliver development. new development in the development. without it. most sustainable locations, and seek to alleviate known highway infrastructure capacity constraints on the road network within the County Borough; x x x Objective 5a: Facilitate Site has positive viability and can Site has positive viability and can provide a Site has positive viability and can mixed diverse provide a significant scale of market significant scale of market housing in close provide a significant scale of market communities by housing close to employment proximity to employment opportunities (e.g. housing in close proximity to delivering housing, opportunities. Western Gateway). However, the site is employment opportunities (e.g. including affordable homes constrained by the capacity of junction 4 off the Wrexham town centre). to meet the needs of the A483, the delivery of housing during the plan County Borough; period is limited. However, the area is constrained by deliverability factors so the volume of housing during the plan period is limited. Objective 5b: Facilitate Site has positive viability and lies Delivery of affordable housing is constrained Within the Western Border Housing mixed diverse communities within the eastern housing market by the need to provide infrastructure to deliver Market area with a demand for by delivering housing, area with a demand for affordable. site (A483 junction, education) but some AH affordable housing. including affordable If local priority requires delivery of could be provided if local priority requires it but homes to meet the needs affordable housing from the site this is likely to be outside the plan period. Site can provide a significant scale of of the County Borough; viability could support it and the market housing and could contribute to delivery of supporting infrastructure delivery of affordable housing but infrastructure needed to support development (A483 junction and education) and viability is relatively lower. Objective 6: Promote and Location is accessible to all main Location is accessible to all main services and Some potential to integrate with encourage a healthy, active services and facilities. facilities. services in Wrexham and Gwersyllt to and safe lifestyle; encourage walking and cycling. Potential to integrate with services in Potential to be well integrated with services in Opportunities to provide open space Wrexham and Wrexham industrial Wrexham, the Western Gateway Business within the development. Much will estate to encourage walking and Park, hospital, adjacent secondary school and depend on the detailed site proposals. cycling. Opportunities to provide Clywedog Trail to encourage walking and open space within the development. cycling. Opportunities to provide open space Opportunity to improve accessibility to Page 73 of 129
Much will depend on the detailed within the development. Much will depend on services. site proposals. the detailed site proposals.
Opportunity to improve accessibility Opportunity to improve accessibility to to services. services.
Potential impact on air and noise quality due to proximity A483 and main arterial route into Wrexham but mitigation available. Objective 7a: Conserve, This would be a natural extension to This would be a natural extension to Wrexham, There would be a danger of settlement enhance and promote the Wrexham, impacts are site specific impacts are site specific but mitigation coalescence which may harm sense of local culture, character but mitigation possible. possible. identity. An amalgamated site would and distinctiveness of merge Wrexham, Gwersyllt, Rhosrobin Wrexham including the and Bradley, with a loss of local Welsh Language; identity and character but some parts may be more suitable (detailed candidate site assessment at Deposit stage will clarify this). x Objective 7b: Conserve, This site is not within language This site is not within language sensitive areas This site is not within language enhance and promote the sensitive areas sensitive areas local culture, character and distinctiveness of Wrexham including the Welsh Language; N/A N/A N/A Objective 8 Ensure all There is no primary school capacity. Junction with the A483 is not capable of taking Junctions with the A483 are at or development is supported Provision for school playing fields this scale of development. exceeding capacity and are not by the necessary provision required. capable of taking this scale of of, or improvements to There is no primary school capacity. development. infrastructure, services and Local highway capacity constraints. facilities in an effective and Surface water drainage solution required. There is no primary school capacity timely manner to make Surface water drainage solution and secondary schools may need development sustainable required. Relatively high viability to fund infrastructure, additional capacity. and minimise its effect upon infrastructure would be needed before existing communities. Relatively high viability to fund affordable housing could be supplied. Site crosses a number of viability infrastructure. market areas which are generally lower in value than the other two strategic options.
Surface water drainage solution required. Page 74 of 129
Significant infrastructure constraints and relatively lower viability, infrastructure would be needed before affordable housing could be supplied.
x x x Objective 9a: Protect, Ecological mitigation would be The site is mostly improved grassland of Major constraint is the GCN manage and enhance the required particularly regarding GCN, limited biodiversity value. However, there are population, ponds, supportive habitat natural and historic there are also features of local important features of local value (veteran trees and connectivity. Ecological mitigation environment and value. and indications of ancient woodland, ancient would be required particularly landscapes; hedgerows, ponds requiring survey on the site) regarding GCN, there are also Subject to further detailed survey and protected species may be present. features of local value (hedgerows and and mitigation local features could trees). be retained. There is a green corridor with excellent biodiversity value running through the site.
Subject to further detailed survey and mitigation local features could be retained. x x x Objective 9b: Protect, Land is dominated by grade 2 and Land is dominated by grade 2 and sub grade High proportion of the site is BMV manage and enhance the sub grade 3a, confirmed BMV 3a, confirmed BMV present across the majority agricultural land (Confirmed grade 1, natural and historic present across the majority of the of the site (recent site survey data). 2, 3, and 3a) on much of the site environment and site (recent site survey data). (recent site survey data). landscapes;
xx xx xx Objective 9c: Protect, Potential impact upon views to and Grade II* listed Lower Berse Farm is present Potential impact on setting of Lower manage and enhance the from Cefn Park, affecting wider on site, survey reveals archaeological value Stansty Farmhouse (listed) and Wats natural and historic setting of the Grade II Listed here. Mitigation on the listing and setting may Dyke SAM. environment and Building and parkland. This will be a be possible but will depend on detailed landscapes; consideration in the development of proposals and scale of development. the southern section of the site. Also identified archaeological issues related to the Bryn Estyn Estate and Tyn-twll. Mitigation on the listing and setting may be possible but will depend on detailed proposals and scale of development. x x x
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Objective 9d: Protect, No impacts on national landscape No impacts on national landscape No impacts on national landscape manage and enhance the designations but landscape designations but landscape sensitivities are designations but landscape natural and historic sensitivities are present (e.g. impact present (e.g. impact on landscape resources, sensitivities are present (e.g. impact environment and on landscape resources, visual visual character, listed building setting) that on landscape resources, visual landscapes; character, listed building setting and would reduce developable area if mitigation character, listed building setting) that parkland) that would reduce provided. would reduce developable area if developable area if mitigation mitigation provided. provided. Site not required to fulfil the purposes of Green Wedge. Elements of the site contribute to the Site not required to fulfil the purpose of green wedge. purposes of Green Wedge. x x x Objective 10a: Reduce Opportunities to reduce the need to Opportunities to reduce the need to travel due Opportunities to reduce the need to carbon emissions and travel due to proximity to Wrexham, to proximity to Wrexham, tier 1 settlement, travel due to proximity to Wrexham maximise our resilience to tier 1 settlement and WIE, WIE and Western Gateway, accessible to all (tier 1) and Gwersyllt (tier 2), and mitigate and adapt to accessible to all main town main town functions. Potential for low carbon accessible to all main town functions. the impact of climate functions. Potential for low carbon development. Walking /cycling options are less well change development. integrated with Wrexham. Potential for low carbon development. Objective 10b: Reduce Risk of surface water flooding, Risk of surface water flooding and on a limited Risk of surface water flooding, further carbon emissions and further investigation and mitigation part of the site fluvial flooding, further investigation and mitigation required at maximise our resilience to required at application stage. investigation and mitigation required at application stage and mitigate and adapt to application stage the impact of climate Surface water run-off will require Surface water run-off will require change managing to prevent causing Surface water run-off will require managing to managing to prevent causing flooding flooding elsewhere. prevent causing flooding elsewhere. elsewhere.
SuDS required but possible. SuDS required but possible. SuDS required but possible. x x x Objective 11: Ensure Development of the site would Development of the site would sterilise sand Site is largely underlain by sand and development meets the sterilise sand and gravel beneath brick clay and coal beneath the site and gravel and coal. Development would needs of society and the site and beyond the site. Some sterilise coal beyond the site. sterilise these resources. Some of the industry, now and in the of the sand and gravel is already resources are already sterilised by future, through sterilised by adjacent sensitive adjacent development. ensuring adequate development. protection and supply of high quality minerals; x x x Objective 12: Facilitate the N/A at this level of assessment provision of an integrated network of waste facilities which enable waste to be managed in a sustainable Page 76 of 129 way.
Summary All options can provide a significant amount of housing but highway constraints limit delivery from Lower Berse Farm and deliverability issues limit the amalgamated site. The two Wrexham sites have the highest market values to fund infrastructure and provide affordable housing. Option 3, an amalgamation of sites across various market areas, has pockets of relatively high value but on balance values are lower than the Wrexham site, therefore the ability to fund infrastructure and affordable housing is relatively lower.
Option 1 (Cefn Road) is best placed to provide affordable housing with good viability.
Option 2 (Lower Berse farm) could help address the A483 capacity issues, unlock employment potential at the Western Gateway Business Park and support the growth of Wrexham Town Centre.
Option 3 (North West Wrexham amalgamation) could help supply affordable housing in an area in need, however the ability to provide affordable housing is perhaps constrained by viability and infrastructure costs.
All options have mixed effects on biodiversity/ecological issues, particularly option 1 Cefn Road and option 3 which are constrained by Great Crested Newt Populations with European protection.
All options have very negative effects on natural resources leading to the loss of the best and most versatile agricultural land and loss/sterilisation of mineral resources (coal, sand and gravel).
Landscape impacts would be negative across all options with local impacts, option 3 would have some impact on the purposes of Green Wedges in specific areas within the amalgamated site.
In choosing strategic sites option 1 is best placed to provide affordable housing and/or wider infrastructure; option 2 can help address A483 capacity and unlock employment opportunities and could also provide some affordable housing (again demand is limited); while option 3 has lower viability to deliver infrastructure and affordable housing but it is located in an area with a demand for affordable housing, subject to viability the site could contribute to meeting these needs. SA Issues Recommendations for the LDP With all options there is a balance between how much the sites support LDP to be clear what the priorities for the sites are, with mitigation to address infrastructure and how much affordable housing they provide. infrastructure and/or affordable housing. Option 3 would have less positive effects on reducing carbon emissions. If this option was taken forward then mitigation measures to be considered in Deposit plan. Options 1 and 3 could impact on GCN populations. LDP to take a strategic approach to protecting GCN populations, habitats, ponds and connectivity. Local ecological and biodiversity features could be lost Mitigation measures required in Deposit plan. Potential surface water flood risk LDP to have a policy mechanism to ensure flood consequences are understood and mitigated (e.g. strategic design policy, Deposit plan and at design stage) Sites have impact on setting of listed buildings and potential impact on a LDP to mitigate negative impacts. SAM Option 3 could impacts on local identity and character LDP to mitigate and remove some areas of the site from development boundary if this option taken forward. Page 77 of 129
Loss of the best and most versatile agricultural land The loss of BMV is inevitable with a strategic site Loss of mineral resources Consider prior extraction Infrastructure needed to support development (A483 junction, education, Policy mechanism to deliver infrastructure (CIL or section 106) established in open spaces) LDP.
Table 6.7
LDP Option – LDP Option Policy 3: Strategic Employment Allocation (SP11) – Commentary on option generation.
The Employment Land Review 2015 identified a need for an additional allocation of between 20-30 hectares at Wrexham Industrial Estate (WIE) arising from strong demand and supply constraints. In looking for alternatives to WIE, the report has not identified demand for additional employment land at other key sites (Llay, Wrexham Technology Park) or areas of the County Borough. Therefore the area of search for employment land allocations concentrates on WIE. While the ELR has not made recommendations for employment allocations beyond WIE, for the purposes of the SA, sites around Wrexham have been considered (proximity to Wrexham, the A483 and wider markets and availability of candidate sites makes this a realistic option).
In generating alternatives adjacent to Wrexham, there are limited sites of the scale needed, the two Key Strategic Sites (Lower Berse Farm and Bryn Estyn Lane have been proposed as housing sites and can be ruled out. However, sites along Mold Road (WR25/26/27 – see plan below) have been proposed as mixed use, as a combined site these could deliver the scale of development required. Their proximity to Wrexham and relative proximity to WIE and the A483 make these reasonable alternatives.
Meeting the demand from within WIE on existing land has been dismissed by the ELR; long term supply is relatively small; most sites have plans for change or are held for the expansion of specific firms, there are significant ecological constraints, supply of sites does not match the demanded format or quality and vacancies are low suggesting an undersupply.
In looking for extensions to WIE, significant allocations of this scale require highway capacity which is provided by the recently completed WIE link roads, therefore two ‘areas of search’ around the northern and southern link roads have been identified (see plan A). Alternative locations on the edge of WIE are limited by access, ecology, flooding and highways.
Integrated Objective Option A – WIE North Option B – WIE South Option C – Site WR25/26/27CS Objective 1: Ensuring that Would positively support the role of Would positively support the role of Wrexham Would positively support the role of the role of Wrexham as a Wrexham Wrexham. However it is not certain key settlement of national there would be demand in this importance in the Wales location. Spatial Plan Wrexham – Deeside – Chester hub is strengthened; x
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Objective 2: Support a The area could accommodate the The area could accommodate the required The area could accommodate the vibrant, diverse and required scale of development in an scale of development in an area with an required scale of development with competitive local economy area with an identified need with identified need with opportunities to provide a opportunities to provide a range of that provides a range of job opportunities to provide a range of range of employment types and unit sizes. employment types and unit sizes. opportunities to enable new employment types and unit sizes. However, it is not certain that there and existing businesses to would be demand in this location for grow in Wrexham town and Slightly closer than option B to the general industrial and commercial Wrexham Industrial Estate; A483, a key transport link. employment, the ELR was explicit in identifying demand in WIE. x Objective 3: Regenerate Marginal direct impact on Wrexham Marginal direct impact on Wrexham Town Marginal direct impact on Wrexham Wrexham Town Centre as a Town Centre Centre Town Centre multifunctional destination for retail, education, civic, amenity, employment, leisure and residential uses; ? ? ? Objective 4a: Promote Allocating more employment will Allocating more employment will increase the Allocating more employment will active travel and use of increase the need to travel arising need to travel arising from development increase the need to travel arising public transport by from development activity, but given activity, but given the need to grow, the close from development activity, but given locating new development the need to grow, the close proximity to Wrexham’s labour force which can the need to grow, the close proximity in the most sustainable proximity to Wrexham’s labour force access good public transport and sustainable to Wrexham’s labour force which can locations, and seek to which can access good public travel options provides opportunities to reduce access good public transport and alleviate known highway transport and sustainable travel the need to travel. sustainable travel options provides infrastructure capacity options provides opportunities to opportunities to reduce the need to constraints on the road reduce the need to travel. travel. Walking /cycling options are network within the County less well integrated with Wrexham. Borough; Slightly closer than option B to the A483, a key transport link. ? Objective 4b: Promote No significant impacts on highway No significant impacts on highway Impacts on the A483 junction 5, a key active travel and use of infrastructure arising from this infrastructure arising from this option. strategic junction that exceeds public transport by locating option. capacity. new development in the most sustainable locations, and seek to alleviate known highway infrastructure capacity constraints on the road network within the County Borough; x
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Objective 5a: Facilitate N/A mixed diverse communities by delivering housing, including affordable homes to meet the needs of the County Borough; Objective 5b: Facilitate N/A mixed diverse communities by delivering housing, including affordable homes to meet the needs of the County Borough; Objective 6: Promote and Positive impact on economic factors, Positive impact on economic factors, impact on Positive impact on economic factors, encourage a healthy, active impact on environmental factors environmental factors (noise, air quality) may impact on environmental factors and safe lifestyle; (noise, air quality) may require require mitigation and avoidance at detailed (noise, air quality) may require mitigation and avoidance at detailed design stage required. mitigation and avoidance at detailed design stage required. design stage required. x x x Objective 7a: Conserve, Natural extension to Wrexham Natural extension to Wrexham Industrial Potential issues of coalescence with enhance and promote the Industrial Estate, impacts are local Estate, impacts are local with mitigation at adjoining settlements local culture, character with mitigation at design stage design stage and distinctiveness of Wrexham including the Welsh Language; x x x Objective 7b: Conserve, This site is not within language This site is not within language sensitive areas This site is not within language enhance and promote the sensitive areas sensitive areas local culture, character and distinctiveness of Wrexham including the Welsh Language; N/A N/A N/A Objective 8 Ensure all Capacity may be required at Five Capacity may be required at Five Fords Junction with A483 junction 5 development is supported Fords Treatment works, detailed Treatment works, detailed modelling would be approaching capacity. by the necessary provision modelling would be required for required for specific schemes. of, or improvements to specific schemes. CIL not viable for commercial and infrastructure, services and WIE Southern link road is adjacent with industrial development, if an upgrade facilities in an effective and WIE Northern link road is adjacent capacity. Access possible into the site. to the junction were required this timely manner to make with capacity. Access possible into would have to be funded from S106 or development sustainable the site. CIL not viable for commercial and industrial funded via CIL. and minimise its effect upon development. existing communities. CIL not viable for commercial and This option may be dependent on CIL Page 80 of 129
industrial development. (funded from non-commercial/ employment development) to deliver the junction upgrades. xx Objective 9a: Protect, Major constraint is the GCN Major constraint is the GCN population, ponds, Major constraint is the GCN manage and enhance the population, ponds, supportive supportive habitat and connectivity. Ecological population, ponds, supportive habitat natural and historic habitat and connectivity. Ecological mitigation would be required particularly and connectivity. Ecological mitigation environment and mitigation would be required regarding GCN, there are also features of local would be required particularly landscapes; particularly regarding GCN, there value (hedgerows and trees). regarding GCN, there are also are also features of local value features of local value (hedgerows and (hedgerows and trees). Substantial set aside mitigation areas provided trees). in this search area in association with the link Potential to provide GCN mitigation road. Severe constraint to the site. and improved wildlife corridors. x x x Objective 9b: Protect, The majority of this site is confirmed This site is confirmed as being BMV grade 2 High proportion of the site is BMV manage and enhance the as grade 3b or a mosaic with small and 3a. agricultural land (Confirmed grade 1, natural and historic quantities of BMV. 2, 3, and 3a) on much of the site. environment and Site is largely underlain by sand and gravel landscapes; Site is largely underlain by sand and and coal reserves, development would sterilise Site is largely underlain by sand and gravel and coal reserves, these resources. Some of the resources are gravel and coal reserves, development development would sterilise these already sterilised by adjacent development. would sterilise these resources. Some resources. Some of the resources of the resources are already sterilised are already sterilised by adjacent by adjacent development. development. x xx xx Objective 9c: Protect, No known constraints. No known constraints. Potential impact on setting of Lower manage and enhance the Stansty Farmhouse (listed). natural and historic environment and landscapes; x Objective 9d: Protect, Impacts would be of local value, site Impacts would be of local value, site is not SLA Impacts would be of local value, manage and enhance the is not SLA or in the Green Wedge or in the Green Wedge elements of the site contribute to the natural and historic purpose of green wedge. environment and landscapes; x x xx Objective 10a: Reduce Allocating more employment will Allocating more employment will increase Allocating more employment will carbon emissions and increase carbon emissions arising carbon emissions arising from travel and increase carbon emissions arising maximise our resilience to from travel and development development activity, but given the need to from travel and development activity, and mitigate and adapt to activity, but given the need to grow, grow, the close proximity to Wrexham’s labour but given the need to grow, the close the impact of climate the close proximity to Wrexham’s force which can access good public transport proximity to Wrexham’s labour force change labour force which can access good and sustainable travel options provides which can access good public public transport and sustainable opportunities to reduce the need to travel. transport and sustainable travel Page 81 of 129
travel options provides opportunities options provides opportunities to to reduce the need to travel. reduce the need to travel. Walking /cycling/public transport options are less well integrated with Wrexham.
Objective 10b: Reduce Surface water will need to be There is some flood risk (C2) within the search Risk of surface water flooding, further carbon emissions and mitigated and managed. area but this may not limit the delivery of the investigation and mitigation required at maximise our resilience to site, surface water will need to be mitigated application stage and mitigate and adapt to and managed. the impact of climate change x x x Objective 11: Ensure No minerals of economic value Clips sand and gravel resources but these are Site is largely underlain by sand and development meets the already sterilised by proximal development. gravel and coal reserves, development needs of society and would sterilise these resources. Some industry, now and in the of the resources are already sterilised future, through by adjacent development. ensuring adequate protection and supply of high quality minerals; x Objective 12: Facilitate the Provides opportunities for waste Provides opportunities for waste management Provides opportunities for waste provision of an integrated management facilities should these facilities should these be required close to the management facilities should these be network of waste facilities be required close to the source of source of arisings. Waste management uses required. Located away from the which enable waste to be arisings. Waste management uses may struggle to compete with land values Wrexham Industrial Estate which managed in a sustainable may struggle to compete with land generated by other development. accommodates a number of other way. values generated by other waste management uses and is a development. source of arisings. x Summary and Conclusion The most sustainable option is area A (North of the estate), while closely matched with site B, site A isn’t constrained by agricultural land and has less constraints with ecology. In terms of economic performance it is slightly closer to markets accessed from the A483. If site A was taken forward, landscape and surface water flooding mitigation would be required. The delivery of sites A and B would not require significant upgrades to the highways network.
Site C is the worst performing option, it would lead to the loss of BMV, would impact on the Green Wedge and there is also doubt whether the site would be in the right location to meet the identified need. It may also impact on the A483 junctions with the local road network as junction 5 is approaching/exceeding capacity. Development of this site for employment use may not be able to address the concerns and would be dependent on CIL (funded from non- employment development i.e. housing) to deliver the necessary infrastructure which would a) impact on the delivery and timing of a strategic employment allocation b) would compete with the need to provide education and open spaces that support housing growth. SA Issues Recommendations for the LDP Option A is the most sustainable Proceed with option A for more detailed analysis Ecology, flooding, pollution and heritage constraints Detailed mitigation and avoidance measures to be used as schemes for the area come forward.
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6.2 How consideration of the social, environmental and economic issues determined the choice of the preferred options.
6.2.1 The chosen LDP options were growth option 2 (table 6.1), spatial option 3 (table 6.3), Key Strategic Sites Options 1 & 2 (Lower Berse Farm and Cefn Road – table 6.5) and WIE North for the employment allocation (table 6.7). The relationship to integrated objectives is summarised in table 6.8 below;
Table 6.8; Chosen LDP Options;
Growth Strategic Key WIE Extension Option 2 (10 Spatial Strategic (North of WIE) year Option 3 Sites (KSS1, migration) (hybrid) KSS2) 1 Wrexham Key The highest Retains the KSS1, KSS2 and Fully aligns with this Settlement growth option economic the extension to objective was chosen, this prominence of WIE are in presents the Wrexham but Wrexham so greatest potential there is a dilution fully support this to support this of the impact of objective. objective. development 2 Economy The highest Neutral, Neutral, limited The chosen option is growth option dependent on scope to make better performing in was chosen, this spatial location of choices with real meeting an identified presents the growth differences. need, uncertain whether greatest potential the option north West of to support this Wrexham would meet objective. demand.
3 Wrexham Town Supports Slightly dilutes Neutral, limited Neutral, limited scope to Centre Wrexham’s role benefits to the scope to make make choices with real and the town town centre, choices with real differences centre, higher some trade could differences. growth could be lost to district/ create higher local/ demand for neighbourhood/ services within village centre and the town leakage outside the County Borough 4a Active Travel Neutral Dispersal Neutral, limited No significant difference weakens scope to make between options opportunities to choices with real promote active differences. travel. 4b Highway Impacts are Neutral, The shift in No significant difference Capacity uncertain, trip dependent on development in performance of levels will spatial location of focus to KSS2 options in WIE, but increase but the growth helps avoid these perform better impact on capacity issues than employment capacity is site with the A483 development north west specific. junctions. of Wrexham 5a Communities Higher growth More positive Neutral, limited N/A provides positive benefits than scope to make benefits in other spatial choices with real
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meeting the options; dispersal differences housing needs of meets housing the County needs throughout Borough the County Borough, including rural housing; improves viability to deliver better communities 5b Affordable High growth Dispersal helps Neutral, limited N/A Housing provides positive meets affordable scope to make benefits in housing need choices with real meeting the more equitably differences housing needs of throughout the the County County Borough Borough and gives including opportunities to affordable pick more viable housing. sites to deliver it. 6 Health & Wellbeing Impacts on health Impacts mixed; No significant No significant difference mixed, much will preferred option difference in in performance of depend on spatial improves performance of options, all would require distribution and economic and options mitigation measures. mitigation housing related measures. health impacts, improves viability to address infrastructure, but much is still dependent on detailed site selection and mitigation 7 Character Impacts are Neutral, Neutral, limited No significant difference mixed, much will dependent on scope to make in performance of depend on spatial spatial location of choices with real options, all would require distribution and growth differences mitigation measures. mitigation measures. 8 Infrastructure Impacts are Spatially avoiding Neutral, limited The preferred option is mixed, much will infrastructure scope to make the best performing, WIE depend on spatial capacity choices with real link road already distribution and constraints is not differences provided. The worst site, mitigation realistic for North West Wrexham is measures. strategic levels of constrained by A483 growth but the junction capacity, does spatial approach not have the viability to avoids and address the constraint mitigates and would be dependent significant on non-employment constraints. development on the site or CIL. Key infrastructure constraints (J4/5 of the A483, Five Fords Waste Water treatment
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works and education) will need upgrading but these could not be avoided by alternative approaches and can be effectively mitigated through the plan. 9a Ecology Highest growth All options will All options have All options constrained option has have negative a mixed impact by need to provide potentially more impacts on local on local features strategic GCN negative impacts features though that would mitigation. on local ecology, dispersal gives require though avoidance some flexibility to mitigation. and mitigation choose better may be possible. performing sites. 9b Natural Negative impacts The preferred No significant The preferred option is Resources on BMV around option improves difference in best performing by Wrexham, affects on the other performance of avoiding loss of BMV reduced with less spatial options, options, all (actual survey) that growth but the the dispersed would lose BMV would arise from higher growth approach (actual and developing the other option was provides some predictive options. chosen flexibility in site mapping). selection to help avoid negative impacts on BMV etc. 9c Historic Uncertain Impacts are site No significant The site south of WIE impacts, potential specific so all difference in (dismissed option) is the to impact on options have performance of best performing with no heritage but uncertain impacts options, all impacts on the setting of mitigation may be on local features would impact on listed buildings. available setting of listed farm buildings. 9d Landscapes Highest growth All options will All options The chosen option option has have negative impact on local would not impact on potentially more impacts on local landscapes and green wedge unlike NW negative impacts features though all options would Wrexham. on local dispersal gives require a re- landscapes, some flexibility to drawing of the though avoidance choose better Green Wedge and mitigation performing sites. boundary - this may be possible. would not compromise its function in the Preferred option but would require mitigation in the North West Wrexham option. 10a Carbon The higher the A more dispersed All options All options provide Emissions growth the approach will provide opportunities to mitigate greater the increase the need opportunities to against the harmful increase in to travel with mitigate against effects of growth by
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carbon emissions associated the harmful locating development in emissions. Effects effects of growth locations close to more negative by locating Wrexham, with than other spatial development in sustainable transport options. locations close and active travel options to Wrexham, but the preferred option with sustainable has marginally better transport and connections. There active travel could be co-location options but the benefits for heat and preferred options power options. have better connections. 10b Climate Change Uncertain Uncertain No significant No significant difference Resilience impacts, potential impacts, potential difference in in performance of to impact on flood to impact on flood performance of options, all would require risk but mitigation risk but mitigation options, all mitigation measures. available available would require mitigation measures. 11 Minerals Higher growth The preferred No significant The preferred option is would give less option improves difference in best performing by scope to avoid on the other performance of avoiding loss of mineral impacts on spatial options, options, all resources. minerals which the dispersed would impact on are located approach important around most tier provides minor minerals 1-3 settlements flexibility in site selection to help avoid negative impacts on Minerals. 12 Waste Growth will No significant No significant No significant difference increase waste difference difference in in performance of generation but between options. performance of options impacts on per options capita waste are uncertain
6.2.2 In conclusion, the preferred strategic growth option 2 is more ambitious than option 1 in terms of providing homes and employment growth. The socio-economic benefits of growth are seen to outweigh the negative impacts on carbon emissions, local ecology, landscapes, natural resources and increase in traffic. In mitigation development in the most sensitive ecological and landscape features has been avoided but all growth options would harm agricultural land assets and impact on mineral resources.
6.2.3 The spatial strategy builds on the socio-economic benefits of growth by spreading the benefits into the more sustainable locations and rural areas. To mitigate the impacts on carbon emissions and traffic generation while supporting sustainable development principles, settlements which can reduce the need to travel and support sustainable transport/active travel (tier 3 settlements) form the core of the strategy and allocations. Lower tier settlements supplement tier 3 settlements but would only make a limited contribution through windfall development.
6.2.4 The choice of Key Strategic sites responds to the social and economic objectives in growing Wrexham as the most sustainable location and driver for the sub-regional economy. The sites
Page 86 of 129 support Wrexham town centre. The sites can make a significant contribution to meeting housing needs, though the ability to deliver affordable housing varies. All strategic site options would negatively impact on natural resources, in particular BMV Agricultural land19 and mineral resources. All options would impact on ecology, landscapes, heritage, flood risk (surface water) and minerals but mitigation and avoidance measures may address many of the issues.
6.2.5 In terms of minerals, prior extraction (which is the mitigation) won’t address the issue since the majority of the mineral can’t be extracted without compromising the subsequent housing development. The LDP and the SA have sought to minimise the impact that the LDP would have on the loss of mineral, however, it is evident that some loss would occur unless a new town option is chosen which is not sustainable or feasible given the housing number required and would conflict with national policy.
6.2.6 The employment site area of search responds to an evidence based need for an expansion to Wrexham Industrial Estate where there is a proven demand. The area is accessible, has highways infrastructure in place and is free of agricultural land constraint. Mineral constraints are also limited in this area and any loss is considered unlikely to have an impact on commercially viable resources.
6.3 Which other options were rejected.
6.3.1 Growth Zero Growth Option – people are living longer, births are increasing and due to economic progression, people will migrate to the County Borough both on a local/national level and internationally. Population Led Options – BP01a - Population and Household Projections with Dwelling and Employment Impacts Revised (Feb 2016); Population and household projections with dwelling and employment impacts, details population projections that were rejected including low migration, altered household membership rates and 2008-based 5 year migration trend. Dwelling Led Options – BP01a also discounted options based on 2001 census data, highest past completions and 5/10/13 year completion levels discounted as too low in meeting growth aspirations. Employment Led Options – BP1 rejected sectoral analysis led growth as too low, economic baseline projections rejected as too low in face of Ministerial advice and 10 year take up rejected as not matching sectoral analysis.
6.3.2 Spatial Within settlement limits/brownfield – Insufficient supply of viable and deliverable sites capable of meeting even the lowest migration based growth trend, this is essentially the current ‘business as usual’ scenario. The Unitary Development Plan has passed its end date and has built out nearly all its allocations, the UDP focusses development within existing settlement limits, yet the plan is not delivering anything like the number of houses needed to meet the growth options. End of Spectrum (Strategy focussed on land of low ecological/agricultural/mineral value etc.) – End of spectrum environmental options (e.g. focus development entirely in areas with low or no environmental constraint – low BMV value, low mineral, ecological, landscape or heritage constraint) are unrealistic as these areas are isolated and largely rural, they don’t have sufficient development opportunities (social, economic infrastructure) or constraint free candidate sites capable of making a strategic contribution to housing and employment land supply. Significant
19 Based on actual survey and predictive mapping
Page 87 of 129 development in these villages would be contrary to National Planning Policy for Sustainable Development Patterns. New Town – Does not comply with the National Planning Policy search sequence which starts with the use of previously developed land and buildings within settlements, then settlement extensions and then development around settlements with good public transport links. New settlements on greenfield sites are unlikely to be appropriate in Wales and should only be proposed where they offer significant environmental, social and economic advantages over settlement expansion (PPW 9.2.7). WwTW Capacity – A spatial strategy that avoids capacity constraints at Five Fords Waste Water Treatment Works has been dismissed as technically and viably unfeasible and unsustainable. Over 70% of the current population including tier 1 Wrexham and several tier 2-3 settlements (Broughton, Coedpoeth, Rhos.) are served by Five Fords, the remaining 30% of the population are served by 16 treatment works or none at all, strategically Five Fords is the only treatment works of a scale to take growth and operate within NRW consent restrictions. Other treatment works would require major capacity upgrades via AMP7 or developer contributions anyway (if such works were feasible and could operate within NRW consents). Funding and deliverability is more likely for strategic works at Five Fords than a piecemeal approach at other works and is less likely to have consent issues with NRW (other works largely feed into smaller rivers with reduced flows). Diverting growth to smaller tier 4-5 settlements would not be sustainable, Cefn Mawr could potentially be upgraded (and feeds into the Dee) but is in a market area with very poor viability and deliverability. A483 Junctions - A spatial strategy that avoids capacity constraints with the junctions between the A483 and Wrexham have been dismissed as unfeasible and unsustainable. Around 90% of the population live in locations that would impact on junctions 3-6 of the A483. Strategic growth in the Maelor and north of Wrexham (less dependent on accessing Wrexham via the A483) would not be sustainable.
6.3.3 Key Strategic Sites No strategic sites - The option of not having a strategic housing site has been dismissed as unrealistic; Wrexham is the most sustainable location for development but there is an insufficient supply of land (viable and deliverable candidate sites and brownfield land) within the town to sustain its strategic role. Nor are there any other submitted candidate sites (small or large) adjacent to Wrexham that could cumulatively serve as an alternative. No Employment Land Extension - Meeting the demand from within WIE on existing land has been dismissed by the ELR; long term supply is relatively small; most sites have plans for change or are held for the expansion of specific firms, there are significant ecological constraints, supply of sites does not match the demanded format or quality and vacancies are low suggesting an undersupply.
6.4 Any proposed mitigation measures.
6.4.1 The way the choice of options has been determined (section 6.2) provides high level mitigation. Additional to these there are specific measures that have been (Deposit Plan Strategic and Detailed Policies) inserted into the Deposit Plan.
6.4.2 The strategic and detailed policies deliver the plan strategy and provide mitigation to alleviate and reduce the worst effects; enhanced walking/cycling connectivity and public transport improvements; strategic approach to ecological connectivity particularly WIE and around Wrexham; surface water flooding and waste water disposal; impacts on heritage assets and local distinctiveness, promotion of higher density development, where appropriate, to reduce greenfield land take; prior extraction of minerals where appropriate:
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Table 6.1 SA Effect Identified in Assessment Policy Mitigation Increased Carbon Emissions and air SP3/SP4/SP5 Key Strategic Housing Sites are the primary pollution source of housing supply to reduce the need to travel and maximise opportunities for active travel and sustainable transport.
SP6 Planning Obligations provides hooks to support sustainable travel
SP8 focuses development into Wrexham the most sustainable location.
SP11 WIE extension focuses development into Wrexham IE, the most sustainable location.
SP18 supports development that diverts waste from landfill and avoid overprovision of disposal capacity (landfill produces methane).
SP19 Climate Change and SP20 Green Infrastructure policies inserted into the plan
Detailed Policies DM1, NE1, NE2, NE3, T1, T2, T3, T4, T5, T6, R1, RE1-2, MW5, MW6 Ecology Impacts SP10 Wrexham Industrial Estate protects ecological networks
SP13 Design Principles establishes a framework with which to identify key design considerations local features and justify site design
SP15 Provides strategic protection for biodiversity
SP20 Green Infrastructure policy inserted into the plan
Detailed Policies DM1, NE1, NE2, NE3, NE4, NE5, NE6, BE2 Landscapes impacts SP7: designates Green Wedges to protect local character
SP13 Design Principles establishes a framework with which to identify key design considerations local features and justify site design
SP20 Green Infrastructure policy inserted into the plan
Detailed Policies DM1, NE1, NE2, NE3, NE4, NE5,
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Traffic Increases SP3/SP4/SP5 Key Strategic Housing Sites are the primary source of housing supply to reduce the need to travel and maximise opportunities for active travel and sustainable transport.
SP6 Planning Obligations provides hooks to address this concern
SP11 WIE extension focuses development into Wrexham IE, the most sustainable location to support sustainable transport
SP12 Transport enhances the transport network in a sustainable manner.
Detailed Policies DM1, T1, T2, T3, T4, T5, T6 Historic Assets SP16 Provides protection Detailed Policies DM1, BE1, BE2 Natural Resources Detailed Policies DM1, NE6 Natural Resources (minerals) SP17: Requires prior extraction and minimises the need for raw materials Detailed Policies MW1-MW5 Economy SP9: Provides balanced growth while supporting key strategic strength of Wrexham and WIE.
Detailed Policies EM1: EM4, EM5 Local Character and Distinctiveness Strategic Policies SP4/5, SP6, SP7, SP11, SP13, SP16, SP20,
Detailed Policies DM1, NE1, NE2, NE3, NE4, NE5, BE1, BE2, R1-R6, CF1-CF3, WL1 Waste Water Infrastructure Strategic Policies SP2, SP6, SP8, SP20 Constraint Detailed Policies DM1, NE6
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7. Appraisal of Strategic and Detailed Policies
“the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (SEA Directive Annex I(f))
“an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know‐how) encountered in compiling the required information” (SEA Directive Annex I(h))
7.1 Significant social, environmental and economic effects of the strategic policies. This section discusses the main sustainability impacts of the LDP's strategic policies (table 7.1) which are shown summarised in Table 7.2 and Table 7.3, the full appraisal is contained in Appendix G.
Table 7.1: Strategic Policies
SP1: Housing Provision SP2: Location of New Development SP3: Key Strategic Sites SP4: KSS1 Land at Lower Berse Farm, Ruthin Road, Wrexham SP5: KSS2: Land East of Cefn Road, Wrexham SP6: Planning Obligations SP7: Green Wedge SP8: Wrexham Town SP9: Economic Growth Employment and Enterprise SP10: Wrexham Industrial Estate SP11: KSS3: Land to the north of Bryn Lane, Wrexham Industrial Estate SP12: Transport and Accessibility SP13: Design Principles & Masterplanning Framework SP14: Health and Wellbeing SP15: Natural Environment SP16: Historic and Cultural Environment SP17: Minerals Supply and Safeguarding SP18: Sustainable Waste Management SP19: Climate Change SP20: Green Infrastructure
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Table 7.2: Summary Effects of Policies
Historic Environment
1. Role 1. of Wrexham Economy 2. Wrexham 3. Town Centre 4a. Travel Active Highways 4b. Capacity a 5. MixedCommunity Housing b. 5 Healthy 6. Living Character 7b. Welsh & Language Infrastructure 8. 9a. Ecology & Habitats Natural 9b. Resources 9c. Landscape 9d. 10a. Carbonemissions 10b. ClimateChange Resilience Minerals 11. 12. Waste SP1; Housing Provision SP2; Location of New Development SP3: KSS Key Strategic Sites ? SP4: KSS1 SP5: KSS2 SP6: Planning Obligations SP7: Green Wedge SP8: Wrexham Town SP9 Economic Growth, Employment and Enterprise SP10: Wrexham Industrial Estate SP11: KSS3 WIE SP12 Transport and Accessibility SP13: Design Principles SP14: Health & Wellbeing SP15: Natural Environment SP16; Historic and Cultural Environment SP17: Minerals Supply and Safeguarding SP18: Sustainable Waste Management SP19: Climate Change SP20: Green Infrastructure
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Detailed Policies
NaturalResources
1. Role 1. of Wrexham Economy 2. Wrexham 3. Town Centre 4a. Travel Active Highways 4b. Capacity a 5. MixedCommunity Housing b. 5 Healthy 6. Living Character 7b. Welsh & Language Infrastructure 8. 9a. Ecology & Habitats 9b. 9c.Historic Environment Landscape 9d. 10a. Carbonemissions 10b. ClimateChange Resilience Minerals 11. 12. Waste DM1: Development Management NE1: European and Nationally Designated Sites NE2: Locally designated sites of nature conservation and geological importance NE3: Trees Woodlands and Hedgerows NE4: Area of Outstanding Natural Beauty NE5: Special Landscape Areas NE6: Waste Water Treatment and Water Quality BE1: Pontcysyllte Aqueduct and Canal World Heritage Site BE2: Trevor Basin Masterplan Area H1: Housing Provision H2; Affordable Housing H3: Affordable Housing Exception Sites H4; Gypsy and Traveller Sites H5: Gypsy and Traveller Accommodation H6; Houses in Multiple Occupation H7: Houses in the Countryside H8: Replacement Dwellings in the Countryside H9: Conversion of Buildings
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EM1: Protection of Existing Employment Land EM2: Provision of Supporting Facilities EM3: Alternative Use Employment Land EM4: Employment Development Outside of Settlement limits EM5: Visitor Accommodation EM6: Pentre Maelor Housing Buffer T1: Managing Transport Impacts T2: Active Travel T3: Passenger Transport T4: Wrexham General Rail Station Enhancements T5: Safeguarding of Dis- used Railway Infrastructure T6: Strategic Transport Infrastructure Improvements R1: Retail Hierarchy R2: Development in the Masterplan Area R3: Primary Shopping Streets R4: Proposals Outside Primary Shopping Streets R5: District, Local, Village and Neighbourhood Centres R6: Retail Development (Out of Centre) R7: Loss of Local Services CF1: Protection of Open Space CF2: Open Space in New Development CF3: Regional Sports Stadia MW1: Minerals Safeguarding MW2: Minerals Buffer Zones MW3: Sustainable Supply of Minerals MW4: Secondary Aggregates
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MW5: Sustainable Waste Management MW6: Waste Management Facilities W1: Welsh Language RE1: Development and Renewable Energy/Low Carbon Technology RE2: Renewable Energy Schemes
7.1.1 Overall, the appraisal found that the LDP policies would have mostly positive or neutral impacts. The impacts were particularly positive with regard to social and economic issues such as economic growth, housing, sustainable travel and health. The main negative effects would be caused by the policies that promote housing and economic growth and specific development locations, notably policies SP1, SP7 and SP9. Together these would have significant impacts on natural resources and in particular the Best and Most Versatile Agricultural Land, Mineral Resources and local ecology and landscape assets. Also noteworthy, the growth agenda of the plan will negatively impact on the absolute levels of carbon emissions, waste and trip generation, but mitigation (see section 7.3) is proposed. Many policies have uncertain effects or a mix of positive and negative effects dependent on how the policies are implemented and mitigation/avoidance measures (also see 7.3). The LDP's overall impacts are discussed in more detail at Chapter 8.
7.2 How social, environmental and economic problems were considered in developing the policies and proposals. Table 7.3 details for each of the SA objectives the effects of the strategic policies and how these SA issues shaped the policies.
Table 7.3: Sustainability Issues and Policy Response
Integrated Policy Effects Score Objectives 1 Wrexham Key The level of housing and employment growth, location of development including Settlement employment, choice of key strategic sites provide strong support for the role of Wrexham. The strategic approach to transport and planning obligations helps mitigate the impacts of growth on the A483. Design principles and protection of the natural environment help contribute to the quality of the natural and built environment.
The detailed policies for employment and retail establish Wrexham as the primary focus for these types of development supported by strategic and local transport improvements in Wrexham, particularly focused on active travel and sustainable transport to mitigate the impacts of additional car traffic and improve accessibility of the town to the wider region. 2. Economy By safeguarding employment land and extending WIE the plan gives strong support to the strategic employment needs of the County Borough by providing a scale and range of employment opportunities in locations demanded by employers, primarily in Wrexham and WIE.
This is supported by the safeguarding of employment land of local importance throughout the County Borough. It also provides for employment development associated with tourism, rural and farm based enterprises. The retail, minerals and waste policies provide opportunities for these sectors.
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The level of housing growth is balanced with the employment growth to give sustainable development and a pool of labour.
The strategic approach to transport and planning obligations helps mitigate the impacts of growth on the A483 which could otherwise constrain development. This also provides access to markets and labour outside the County Borough. Design principles and protection of the natural environment help contribute to the quality of the natural and built environment.
Provides sufficient steer to guide development away from the most sensitive environmental areas but some conflict with employment aspirations in particular associated with the AONB, rural areas and GCN, detailed policies (NE4, EM4, EM5, and SPG’s (Wrexham Industrial Estate: Strategic Green Network) provide a steer on these issues.
There is a potential conflict between protection of historic and cultural assets and economic growth particularly e.g. World Heritage Site but detailed policies (BE1 and BE2) and SPG’s (World Heritage Site) provide a steer on these issues. 3. Wrexham Town The location of housing and employment growth and Key Strategic Sites centre (Wrexham) provides opportunities for development to support the town centre. The approach to transport and planning obligations will help address transport and highways capacity issues that constrain growth in the town. The approach to enhancing design quality and the historic environment will support town centre regeneration.
The level of housing growth set out in SP1 may benefit the town centre but this is dependent on site specific locations and linkages. Policy H1 allocates nearly 2/3rds of all housing growth in Wrexham and principally in the key strategic sites and Stansty. KSS1 provides the best opportunities for direct links into the town centre but this will be outside the plan period. Policy EM1 safeguards Western Gateway and Wrexham Technology Parks for employment, these are key areas with links to the town. 4a. Active Travel The growth agenda of the plan (housing and economy) will increase transport movements. But policies reinforcing the role of Wrexham and Wrexham town centre and the most sustainable locations for development (SP9), offer opportunities to reduce these effects (minimising the need to travel, promoting active travel and sustainable transport options).
Strategic policies for Transport, Spatial Strategy, Key Strategic Sites, obligations, design provide the hooks by which avoidance and mitigation measures can be delivered and help reduce per capita travel.
Detailed policies for transport establish a transport hierarchy placing walking and cycling ahead of car travel when considering transport solutions for sites. They also give weight to the Active Travel Networks that have been submitted to Welsh Government Transport and obligations policies will help deliver infrastructure needed to support sustainable transport. The housing, employment and retail policies focus development in the most sustainable locations with access to services and sustainable transport. The master- planning principles policy and supporting SPG identifies active travel and connectivity as key considerations in site design.
There is policy support for housing and employment in the countryside but the detailed policies control the scale of such growth. 4b. Highways Focussing development in Wrexham where there are constraints with the A483 x junctions and with the local highway network will create local traffic impacts. Development elsewhere in the County Borough will also have local impacts.
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The plan provides mitigation in the strategic transport policy, key strategic sites policies, planning obligations and design principles which will help keep highways operating within capacity but there are likely to be local impacts.
WG plans for investment in the A483 junctions during the plan period will prevent highways capacity becoming a regional/national constraint. The strategic policies (SP4) are worded to keep impacts local (through phasing and timing of development).
See active travel policy assessment for detailed mitigation to encourage active travel and sustainable transport. 5a. Housing Strategic policy SP1 delivers a significant quantity of market housing with (Communities) potential to deliver affordable housing, addresses housing types and tenures and needs of the community.
Development is located in the most viable areas to ensure that sites have development value to fund enabling and necessary infrastructure needed to support development.
Policies for the location of development, Wrexham Town, key strategic sites, Transport promote accessibility to employment, services and facilities needed to support new housing.
Policies for transport, planning obligations, green infrastructure, open spaces, climate change and design ensure that housing is supplied with the necessary infrastructure, connectivity and design to support communities.
The needs of the Welsh Language community have been considered in the LDP with opportunities for windfall development and where appropriate mitigation to address negative impacts and provide positive support.
The wider needs of the community, G&T, rural communities, tenures etc. have been addressed. 5b. Housing (Need) The spatial distribution of housing helps meet needs throughout the County Borough. Due to viability, lack of constraint free sites and the distribution of housing needs it is not possible to perfectly match housing supply with needs but the strategic and detailed policies make the best efforts to maximise affordable housing supply responsive to viability variances across the County Borough and the supply of housing. 6. Health & Wellbeing Policies positively address the six main determinants of health with specific x commitments particularly economy, environmental conditions (housing), access and healthy lifestyles (promoting active travel).
However, on balance the impact of policies on health are mixed, increased development will place additional pressures on infrastructure (health facilities, open spaces), could impact on pollution (air, noise) and sense of place/identity. Much will depend on site specific development at planning application stage. Mitigation provided by design policy SP13. 7. Local Character The locations for growth and its scale will place pressure on local character and x culture, but the impact is dependent on site specifics and mitigation at the planning application stage.
The approach to green wedge, natural and historic environment (AONB, World Heritage), SLA, green infrastructure, locally designated sites, trees and hedgerows will help protect and enhance international and nationally important assets while also protecting local character and settlements from coalescence. The design policy and green infrastructure policy will help protect and mitigate
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impacts locally but generally the outcomes for local character are uncertain until the detailed application is submitted. 8. Infrastructure Development will place pressure on existing infrastructure in particular x education, open spaces, highways, waste water and health. Impacts of development on infrastructure are locational specific.
Development is located in the most viable areas to ensure that sites have development value to fund enabling and necessary infrastructure needed to support development. Infrastructure necessary to deliver and enable the allocated sites has been identified and the phasing and timing of development is tied to the delivery of infrastructure. Policy hooks are in place to ensure that mitigation is available to deliver the infrastructure.
However, there are challenges in providing all infrastructure associated with development, viability will vary site by site, some sites may not be able to fund all infrastructure and some infrastructure is delivered outside of the plan (particularly health and strategic transport). Infrastructure capacity will also vary during the plan period. The impact of these will be clear at detailed planning application stage. While the LDP has taken reasonable steps to deliver and co- ordinate delivery of infrastructure it cannot be certain what the outcome will be.
Mitigation seeks to make the most efficient use of existing infrastructure in areas which can viably deliver infrastructure through planning obligations/CIL and mitigate impacts through policies for Infrastructure, Transport, Health and Wellbeing, Key Strategic sites, Design and waste. Policy safeguards are in place to ensure that infrastructure necessary to deliver and enable development is provided with sites at an appropriate time. 9a. Ecology Provides a strong steer to guide development away from the most sensitive x (Biodiversity) ecological areas (Internationally and nationally designated sites) but growth will impact on local ecological features as a consequence of the levels of growth and the need for greenfield development. In particular the Key strategic sites and location of development could have negative effects on local features. Mitigation and avoidance measures are provided by policy SP13 Design, SP15 SP 20 and detailed policies NE1-NE6.
A strategic approach to ecological mitigation is provided around Wrexham and WIE relating to Great Crested Newts and in Rhos with Hafod SAC. 9b. Natural Resources The main negative effects would be caused by the policies that promote xx housing and economic growth which requires greenfield development. The location of growth in tiers 1-3, would lead to the loss of the best and most versatile agricultural land.
A growing population and increased economic activity will increase transport related air pollution. Site specific impacts can be managed at the planning application stage but diffuse levels will increase.
Few allocations are on brownfield land but a significant element of the housing and employment supply is brownfield.
Site specific mitigation protecting wider natural resource issues provided by SP15 (Environment), SP13 (Design), SP17 (Minerals), SP20 (GI) and DM1, NE6. The strategy of locating growth in Wrexham and other sustainable settlements with good active travel/public transport potential allied with transport policies will help encourage active travel to reduce emissions. 9c. Historic The Historic environment policy (SP16) provides protection and enhancement x for internationally, nationally important historic and cultural assets.
Local assets will be protected by Design policy 13 but the outcomes are
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uncertain as much depends on site specifics and mitigation. 9d. Landscape Provides a strong steer to guide development away from the most sensitive x landscape areas (Internationally and nationally designated sites) but growth will impact on local features as a consequence of the levels of growth and the need for greenfield development. In particular the Key strategic sites and spatial location of development could have negative effects on local features. Mitigation and avoidance measures are provided by policy SP4-5, SP7, Green Wedge, SP15 (Historic) and SP13 Design and detailed policies DM1, NE2, 3, 4, and 5. 10a Climate Change The growth agenda of the plan (housing and economy) will increase carbon x emissions through economic activity. But policies reinforcing the role of Wrexham and Wrexham town centre, the most sustainable location for development, offer opportunities to reduce these effects (resource efficiency, minimising travel, and opportunities to facilitate sustainable building standards).
The plan promotes low carbon and renewable energy development through the detailed policies RE1 and RE2 with an energy opportunities plan (REA). The plan seeks to reduce the need to travel by locating development in the most sustainable locations with a range of services while promoting sustainable transport.
Strategic policies for Transport, location for development, Key Strategic Sites, Design and Minerals provide the hooks by which avoidance and mitigation measures can be delivered and help reduce per capita emissions.
The absolute levels of carbon will increase (as they would with a growing population) but the plan takes positive steps in reducing per capita emissions. 10b Climate Change Strategic policy 19 ensures development delivers this objective. Resilience The plan protects and enhances the natural environment, green infrastructure, open spaces and natural resources that have important roles in climate change resilience.
The majority of the spatial areas for development avoid areas at risk of flooding but there are some locations that require further avoidance and mitigation at site level. Surface water flood risk occurs in specific sites and the loss of greenfields may impact on capacity to deal with flood events and cause flooding elsewhere.
Effective mitigation provided by the Infrastructure, location for development and Design policies. 11. Minerals The scale and location for development (KSS’s and policy SP2) will negatively x impact on mineral resources. However the option of an environmentally led spatial strategy has been considered (above) and dismissed as unreasonable – the majority of settlements free of mineral constraint are small rural tier 4-5 villages which would be inappropriate for strategic scale development.
Other plan objectives and sustainability reasons outweigh the loss of minerals, in particular, supporting Wrexham as a key national settlement, promoting active and sustainable travel, reducing carbon emissions, providing housing and associated infrastructure to support communities and ensuring climate change resilience.
Policies SP17 and MW1-4 provides mitigation in promoting prior extraction and protecting/supplying mineral resources but the practical amount of prior extraction is likely to be limited.
Protection of natural environment conflicts with the supply of mineral resources, Planning Policy Wales and the plans environmental protection policies provides the framework by which natural areas of importance are protected from
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inappropriate mineral development. 12. Waste Absolute levels of waste will increase but the requirement to consider sustainable waste management will help reduce arisings.
7.3 Proposed mitigation or enhancement measures.
7.3.1The most significant changes were to Policy SP5 Protecting, Conserving and Enhancing the Natural Environment which was amended to address concerns raised by the Habitat Regulations Appraisal and changes to the Spatial Strategy (SP8) to include villages which could provide more sustainable outcomes and flexibility in site selection. The majority of SA observations require strategic avoidance where possible (see Appendix F for details of options considered) or more detailed mitigation policies at Deposit Plan stage. The SA assessment has largely been most effective in highlighting issues that need to be addressed later in the plan process which is a typical result of an iterative process. Table 7.4 summarises the suggested changes and shows how they were taken into account.
Table 7.4: Mitigation Strategic Policy SA Comments Mitigation Policy SP1:Housing The level of growth requires greenfield Alternatives that minimise/avoid the loss of Provision development with impacts on natural resources arising from housing agricultural land, mineral resources, development considered as part of the options ecology, heritage/culture and appraisal in Appendix F. landscape. Growth will also increase absolute levels of carbon emissions, Many of the issues raised are tackled by wider travel and waste, mitigation required to plan policies including Strategic Policies; SP4, reduce per capita impacts – design, SP5, SP6, SP11, SP12, SP13, SP15, SP16, density, criteria policies. SP17, SP18 and detailed policies: DM1, NE1, NE2, NE3, NE4, NE6, BE1, BE2, T1, T2, T3, Housing needs for older population, T4, T5, T6, MW1, MW5, MW6, RE1, RE2. children, students, homeless to be catered for. Changes: Criterion e) is included in the policy that requires developments to make provision for specific housing needs which would cover the groups (and others) identified. Policy SP2: Location for Need to mitigate travel related carbon Many of the issues raised are tackled by wider development emissions and increased trip generation plan policies; - encourage active travel and Carbon, active travel and transport – sustainable transport options, mixed SP12, SP19, SP20, T1, T2, T3, T4, use development, renewable energy T5, T6 support the delivery of active and energy efficiency. Sites need to travel and sustainable transport contribute towards active travel and options and ensure that developments sustainable transport. put active travel first. Natural Environment - DM1, NE1, Mitigation required for developments NE2, NE3, NE4, NE6 provides within the WLS areas that cannot mitigation for local impacts and reasonably be foreseen. provide a basis to support SPG’s for Johnstown Newt SAC and WIE GCN Strategic approach to GCN populations mitigation; around Wrexham and WIE needed. Welsh Language WL1 identifies the Need a policy to mitigate ecological localities, scale of development and impacts of development that will come thresholds of developments that would forward during the plan period. not be typical for the WLS areas and would require additional impact The need for infrastructure arising from assessment; development, its timing, phasing and Minerals MW1, MW5, MW6 provides
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funding will need to be mitigated in the mitigation for the loss of minerals LDP. through development; World Heritage Site BE1, BE2 and Mitigation required for historic assets historic environment SP16 provides and local landscape. mitigation in the World Heritage Site and for designated assets; Planning Obligations policy SP6 and NE6 (waste water treatment works) provide the basis for infrastructure provision, the Infrastructure Delivery Plan and Housing Supply and Delivery Background Papers (with allocated site Proformas) detail how the supply of infrastructure dovetails with the supply of housing, its timing and phasing.
Changes: Welsh Language Policy WL1, SPG’s for Johnstown SAC and WIE GCN mitigation. Policy SP3: Key Strategic Ecological, landscape, historical/cultural Design policy SP13 establishes a Housing Sites heritage and flooding mitigation will be Masterplanning framework with which to required. inform place making at detailed application stage. Encourage high density development to Opportunities to reduce greenfield land reduce greenfield requirement. requirements and minimise loss of agricultural land and mineral resources Changes: SP13 and the accompanying to be pursued for the Deposit plan – Masterplan Framework, criterion c added to e.g. increasing density, mineral prior- policy SP1 (housing density). extraction.
Mitigation to encourage active travel and leisure required; mitigation to control the impact of development on local character and distinctiveness is also required. Policy SP4: Land at Lower Ecological, landscape, historical/cultural Design policy SP13 establishes a Berse Farm, Ruthin Road heritage and flooding mitigation will be Masterplanning framework with which to Wrexham required. inform place making at detailed application stage. Encourage high density development to Clarity needed that delivery of the site is reduce greenfield requirement. dependent on junction 4 upgrade. Changes: SP13 and the accompanying Opportunities to reduce greenfield land Masterplan Framework, criterion c added to requirements and minimise loss of policy SP1 (housing density). Policy SP4 agricultural land and mineral resources amended inserting the following words at the to be pursued for the Deposit plan – end of the first sentence of the policy e.g. increasing density, mineral prior- “following completion of works to junction 4”. extraction.
Mitigation to encourage active travel and leisure required; mitigation to control the impact of development on local character and distinctiveness is also required. Policy SP5: KSS2: Land Ecological, landscape, historical/cultural Design policy SP13 establishes a Master- east of Cefn Road, heritage and flooding mitigation will be planning framework with which to inform place Wrexham required. making at detailed application stage. Encourage high density development to Opportunities to reduce greenfield land reduce greenfield requirement. Minerals policy
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requirements and minimise loss of MW1 requires a Prior Extraction Assessment. agricultural land and mineral assets to Transport policies promote active travel as a be pursued – e.g. increasing density, lead element of reducing the need to travel by mineral prior-extraction. car.
Mitigation to encourage active travel Changes: SP13 and the accompanying and leisure required; mitigation to Masterplan Framework, criterion c added to control the impact of development on policy SP1 (housing density). local character and distinctiveness is also required. In policy SP5 under the heading ‘Necessary Infrastructure’, the following inserted “Ensuring Add ‘Ensuring connectivity between the connectivity between the land north and south land north and south of Bryn Estyn of Bryn Estyn Road” and ‘retention of existing Road’ to the necessary infrastructure. open space’.
Confirm the Ysgol Morgan Llwyd Last sentence of justification now reads “Due playing fields will be retained. to recent expansions at the school, there is limited space within the curtilage to relocate the school playing fields which will need to be retained and integrated into the future master- planning of the site”. Policy SP6: Planning As an overarching policy this contains The Infrastructure Delivery Paper and Housing Obligations sufficient hooks to address Delivery and Supply Background Paper clarify sustainability issues but the LDP will what infrastructure is necessary to deliver and need to clarify the strategy for delivering enable development. For each policy, where infrastructure needs, identifying relevant, supporting SPG’s have been priorities, delivery mechanisms identified to support policies, these will contain (S106/CIL) and timings. the details required above. SPG’s supporting the LDP – New - Masterplanning Framework, The policy has a catch all criteria for Development in proximity to Johnstown Newt Community facilities but the LDP and/or SAC, Wrexham Industrial Estate Protected supporting SPG’s need to make it Species; Special Landscape Area; Open explicit that there is support for Access, Space and Outdoor Sports Facilities; Mineral circulation, parking, transport plans, Safeguarding, Renewable Energy and public transport provision and Independent Assessment; Wrexham Town infrastructure for walking and cycling; Centre Masterplan, AONB, Trevor Basin allotments, recreation and leisure; Masterplan; UDP SPG’s – Main ones – Public realm improvements; Waste Parking Standards, Developer Contributions to management facilities and services; Schools; Affordable Housing; Design; Protection, enhancement and Biodiversity and Development; Pontcysyllte management of natural and built Aqueduct and Canal. heritage interests and enhancements; Community safety initiatives; and other Changes: Active travel explicitly added to facilities and services considered infrastructure. necessary. Added to policy “Any attempts to sub divide sites to avoid thresholds for planning obligations will not be supported.” Policy SP7: Green Wedges Land that performs the role and None functions of Green Wedge have been released for housing, however sufficient land remains to retain green wedge functions. Policy SP8: Wrexham Town None None Policy SP9: Economic Broadly the policy has very positive Strategic Policies for the Natural and Historic Growth Employment and impacts for the economy and housing Environments, Transport and Design address Enterprise with negative effects on the natural the concerns raised in selecting sites and environment (ecology, landscapes and managing future applications.
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natural resources) but impacts on the most sensitive environmental assets The choice of key employment site reflects the have been avoided with impacts mainly need to avoid loss of BMV agricultural land. of local scale. Ecological, landscape, flooding, historical/cultural heritage Changes: Policy to protect WIE ecological (including local character and network inserted into SP10. distinctiveness) mitigation will be required at site selection stages and in managing future applications.
Mitigation to encourage active travel and leisure required
Employment site selection to avoid pollution effects. Mitigation required managing pollution arising from development.
Infrastructure strategy to mitigate development to be detailed in the Deposit plan. Policy SP10: Wrexham Development within WIE can conflict Policy to protect WIE ecological network Industrial Estate with the conservation of protected inserted into SP10, SPG linked to policy SPG species, particularly GCN. linked to policy Policy SP11: KSS3: Land to Impacts on neighbouring residents, Residential buffer zone applied, policy DM1 the north of Bryn Lane, local landscape features and surface mitigates other impacts. Wrexham Industrial Estate water run-off, suggest mitigation. Changes: Residential buffer zone applied Policy SP12: Transport & Priority of walking and cycling over cars Detailed policy T1 establishes transport Accessibility in development sites to be established hierarchy with walking/cycling/sustainable in the plan. transport at the top. Policy SP13: Design The policy should be more explicit The current wording and SPG provides Principles & Master- about the key themes within the adequate scope to give due weight to the planning Framework framework, this would give them greater themes within the framework. weight.
The contribution of this policy to SP20 provides sufficient protection to mitigate mitigating local environmental impacts impacts on local environment, no change. would be improved if reference to a green infrastructure approach was included in the policy wording. Policy SP14: Health & Deposit plan needs to expand on the Deposit LDP contains policies and/or SPG’s to Wellbeing protection and enhancement of leisure address the concerns raised. and recreation facilities. Policy guidance needed in relation to healthy Policy revised to capture role of access to eating and proximity to fast food. Active services, policy now reads “All development travel promotion will require greater should seek to reduce health inequalities and clarification in the deposit plan. provide opportunities for healthy lifestyles and improving health and well-being. This will be achieved by supporting proposals which provide access to services including primary and secondary healthcare, sports facilities and opportunities for recreation, as well as active travel opportunities, high quality sustainable design, open space, green infrastructure, food growing and allotments”. Policy SP15: Natural The Preferred Strategy policy was out Deposit Plan Policies amended to recognise Environment of kilter with the protection afforded to the various levels of legal protection offered to
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different levels of European sites. different designated sites. Close working with Welsh Water to ensure Waste Water Detailed approach to ecological Treatment Works capacity is compatible with protection reflecting the range of the housing supply and designated site ecological designations required, as is protection objectives. SPG’s prepared to the approach to development in WIE, protect species at WIE and Johnstown Newt managing surface water and green SAC. infrastructure and approach to protecting natural resources. Changes: Policy broken down into NE1 (International and Nationally Designated Approach to development recognising sites), NE2 (Locally Designated) NE3 (Trees the different landscape designations and Woodlands), NE4 (AONB), NE5 (SLA) required e.g. SLA. AONB, Green strategic policy amended to that written above. Wedges, open countryside. Waste Water Treatment Policy NE6 inserted into the plan. Policy SP16: Historic & Deposit plan needs to give a clearer The Deposit Plan contains a detailed policy, Cultural Environment steer to; the protection and BE1 for the World Heritage Site supported by enhancement of the World Heritage site an SPG, there will be an SPG’s for Buildings and its Outstanding Universal Value; at Risk, Conservation Areas, Wrexham Town the approach to buildings at risk; Centre and Shop Fronts. development in conservation areas, alterations to unlisted buildings and shop fronts in conservation areas; heritage assets and regeneration and archaeological remains.
No protection for cultural assets which are not listed e.g. Stiwt, Bangor Racecourse, Wrexham Racecourse, no protection for heritage assets of local value. Policy SP17: Minerals In the Preferred Strategy the following Detailed Policies MW1 Mineral Safeguarding, Supply and Safeguarding was raised – ‘Clarification needed as to MW2 Minerals Buffer Zones, MW3 when mineral extraction would be Sustainable Supply of minerals and MW4 acceptable, assurance the LDP can Secondary Aggregates respond to these meet the regional requirements for issues. aggregate over the plan period, identify a buffer zone around all permitted Changes: Policies MW1, MW2, MW3 and mineral workings with a detailed policy MW4 inserted. to direct development away from the buffer zone, criteria against which proposals for mineral extraction will be assessed to minimise environmental impacts, setting out restoration requirements and acceptable after use.
Need criteria against which proposals for mineral extraction will be assessed to minimise environmental impacts. Need to set out restoration requirements and acceptable after use’. Policy SP18: Sustainable An allocation or criteria based policy is Policies MW5 and MW6 inserted into the plan. Waste Management required to enable a site(s) to come forward. Policy SP19: Climate Need to avoid areas at risk of flooding Extra criteria vi and vii added. Change and prevent development from increasing flood risk Policy SP20: Green Ensure that blue infrastructure is Reasoned justification amended accordingly to
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Infrastructure recognised as an element of GI. capture blue infrastructure.
Detailed Policy SA Comments Mitigation DM1: Development None None Management NE1: European and None None Nationally Designated Sites NE2: Locally designated Need to ensure that suitable mitigation This policy provides sufficient protection with sites of nature is in place where features are lost. support from Biodiversity SPG. Minerals policy conservation and MW3 requires restoration and aftercare. geological importance NE3: Trees Woodlands Need to ensure that suitable mitigation This policy provides sufficient protection with and Hedgerows is in place where features are lost. support from Biodiversity SPG. Minerals policy MW3 requires restoration and aftercare. NE4: Area of Outstanding Potential conflict between AONB and The existing criteria protects against mineral Natural Beauty mineral development needs clarity with development. The minerals strategic policy a criteria preventing development. SP17 gives an additional steer on these matters, acknowledging that national policy says mineral development in the AONB should be in exceptional circumstances and that WCBC are working with Flintshire to source a supply in Flintshire. Currently the AONB is within mineral extraction exclusion areas, thereby protecting the AONB.
Conflict between the AONB and Local Buffer zone added to the AONB (7km for wind Search Area (wind and solar). 3.5km for solar), resources within the buffer deleted.
NE5: Special Landscape SLA’s and mineral resources overlap, Minerals can only be worked where they are Areas development for mineral use would not and WCBC have a duty to safeguard and be consistent with this policy, exclude supply economically important minerals. The SLA’s from mineral development. approach to minerals identifies the most constrained areas and focusses mineral development to the least constrained areas. The SLA is a local feature but wider sustainability issues override potential loss NE6: Waste Water Add criteria to control mineral The existing criteria provide sufficient Treatment and Water development. protection. Quality BE1: Pontcysyllte None None Aqueduct and Canal World Heritage Site BE2: Trevor Basin Following the HRA the internal conflict Inserted ‘The Masterplan area includes land Masterplan Area between promoting regeneration of the which is designated as a part of the River Dee site and disturbance to otters resolved and Bala Lake Special Area of Conservation. by making it explicit NE1 applies. All proposals under this policy will therefore need to demonstrate compliance with policy NE1’.
Potential conflict between recreational Policy BE2 amended to acknowledge that pressure arising from development and development must accord with NE1. conservation values of designated sites. H1: Housing Provision Harmful impacts on BMV agricultural All of the suggestions have been considered land, highways capacity, green wedge, as part of the strategic option appraisal for the
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mineral resources; with effects on spatial strategy, however, due to the need for ecology, landscape, historic assets viable and deliverable sites with constraints requiring mitigation at detailed planning that can be demonstrated to be overcome the application stage. options are limited and would often Viability could be improved by compromise other sustainability objectives. including more sites from The chosen allocations effectively balance all Overton, Rossett, Bronington, objectives without significant harm. Gresford; Affordable Housing provision could be enhanced with sites on Cefn Road and the rural settlements in Overton, Rossett, Bronington; Impacts on BMV could be reduced by locating development in Broughton (North), Chirk, Coedpoeth, Gwersyllt, Llay; Impacts on minerals could be reduced by including sites from Bronington, Chirk, Gresford and Overton; Reduce number of sites with impacts on Green Wedge and SLA. H2; Affordable Housing None None H3: Affordable Housing None None Exception Sites H4; Gypsy and Traveller None None Sites H5: Gypsy and Traveller None None Accommodation H6; Houses in Multiple Add criteria to ensure the over Policies for District, Local, Village and Occupation concentration of HMO’s does not impact Neighbourhood centres have sufficient criteria on retail and commercial centres. to protect against this. The Wrexham Town Centre Masterplan (future SPG) also provides sufficient steer to protect against this issue. Policy R4 provides clarity on the matter. H7: Houses in the None None Countryside H8: Replacement None None Dwellings in the Countryside H9: Conversion of None None Buildings EM1: Protection of Existing None None Employment Land EM2: Provision of None None Supporting Facilities EM3: Alternative Use None None Employment Land EM4: Employment Employment development in the Agreed, criteria iii amended with Development Outside of countryside should not be harmful to ‘infrastructure’ inserted. Settlement limits infrastructure EM5: Visitor None None Accommodation EM6: Pentre Maelor None None
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Housing Buffer T1: Managing Transport The policy should establish a transport Agreed, the policy has been reformatted to Impacts hierarchy that proposals should follow, reflect this hierarchy with greater precedence in considering transport solutions for given to active travel first. sites the priority should be to first consider walking and cycling, then Change: Policy re-ordered and a transport public transport and finally cars. hierarchy established as criteria i. T2: Active Travel None None T3: Passenger Transport None None T4: Wrexham General Rail None None Station Enhancements T5: Safeguarding of Dis- None None used Railway Infrastructure T6: Strategic Transport None None Infrastructure Improvements R1: Retail Hierarchy None None R2: Development in the None None Masterplan Area R3: Primary Shopping None None Streets R4: Development Outside None None Primary Shopping Streets R5: District, Local, Village None None and Neighbourhood Centres R6: Retail Development None None (Out of Centre) R7: Loss of Local Services None None CF1: Protection of Open None None Space CF2: Open Space in New Open spaces should secure sufficient The detail will be contained in the SPG for Development opportunities for play, encourage multi- Public Open Space on New Housing functional play activities across a wide Development. The policy provides sufficient range of children’s ages while also clarity to provide opportunities for play. providing suitable provision for adults. Provide further detail in the policy to Any attempts to sub divide sites to avoid support this. thresholds for provision of open space will not be supported. Ensure there are no opportunities to avoid the policy with two smaller sites under the threshold. CF3: Regional Sports None None Stadia MW1: Minerals None None Safeguarding MW2: Minerals Buffer Treatment of sensitive development Revised policy Zones within the buffer zones MW3: Sustainable Supply Add the World Heritage Site Buffer to Buffer Zone added to extraction exclusion of Minerals the extraction exclusion area area MW4: Secondary None None Aggregates MW5: Sustainable Waste None None Management MW6: Waste Management Amend criteria to prevent development The policies for SLA and Green Wedge Facilities in Green Wedge and SLA. provide sufficient protection against inn- appropriate development.
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W1: Welsh Language None None RE1: Development and None None Renewable Energy/Low Carbon Technology RE2: Renewable Energy Make it explicit how small scale Criterion c amended to give explicit support for Schemes schemes for wind, biomass, anaerobic renewable technologies. digestion and hydropower would be treated.
Conflict between the AONB and Local Buffer zone added to the AONB (7km for wind Search Area (wind and solar). 3.5km for solar), resources within the buffer deleted.
7.3.2 In addition to reviewing individual strategic policies, the sustainability appraisal identified some gaps where the policies did not fully cover the SA objectives. These are shown at Table 7.5, along with the planning team's response to the SA comments.
Table 7.5: Changes resulting from the appraisal of gaps in the LDP strategic policies
Identified Gap LDP Response Carbon reduction and renewable energy This has been elevated within the LDP with the insertion of a Strategic Policy for Climate Change Welsh Language Welsh speaking is in the minority in most communities (except for pockets in the rural Ceiriog and around Rhosllanerchrugog) with levels below the Welsh average. Not a strategic issue requiring an explicit policy but the SA has assessed the impacts on Welsh Language communities and policy WL1 establishes Sensitive Areas, within which developments over a threshold will need to consider impacts on the language. Tourism has been identified by Welsh Government and The Deposit Plan has a range of criteria and topic based WCBC as a vital part of a sustainable economy but this policies for tourism development in rural areas, does not have explicit weight in the Preferred Strategy. preservation of facilities, Wrexham town centre regeneration, visitor accommodation, re-use of existing buildings in the countryside and farm diversification. Approach to manage Green Wedges and managing The Deposit Plan has a Strategic Policy defining the development in Green Wedges needs to be established in Green Wedge. the LDP. Open Space and Recreation – Open spaces provide The Deposit Plan contains topic based policies supported important multi-functional benefits for health, ecology, by SPG protecting existing open spaces, providing new, climate change resilience and landscapes. protecting sport facilities. Does the LDP need to say something about air quality? Policy DM1 covers this issue, all development should ‘Safeguard the environment from the adverse effects of pollution of water, land, light or air arising from development’ Should the LDP be more pro-active in requiring Opportunities to enhance building standards and utilise development to deliver low carbon development and renewable energy are determined on a site by site basis renewable energy? requiring complex viability and technical feasibility work. This is a level of detail that is best left to the planning application stage when detailed site proposals are known. Policy RE2 provides a requirement for developers to undertake this work for large housing and employment sites. Many of the negative impacts of the plan are due to the The development density in the KSS’s reflect the site need for greenfield sites. Strategic policy SP1 sets a constraints and mitigation required to deliver the sites. housing density of 30 dwelling per hectare to reduce the Large amounts of land have been set aside for
Page 108 of 129 need for such sites but the housing density figures for both landscaping, green networks for surface water drainage KSS are well below 30dph, could a higher density be used and ecology and other spaces for recreation and school here? playing fields etc. If a higher density can be achieved SP2 and the Master-planning framework will steer development towards doing so.
7.4 Uncertainties and risks.
7.4.1 Certain statements made in the Report that are not historical facts may constitute estimates, projections or other forward looking statements and even though they are based on reasonable assumptions as of the date of the Report, such forward-looking statements by their nature involve risks and uncertainties that could cause actual results to differ materially from the results predicted.
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8. Appraisal of Candidate Sites
“the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (SEA Directive Annex I(f)) “an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know‐how) encountered in compiling the required information” (SEA Directive Annex I(h))
8.1 This section discusses how the specific candidate sites that were proposed for development in Wrexham County Borough were identified and appraised.
8.2 In determining where housing and employment growth could be directed spatially, the planning team considered sites proposed by land owners, agents and developers (candidate sites), potential development within settlement limits of brownfield, underused and vacant sites (urban capacity sites) and possible settlement extensions based on a desk top exercise undertaken by officers (officer sites). This resulted in 626 possible development sites.
Appraisal Methodology
8.3 Full details of the site appraisal of candidate sites and the process are contained in Appendix I of this report. Not all sites have been assessed under the SA framework, the Candidate Site Assessment Methodology20 sieved out a significant number of potential sites from consideration for several reasons; the site had constraints that could not be overcome (e.g. un-safe access, flood risk, housing proposed in open countryside); the site did not conform with the spatial strategy established in the Preferred Strategy the site has already been developed or is not available for development and sites of less than 10 were dismissed as too small to allocate.
8.4 The remaining sites were assessed for their performance against each of the LDP Integrated Objectives using criteria contained in Appendix I. Sites were scored using a colour coding system to make comparison of performance between sites easier.
8.5 Table 3 of Appendix I shows the results of the candidate site appraisal process for all sites, if sites were sieved out the reason for rejection is included, if sites proceeded to the SA stage of assessment the scoring described in 8.4 is shown.
8.6 Table 8.1 below shows the summary of SA scoring for each of the sites assessed. It is important to state that only sites that have been assessed using the SA framework can be considered for allocation in the LDP.
20 http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd
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Table 8.1: Summary Table of Site SA Assessment
nt
e
m
ha
x
re
1. Role of W of 1. Role 2. Economy Centre Town Wrexham 3. Travel 4a. Active Capacity 4b. Highways (viability) Housing 5. a (Need) Housing b. 5 Living 6. Healthy Language Welsh 7b. Infrastructure 8. Habitats & 9a. Ecology Resources 9b. Natural Environm 9c. Historic 9d. Landscape emissions 10a. Carbon Change 10b. Climate Resilience Minerals 11. Waste 12. A01OS Heol Berwyn, Cefn Former Rhosymedre Infant A04CS Site, Rhosymedre Warehouse Site of Former A05CS Flexsys, Cefn Former Ruabon Works, Cefn A06CS Mawr Land off Llangollen Road, A07CS Acrefair Land Opposite Former Ruabon A10CS Works, Cefn Land at Bangor on Dee - BA002AS Royton Farm Bangor on Dee NA ? Land Adjacent to Mountfields, BA01CS Bangor Land Adjoining Mountfields, BA02CS Bangor The Mount, Station Road, BA04CS Bangor BRN01CS Llys yr Ydlan, Bronington BRN02AS Land at A495, Bronington Land at Tan Yr Onnen, School BRN02CS Lane, Bronington Land off Oakfield Close, BRN06CS Bronington BRN10CS Land at A495, Bronington
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South of Berse Road, BRO001AS Broughton BRO002AS Land South Bersham Road BRO003AS Brynteg Quarry BRO01OS South of Berse Road, Caego ? Land at Gatewen Road, New BRO06CS Broughton ? Pats Coaches Depot, Southsea BRO08CS Road, New Broughton ? BROU005UCS Bryn y Gaer Road Former Railway Line, New BRY001AS Road , BRYMBO The Old Quarry Site, off BRY09CS Brymbo Road, Brymbo Former Steelwork Site, Off BRY10CS Phoenix Drive, Brymbo Former Steelwork Site, Off BRY15CS Phoenix Drive, Brymbo CH01OS Off B5070, Chirk CH02OS Off B5070, Chirk CH03OS Off B5070, Chirk Land around Chirk Green, CH04CS Chirk Land at Holyhead Road, Colliery Road and Longfield, CH05CS Chirk Land East of Lodgevale Park, CH06OS Chirk CHIR002UCS Station Avenue/Station Road B5070 Land South of Grogen, CHIR007UCS Chirk CHIR009UCS Station Avenue, North CO001AS Land East of Heol Offa Road CO002AS Land East of Penygelli Road Land north of Tomlinsons CO003AS Dairies. Five Crosses Estate NA Land Adjacent to A525 Ruthin CO02CS Road, Minera ?
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CO03OS Land at Adwy'r Clawdd Land West of Hafod Farm, CO05CS Talwrn Road, Coedpoeth Land at Top Talwrn, Talwrn CO06CS Road, Coedpoeth Land East of Hafod Farm, off CO07CS Talwrn Road, Coedpoeth Tomlinsons Dairies, Five CO08CS Crosses Estate Coedpoeth NA ? Field at 14 Heol Offa, CO09CS Coedpoeth Land to South East of Old GC05CS Road, Glyn Ceiriog NA NA ? Marford Hall Farm Land Off GRE001AS Hosley Lane, Marford. MARFORD HALL FARM Land Off CHESTER GRE002AS ROAD,MARFORD. (B5445) Land to the east of Old GRE003AS Wrexham Road Hillock Lane.Vicarage Lane GRE004AS (Gatehouse Farm) Gresford. GRE005AS Land at Horsley Lodge Land Adjoining Springfield and GRE09CS Marford Land Adjoining Springfield GRE10CS Farm, Marford ? GRE11CS Springfield Farm, Marford ? Land South of Vicarage Lane and East of Old Wrexham GRE15CS Road, Gresford Land at Woodlands Farm, to GWE001AS the north of Dodds Lane Livery Stables, Little Mountain, GWE02CS Summerhill GWE02OS Rhosrobin Road Stansty Fields, Stansty, GWE06CS Gwersyllt GWER003UCS Mold Road, Gwersyllt
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Bellis Brothers (off Frog Lane HOL001AS Holt) HOL05CS Laburnum Way, Holt Land off Chester Lane, Frog HOL06CS Lane, Holt Land Adjacent to Sycamore HOL07CS House, Wrexham Road, Holt The Long Croft, Green Street, HOL08CS Holt JOHN001UCS South of Culfan JOHN014UCS Aberderfyn Works, Aberderfyn JOHN020UCS West of School Street Adj to Kwik Save, Ruabon JOHN024UCS Road JOHN029NUCS High Street, Johnstown Former Infant School Block of LL001AS Llay Park School Llay Infant School Site, Off First LL004AS Avenue, Llay, Wrexham Land at Home Farm, Llay (LL12 LL006AS 0NW) LL01OS Llay Road, Llay Land Adjacent to Llay Miners LL02CS Welfare, Llay New Road, Llay LL02OS Adj. to Llay Hall Farm LL03OS Land West of Llay Hall Farm LL06OS Land opposite Alyn Waters LLAY001UCS British Legion, Llay MA01OS Off A525, Marchwiel MA02OS Land West of A525, Marchwiel Land adj to Holly Hedge, MA04OS Marchwiel Adj to Marchwiel Cottage, MA05OS Marchwiel MA06OS Land West of A528, Marchwiel
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OS6OS North - Land to the east of St Mary's Primary School and Bramblewood O001AS Close /South of Bangor Road North Triangle - Land to the east of St Marys Primary School and Bamblewood O002AS Close/South of Bangor Road. Land South of Bangor Road O003AS (East Site) O01OS Salop Road, Overton O02CS Land off Station Road, Overton O02OS St Mary's Avenue/Station Road O03OS Maelor Court/Parkside O04OS Bangor Road O05OS Adjacent to Maelor Court O06OS Adjacent to St Mary's School O07OS Land North of Fairleigh Land off Afoneith Road, PEN001AS Penycae PEN002AS Land off Stryt Issa, Penycae Land off Copperas Hill, PEN02CS Penycae Chapel Field and Allotment Field, Church Street and PEN04CS Chrwtianydd Lane, Penycae Land South of Pinecroft, PEN05CS Afoneitha Road, Penycae Penycae Junior School, PEN10CS Afoneitha Road, Penycae Land adjacent to Dymock PENL001AS Arms, Penley ? Land between Church Place and Greenacres, Overton PENL002AS Road, Penley PENL01CS Land at The Grange, Penley ? PENL03OS Ellesmere Lane Land Adjoining Lower Grange, PENL04CS Grange Road, Penley
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Pontfadog CP School, PO01CS Pontfadog NA NA Land to the rear of 4 Llys-y- RHO001AS Pant, Rhos RHO01OS Vinegar Hill, Rhos RHO02OS Vinegar Hill, Rhos Land Adjacent to the B5445 Chester Road and immediately RO001AS north of the Rossett Hall Hotel Land at Chester Road, Rossett RO002AS , Wrexham, LL12 Land off Chester Road, RO003AS Lavister, LL12 0AX Land at Rossett Road (B5012), RO004AS Rossett RO06CS Land at Chester Road, Rossett Land Between Rossett Road RO10CS and Gamford Lane, Rossett Land rear of Golden Lion Hotel, RO11CS Chester Road, Rossett Land off Rhosrobin Road , RR002AS Gwersyllt Land at Llay New Road, Rhosrobin, Wrexham (part of RR01AS WR22CS) Land Adjacent to Rhosddu RR02CS Industrial Estate, Rhosrobin Esless Farm, Esless Lane, RT02CS Rhostyllen Land at Plas Grono Road, RT03CS Rhostyllen ? SOUT006UCS Tanyfron Road, Southsea Land off Bedwell Road, Wrexham Industrial Estate, WIE001AS Wrexham, LL13 0UW NA NA AREA 2 Former Tetra Park site, now owned by Mainetti, Land WIE002AS off Bedwell Road NA NA AREA 1 Former Tetra Park site, now owned by Mainetti, Land WIE003AS off Bedwell Road NA NA ? Page 116 of 129
WIE004AS Land at Bryn Lane NA NA Oak Site, Oak Road, Wrexham WIE02CS Industrial Estate NA NA Land to the north of Bridge Road North, Wrexham WIE03CS Industrial Estate NA NA Land at Five Fords Farm, WIE05CS Marchwiel NA NA Land at Five Fords Farm, WIE06CS Marchwiel NA NA Land at Five Fords Farm, WIE07CS Marchwiel NA NA Land adjoining Mold WR003AS Road/A483 Wrexham ? Land off Holt New Road, WR004AS Wrexham Field adj Llwyn Onn Water WR05CS Works, Cefn Road, Wrexham Part of Tyn Twll Farm, Holt WR07CS Road, Wrexham Replaced by WR004AS Part of Tyn Twll Farm, Holt WR09CS Road, Wrexham Part of Tyn Twll Farm, Holt WR10CS Road, Wrexham Land Adjoining Fairways off WR11CS Holt Road, Wrexham WR13CS Land off New Road, Rhosrobin Berrylands, Homestead Lane, WR15CS Wrexham Rhosnesni and Llwyn Knottia WR16CS Farm, Cefn Road, Wrexham Land West of Cefn Road and South of Llanypwll WR19CS Roundabout, Wrexham Land at Lower Berse Farm, WR20CS Ruthin Road, Wrexham ? Land off Brynycabanau Road, WR23CS Hightown, Wrexham Lower Stansty Farm, Stansty WR27CS Chain Road, Stansty
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Erlas Centre, Bryn Estyn Road, WR28CS Wrexham The Four Dogs Pub, Box Lane, Little Acton, Wrexham, LL12 WXT010UCS 8EF WXT019UCS Jacques Scrapyard, Wrexham WXT027UCS The Dunks South WXT035UCS Gwenfro WXT037UCS Anthony Eden Drive WXT039UCS Holt Road/Tan y Dre WXT069UCS Cefndre WXT074NUCS Powell Road, Wrexham Civic Quarter, Chester Road, WXT092NUCS Wrexham
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9. Overall Effects and Mitigation
“the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (SEA Directive Annex I(f))
“the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme” (SEA Directive Annex I(g))
9.1 The Local Development Plan Manual states that a sustainability appraisal should include an evaluation of the significance of the predicted effects including “the probability, duration, frequency and reversibility … [and] secondary, cumulative and synergistic effects”21. The Practical Guide to the Strategic Environmental Assessment (Office of the Deputy Prime Minister et al 2005) states that the nature of the effects should be assessed.
Impact prediction and evaluation 9.2 The Deposit Plan was evaluated to establish what its probable effects would be on the indicators identified in the Scoping Report, including short‐term impacts (0‐5 years), expected to be mostly related to construction of new developments medium term impacts (6‐10 years) long term impacts (11‐20 years), expected to be mostly related to operation of new developments.
9.3 Table 9.1 brings together the previous appraisals of Chapters 5‐8 to show what the overall/cumulative impacts of the Deposit Plan would be. Table 9.2 goes into further detail on the overall impacts of the Deposit Plan (the final row of Table 9.1), with a particular emphasis on the impacts of the proposed key strategic sites.
9.4 Overall the Deposit Plan would have significant benefits in providing the housing and employment land that the current and future residents of Wrexham County Borough will need. The position of Wrexham as a key settlement of national importance will be strengthened and the LDP will support regeneration of Wrexham town centre. It will help to improve access to good quality jobs, services and infrastructure. Resident’s health should improve in response to better housing, promotion of active travel, access to open space, and walking and cycling facilities. The LDP will deliver development resilient to climate change, avoiding areas at risk from flooding and not causing flooding elsewhere. To reduce carbon emissions the plan supports renewable energy generation and low carbon development and spatially distributes growth to reduce the need to travel.
9.5 But growth will impact negatively on the best and most versatile agricultural land and minerals of economic importance (mainly sand and gravel). There will also be negative impacts on assets of local value including ecology, landscapes and historic interest though features of international and national significance will be protected. Increased economic activity with a larger population will lead to increased transport movements, local congestion, increased waste generation and greenhouse
21 LDP Manual 2 August 2015, Chapter 3
Page 119 of 129 gas emissions and also increased air and noise pollution (though a growing population would have the same impacts).
9.6 Strategic options to avoid the negative impacts have been considered, different growth options, spatial distributions and strategic sites but opportunities to strategically reduce impacts are very limited. However, the plan contains a number of mitigation measures with policies protecting local ecology, landscapes and historic assets. Mineral policies ensure that prior extraction is considered and that a supply of minerals is maintained during the life of the plan. Growth is focussed in and adjacent to Wrexham the most sustainable town with the largest range of services and other tier 2-3 settlements. This will help reduce the need to travel, encourage active and sustainable transport, reduce per capita carbon emissions and improve accessibility.
Table 9.1 Overall/cumulative sustainability impacts of the Deposit Plan
Historic Environment
1. Role 1. of Wrexham Economy 2. Wrexham 3. Town Centre 4a. Travel Active Highways 4b. Capacity a 5. MixedCommunity Housing b. 5 Healthy 6. Living Character 7b. Welsh & Language Infrastructure 8. 9a. Ecology & Habitats Natural 9b. Resources 9c. Landscape 9d. 10a. Carbonemissions 10b. ClimateChange Resilience Minerals 11. 12. Waste Vision Objectives SA and LDP Objectives are Integrated SP1; Housing Provision SP2; Location of New Development SP3: KSS Key Strategic Sites SP4: KSS1 SP5: KSS2 SP6: Planning Obligations SP7: Green Wedge SP8: Wrexham Town ? SP9 Economic Growth, Employment and Enterprise SP10: Wrexham Industrial Estate SP11: KSS3 WIE SP12 Transport and Accessibility SP13: Design Principles SP14: Health & Wellbeing
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SP15: Natural Environment SP16; Historic and Cultural Environment SP17: Minerals Supply and Safeguarding SP18: Sustainable Waste Management SP19: Climate Change SP20: Green Infrastructure
Language
1. Role 1. of Wrexham Economy 2. Wrexham 3. Town Centre 4a. Travel Active Highways 4b. Capacity a 5. MixedCommunity Housing b. 5 Healthy 6. Living Character 7b. Welsh & Infrastructure 8. 9a. Ecology & Habitats Natural 9b. Resources 9c.Historic Environment Landscape 9d. 10a. Carbonemissions 10b. ClimateChange Resilience Minerals 11. 12. Waste DM1: Development Management NE1: European and Nationally Designated Sites NE2: Locally designated sites of nature conservation and geological importance NE3: Trees Woodlands and Hedgerows NE4: Area of Outstanding Natural Beauty NE5: Special Landscape Areas NE6: Waste Water Treatment and Water Quality BE1: Pontcysyllte Aqueduct and Canal World Heritage Site BE2: Trevor Basin Masterplan Area H1: Housing Provision
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H2; Affordable Housing H3: Affordable Housing Exception Sites H4; Gypsy and Traveller Sites H5: Gypsy and Traveller Accommodation H6; Houses in Multiple Occupation H7: Houses in the Countryside H8: Replacement Dwellings in the Countryside H9: Conversion of Buildings EM1: Protection of Existing Employment Land EM2: Provision of Supporting Facilities EM3: Alternative Use Employment Land EM4: Employment Development Outside of Settlement limits EM5: Visitor Accommodation EM6: Pentre Maelor Housing Buffer T1: Managing Transport Impacts T2: Active Travel T3: Passenger Transport T4: Wrexham General Rail Station Enhancements T5: Safeguarding of Dis-used Railway Infrastructure T6: Strategic Transport Infrastructure Improvements R1: Retail Hierarchy R2: Development in the Masterplan Area R3: Primary Shopping Streets
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R4: Proposals Outside Primary Shopping Streets R5: District, Local, Village and Neighbourhood Centres R6: Retail Development (Out of Centre) R7: Loss of Local Services CF1: Protection of Open Space CF2: Open Space in New Development CF3: Regional Sports Stadia MW1: Minerals Safeguarding MW2: Minerals Buffer Zones MW3: Sustainable Supply of Minerals MW4: Secondary Aggregates MW5: Sustainable Waste Management MW6: Waste Management Facilities W1: Welsh Language RE1: Development and Renewable Energy/Low Carbon Technology RE2: Renewable Energy Schemes
Table 9.2 Overall sustainability impacts of the Deposit Plan: short, medium and long term impacts
SA Objective Overall Impacts S M L Objective 1: The plan will have positive effects for this objective by focussing the majority Ensuring that the role of growth in housing and employment in Wrexham and in facilitating the of Wrexham as a delivery of necessary and enabling infrastructure to support growth in terms of key settlement of highways/transport, education etc. national importance in the Wales Spatial The delivery of housing, take up of employment land, regeneration of Plan Wrexham – Wrexham town centre, delivery of A483 Junction improvements and transport Deeside – Chester infrastructure will gain impact as the plan progresses with the greatest benefits hub is strengthened; accruing toward the plan end and beyond.
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Objective 2: Support The plan will deliver a platform for strong economic growth with provision for a a vibrant, diverse and strategic expansion to WIE while also safeguarding other regional and locally competitive local important employment estates and support for significant jobs growth. Other economy that sectors such as retail, minerals, waste, tourism, renewables, rural and farming provides a range of enterprises will also benefit from the plans policies. job opportunities to enable new and Supporting employment growth will be balanced growth in housing and the existing businesses delivery of necessary and enabling infrastructure. to grow in Wrexham town and Wrexham Industrial Estate; Objective 3: The retail strategy for the town focuses development to the retail hierarchy Regenerate with Wrexham town centre sitting at the top. The LDP sets a framework to Wrexham Town support regeneration of the town (Masterplan, Design Masterplan Framework) Centre as a and transport infrastructure upgrades with which to bring about qualitative multifunctional improvements in the town centre with enhanced connectivity. destination for retail, education, civic, amenity, employment, leisure and residential uses; Objective 4a: ? x The plan locates development where the need to travel has been reduced and Promote active where sustainable travel can be supported. It provides transport infrastructure travel and use of to support active and sustainable travel and it places active travel at the public transport by forefront of travel planning and designing developments. locating new development in the Traffic will increase as a result of growth, mitigation will be provided but this most sustainable will not completely divert traffic onto public transport or into active travel. The locations, and seek best opportunities to influence travel behaviours will be with new development. to alleviate known highway The success of this will largely depend on the publics propensity to change infrastructure travel behaviours, often factors outside of planning will have a bearing, capacity constraints however the LDP will encourage a shift from car movement to walking/cycling on the road network and use of public transport. within the County Borough; Objective 4b: x x Growth will lead to additional traffic movements, the plan provides mitigation in Promote active travel the strategic transport policy, key strategic sites policies, planning obligations and use of public and design principles which will help keep highways operating within capacity transport by locating but there are likely to be local impacts. new development in the most sustainable WG plans for investment in the A483 junctions during the plan period will locations, and seek prevent highways capacity becoming a regional/national constraint. The to alleviate known strategic policies (SP4) are worded to keep impacts local (through phasing highway and timing of development). infrastructure capacity See active travel policy assessment for detailed mitigation to encourage active constraints on the travel and sustainable transport. road network within the County Borough; Objective 5a: Strategic policy SP1 delivers a significant quantity of market housing with Facilitate mixed potential to deliver affordable housing, addresses housing types and tenures diverse and needs of the community. communities by delivering housing, Development is located in the most viable areas to ensure that sites have including affordable development value to fund enabling and necessary infrastructure needed to homes to meet the support development.
Page 124 of 129 needs of the County Borough; Policies for the location of development, Wrexham Town, key strategic sites, Transport promote accessibility to employment, services and facilities needed to support new housing.
Policies for transport, planning obligations, green infrastructure, open spaces, climate change and design ensure that housing is supplied with the necessary infrastructure, connectivity and design to support communities.
The wider needs of the community, G&T, rural communities, tenures etc. have been addressed. Objective 5b: The spatial distribution of housing helps meet needs throughout the County Facilitate mixed Borough. Due to viability, lack of constraint free sites and the distribution of diverse communities housing needs it is not possible to perfectly match housing supply with by delivering affordable housing needs but the strategic and detailed policies make the best housing, including efforts to maximise affordable housing supply responsive to viability variances affordable homes to across the County Borough and the supply of housing. meet the needs of the County Strategic policy SP1 delivers a significant quantity of market housing with Borough; potential to deliver affordable housing, addresses housing types and tenures and needs of the community. Objective 6: x x x The promotion of health and wellbeing is embedded in the LDP; the plan Promote and encourages healthy lifestyles especially active travel, addresses living and encourage a healthy, environmental conditions (new housing and community facilities), grows the active and safe economy and improves accessibility (transport and location of development) lifestyle; while providing infrastructure to support development and communities.
Much will depend on the ability of the LDP to promote active lifestyles and facilitate/provide infrastructure (much of which is outside the control of planning) at the planning application stage. There will also be an increase in air pollution. Objective 7: x x x The locations for growth and its scale will place pressure on local character Conserve, enhance and culture, but the impact is dependent on site specifics and mitigation at the and promote the local planning application stage. culture, character and distinctiveness of The approach to green wedge, natural and historic environment (AONB, Wrexham including World Heritage), SLA, green infrastructure, locally designated sites, trees and the Welsh Language; hedgerows will help protect and enhance international and nationally important assets while also protecting local character and settlements from coalescence. The design policy and green infrastructure policy will help protect and mitigate impacts locally but generally the outcomes for local character are uncertain until the detailed application is submitted.
The needs of the Welsh Language community have been considered in the LDP with opportunities for windfall development and where appropriate mitigation to address negative impacts and provide positive support. Objective 8 Ensure ? ? ? Development will place pressure on existing infrastructure in particular all development is education, open spaces, highways, waste water and health. Impacts of supported by the development on infrastructure are locational specific. necessary provision of, or improvements Development is located in the most viable areas to ensure that sites have to infrastructure, development value to fund enabling and necessary infrastructure needed to services and facilities support development. Infrastructure necessary to deliver and enable the in an effective and allocated sites has been identified and the phasing and timing of development timely manner to is tied to the delivery of infrastructure. Policy hooks are in place to ensure that make development mitigation is available to deliver the infrastructure. sustainable and minimise its effect However, there are challenges in providing all infrastructure associated with
Page 125 of 129 upon existing development, viability will vary site by site, some sites may not be able to fund communities. all infrastructure and some infrastructure is delivered outside of the plan (particularly health, waste water and strategic transport). Infrastructure capacity will also vary during the plan period. The impact of these will be clear at detailed planning application stage. While the LDP has taken reasonable steps to deliver and co-ordinate delivery of infrastructure it cannot be certain what the outcome will be.
Mitigation seeks to make the most efficient use of existing infrastructure in areas which can viably deliver infrastructure through planning obligations/CIL and mitigate impacts through policies for Infrastructure, Transport, Health and Wellbeing, Key Strategic sites, Design, waste and waste water treatment. Policy safeguards are in place to ensure that infrastructure necessary to deliver and enable development is provided with sites at an appropriate time.
There are several infrastructure types that are not funded through the planning system (e.g. health, utilities, water) the ability of these providers to keep up with demand will be outside the control of this plan. Objective 9a: ? x x Provides a strong steer to guide development away from the most sensitive Protect, manage ecological areas (Internationally and nationally designated sites) but growth and enhance the will impact on local ecological features as a consequence of the levels of natural and historic growth and the need for greenfield development. In particular the Key environment and strategic sites and location of development could have negative effects on landscapes; local features. Mitigation and avoidance measures are provided by policy SP13 Design and SP15 and detailed policies NE1-NE6.
A strategic approach to ecological mitigation is provided around Wrexham and WIE relating to Great Crested Newts and in Rhos with Hafod SAC. Objective 9b: x x xx The main negative effects would be caused by the policies that promote Protect, manage and housing and economic growth which requires greenfield development. The enhance the natural location of growth in tiers 1-3, would lead to the loss of the best and most and historic versatile agricultural land. environment and landscapes; A growing population and increased economic activity will increase transport related air pollution. Site specific impacts can be managed at the planning application stage but diffuse levels will increase.
Site specific mitigation protecting wider natural resource issues provided by SP15 (Environment), SP13 (Design), SP17 (Minerals) and DM1, NE6. The strategy of locating growth in Wrexham and other sustainable settlements with good active travel/public transport potential allied with transport policies will help encourage active travel to reduce emissions. Sustainable transport measures need to be in place when developments are occupied.
Water resources are given effective protection (NE6) and the plan supports the re-use of land with contamination. Few allocations are on brownfield land but a significant proportion of the housing and employment supply is brownfield. Objective 9c: ? x x Protection of historic and cultural heritage is embedded in the plans vision and Protect, manage and the Historic environment policy (SP16) provides protection and enhancement enhance the natural for internationally, nationally important historic and cultural assets. and historic environment and The plans spatial strategy, housing allocations, mineral and renewable landscapes; policies, in allowing greenfield development, will pressure heritage assets and potentially unknown features. SP16, the design policy SP13 and DM1 provides protection and mitigation but the outcomes are uncertain as much depends on site specifics and mitigation.
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Growth and regeneration will put development pressure on local assets particularly in Wrexham and town centre. Objective 9d: ? x x Provides a strong steer to guide development away from the most sensitive Protect, manage and landscape areas (Internationally and nationally designated sites) and manage enhance the natural development within them. But growth will impact on local features as a and historic consequence of the levels of growth and the need for greenfield development. environment and In particular the Key strategic sites, spatial location of development, landscapes; allocations, minerals and renewables policies could have negative effects on local features. Mitigation and avoidance measures are provided by policy SP4-5, SP7, Green Wedge, SP15 (Historic) and SP13 Design and detailed policies DM1, NE2, 3, 4, and 5, RE2. Over the course of the plan incremental cumulative impacts can erode local character dependent on the effectiveness of mitigation.
Prior extraction of mineral resources (MW1) may conflict with landscape features of local value. Objective 10a: x x x The growth agenda of the plan (housing and economy) will increase carbon Reduce carbon emissions through economic activity and increased travel. But policies emissions and reinforcing the role of Wrexham and Wrexham town centre, the most maximise our sustainable location for development, offer opportunities to reduce these resilience to and effects (resource efficiency, minimising travel, and opportunities to facilitate mitigate and adapt to sustainable building standards) though there will still be an impact. the impact of climate change The plan also promotes low carbon and renewable energy development through the detailed policies RE1 and RE2 with an energy opportunities plan (REA). The plan seeks to reduce the need to travel by locating development in the most sustainable locations with a range of services while promoting sustainable transport.
Strategic policies for Transport, location for development, Key Strategic Sites, Design and Minerals provide the hooks by which avoidance and mitigation measures can be delivered and help reduce per capita emissions.
The absolute levels of carbon will increase (as they would with a growing population) but the plan takes positive steps in reducing per capita emissions, hence an overall positive outcome for this objective.
One of the biggest generators of emissions is space heating for homes where the LDP (RE1) has the potential to improve energy performance in new build. Objective 10b: Strategic policy 19 and SP20 ensures development delivers this objective. Reduce carbon emissions and The plan protects and enhances the natural environment, green infrastructure, maximise our open spaces and natural resources that have important roles in climate resilience to and change resilience. SP19, SP20, DM1 and the Design policy SP13 ensure that mitigate and adapt these issues are addressed through the planning application stage with to the impact of planning obligations mitigation in place to address issues. climate change The majority of the spatial areas for development avoid areas at risk of flooding but there are some locations that require further avoidance and mitigation at site level, particularly with regards to surface water. Surface water flood risk occurs in specific sites and the loss of greenfields may impact on capacity to deal with flood events and cause flooding elsewhere but in principle all known flooding issues can be resolved at planning application stage. Objective 11: Ensure x x x On balance the LDP plans effectively for minerals by safeguarding resources development meets and ensuring a long term supply, it manages conflicts between minerals and the needs of society non-mineral development by using buffer zones and mineral extraction and industry, now exclusion areas.
Page 127 of 129 and in the future, through However, the scale and location for development (KSS’s, policy SP2 and H1) ensuring adequate creates internal conflicts with the minerals approach. These policies will lead protection and supply to development on greenfield sites many of which are underlain by mineral of high quality resources. minerals; Other plan objectives and sustainability reasons outweigh the loss of minerals, in particular, supporting Wrexham as a key national settlement, promoting active and sustainable travel, reducing carbon emissions, providing housing and associated infrastructure to support communities and ensuring climate change resilience.
Policies SP17 and MW1-4 provides mitigation in promoting prior extraction and protecting/supplying mineral resources. Therefore, safeguards are in place to ensure that where possible prior extraction can occur and impacts are minimised.
Protection of the natural environment conflicts with the supply of mineral resources though the most sensitive resources are protected limiting impacts to the potential loss of local features. Objective 12: ? Absolute levels of waste will increase but the strategy makes provision for Facilitate the additional employment land which can accommodate waste handling sites and provision of an detailed policies require developments to consider ways of reducing waste integrated during the development and operation of sites. The approach of the plan gives network of waste reasonable confidence that per capita waste can fall. facilities which enable waste to be managed in a sustainable way.
9.5 Environmentally, the Deposit Plan would have some significant negative impacts. The LDP includes major Greenfield sites located on the edge of Wrexham, Wrexham Industrial Estate and other settlements with impacts of a local nature on landscapes, historical assets and biodiversity. Greenfield expansions will lead to the loss of the best and most versatile agricultural land and in some locations mineral resources. Air pollution arising from increased travel will increase.
9.6 With an increased population and economic growth there will be an increase in transport movements, largely by private car. Greenhouse gas emissions are likely to increase because of increased traffic (and economic activity) which will add to congestion on the highway network.
Mitigation measures
9.7 Measures to avoid or reduce the impact of individual LDP policies or proposed development sites are listed at Tables 6.1 and 7.4.
Conclusion 9.8 This appraisal demonstrates that there are no major sustainability concerns. This is a challenging time for developing planning policy and there is an expectation to deliver solutions to serious long term issues such as climate change, energy resources, housing need and transport. The LDP needs to be clear about the environment in which it is being prepared and what other policy drivers and mechanisms are also required to deliver the required outcomes for the County Borough.
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10. Implementation 10.1 Links to other tiers of plans and programmes and the project level (EIA, design guidance etc.)
10.1 Following this consultation WCBC will collate consultation responses, where appropriate make a small number of focused changes to the LPD and submit to the Welsh Government for Examination. Following examination and adoption, for the plan period of 2013-2028 planning applications will be determined in accordance with the plan unless material circumstances indicate otherwise. Applications which do not accord with the plan will not be allowed unless material considerations justify the grant of planning permission.
10.2 Once adopted, aspects of policy in the LDP may require more detailed guidance to facilitate understanding and delivery of the policy aims. This will be achieved by issuing Supplementary Planning Guidance Notes (SPG). The Deposit LDP will identify the SPG needed.
Monitoring 10.3 Proposals for monitoring the significant effects identified through the SA.
“a description of the measures envisaged concerning monitoring" (SEA Directive Annex I(i))
10.3.1 Once a plan is adopted, the SEA Regulations require local authorities to “monitor the significant environmental effects of the implementation of each plan or programme with the purpose of identifying unforeseen adverse effects at an early stage and being able to undertake appropriate remedial action” (Reg. 17), and the environmental report should describe how this might be carried out.
10.3.2 The SA process has identified a range of significant environmental effects, as well as underlying assumptions of the LDP which, if they do not work out in practice, could lead to unforeseen adverse effects. The final sustainability report that will accompany the Deposit Plan will provide a framework to monitor these impacts. It will show; monitoring indicators that aim to measure likely effects of the LDP identified in the SA; who would monitor the indicators and how frequently; targets (positive) that the LDP will try to achieve; information about why the indicator has been proposed
10.3.3 The starting point for these indicators will be Table 6.1 of the Sustainability Scoping Report, October 2014 which shows the current situation in Wrexham, based on existing monitoring data.
10.3.4 This will be supplemented by a set of monitoring indicators to help the Council assess the effectiveness of the plan’s policies and allocations in an Annual Monitoring Report that helps inform the review of the LDP.
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