Wrexham Local Development Plan 2013 - 2028

Key Stakeholder Consultation Comments and Offi cer Responses June 2015

housing open space employment community transport education

www.wrexham.gov.uk / www.wrecsam.gov.uk

CONTENTS

Contents 1. List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ...... 2 2. List of Respondents to Issues and Options Consultation ...... 29 3. Officer Responses to Stakeholder Comments ...... 35 Q.2. Comments on Vision ...... 36 Q.4. Comments on Objectives ...... 45 Q.5. Comments on Issues ...... 65 Q.6. Comments on Option A ...... 82 Q.7 Comments on Option B ...... 94 Q8. Comments on Option C ...... 104 Q9. Reasons/comments for preferred Growth Option ...... 111 Q10. Other Suggested Growth Options ...... 122 Q.11 Comments on Spatial Option 1 - Primary Key Settlement (Wrexham Town) Focussed including Key Strategic Sites? ...... 128 Q.12 Comments on Option 2 - Primary Key Settlement (Wrexham Town) and Key Settlement Focussed? ...... 146 Q13. Comments on Option 3 - Primary Key Settlement (Wrexham Town), Key Settlements & Local Service Centre Focussed?...... 161 Q14. Preferred Spatial Option Comments and Reasons ...... 178 Q15. Other suggested Spatial Options and Comments ...... 194 Q16. What do you think the Council should prioritise in terms of developer contributions? ...... 212 Q17. Comments on Proposed Methods of Monitoring? ...... 227 Q18. Comments on Evidence Base ...... 231 General Comments ...... 240

1 Wrexham LDP – Issues and Options Consultation Responses

1. List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015

2 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 249 B1 Other Consultees determined by LPA Agent/Consultant Brian Lloyd 394 B1 Other Consultees determined by LPA Agent/Consultant Tim Evans 636 B1 Other Consultees determined by LPA Agent/Consultant John Miles 812 B1 Other Consultees determined by LPA Agent/Consultant J Ayers-Morgan 819 B1 Other Consultees determined by LPA Agent/Consultant K Robertson 820 B1 Other Consultees determined by LPA Agent/Consultant Philip Moren 840 B1 Other Consultees determined by LPA Agent/Consultant Michael Hughes 886 B1 Other Consultees determined by LPA Agent/Consultant Alexander F Litherland 6426 B1 Other Consultees determined by LPA Agent/Consultant A.J. Minshull 7031 B1 Other Consultees determined by LPA Agent/Consultant Barry Smith 7615 B1 Other Consultees determined by LPA Agent/Consultant Tim Rosselli 7678 B1 Other Consultees determined by LPA Agent/Consultant Adam Wardle 7691 B1 Other Consultees determined by LPA Agent/Consultant J Alan Wright 8286 B1 Other Consultees determined by LPA Agent/Consultant David Cooper 8347 B1 Other Consultees determined by LPA Agent/Consultant R Blackwood 154 B1 Other Consultees determined by LPA Agent/Consultant Aaron & Partners 874 B1 Other Consultees determined by LPA Agent/Consultant Aaron & Partners Solicitors 828 B1 Other Consultees determined by LPA Agent/Consultant Adams Holmes Associates 7036 B1 Other Consultees determined by LPA Agent/Consultant ADS Project Management & Architectural Design Services 8359 B1 Other Consultees determined by LPA Agent/Consultant Allies and Morrison Urban Practitioners 7094 B1 Other Consultees determined by LPA Agent/Consultant Andrew Design Service 8009 B1 Other Consultees determined by LPA Agent/Consultant Anthony Bowhill & Associates 7043 B1 Other Consultees determined by LPA Agent/Consultant Architectural Consultant-DSJ Electra 697 B1 Other Consultees determined by LPA Agent/Consultant Atisreal UK 166 B1 Other Consultees determined by LPA Agent/Consultant AXIS 717 B1 Other Consultees determined by LPA Agent/Consultant Balfours 718 B1 Other Consultees determined by LPA Agent/Consultant Balfours - Shrewsbury Office 835 B1 Other Consultees determined by LPA Agent/Consultant Barbers Chartered Surveyors 7702 B1 Other Consultees determined by LPA Agent/Consultant Barbers Chartered Surveyors 8326 B1 Other Consultees determined by LPA Agent/Consultant Barbers Rural Consultancy

3 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 8247 B1 Other Consultees determined by LPA Agent/Consultant Barbers, Chartered Surveyors 8285 B1 Other Consultees determined by LPA Agent/Consultant Barkin Developments 689 B1 Other Consultees determined by LPA Agent/Consultant Barry Vernon Design & Build 6526 B1 Other Consultees determined by LPA Agent/Consultant Barton Willmore 7618 B1 Other Consultees determined by LPA Agent/Consultant Barton Willmore Ltd 6985 B1 Other Consultees determined by LPA Agent/Consultant Baynon Property Services 7045 B1 Other Consultees determined by LPA Agent/Consultant Ben Blake Architectural Design 6517 B1 Other Consultees determined by LPA Agent/Consultant Bench Mark Designs 8412 B1 Other Consultees determined by LPA Agent/Consultant Berrys Chartered Surveyors & Valuers (on behalf of Toni Jones and Richard Tomlinson) 8452 B1 Other Consultees determined by LPA Agent/Consultant Berrys Chartered Surveyors and Valuers (on behalf of R&C Homes Ltd) 7619 B1 Other Consultees determined by LPA Agent/Consultant Black Pear Consulting 7044 B1 Other Consultees determined by LPA Agent/Consultant Blackmores Ltd 8345 B1 Other Consultees determined by LPA Agent/Consultant Blueprint 7266 B1 Other Consultees determined by LPA Agent/Consultant Bob Dewey Planning 8157 B1 Other Consultees determined by LPA Agent/Consultant Bond Pearce Solicitors 733 B1 Other Consultees determined by LPA Agent/Consultant Bowen Son & Watson Oswestry Office 855 B1 Other Consultees determined by LPA Agent/Consultant Bowen Son & Watson Wrexham Office 8400 B1 Other Consultees determined by LPA Agent/Consultant Brookdale Consulting Ltd 7672 B1 Other Consultees determined by LPA Agent/Consultant Cadnant Planning 6538 B1 Other Consultees determined by LPA Agent/Consultant Capita Symonds Cwmbran Office 6507 B1 Other Consultees determined by LPA Agent/Consultant Capita Symonds North Wales Office 8303 B1 Other Consultees determined by LPA Agent/Consultant Carlton Holdings 8005 B1 Other Consultees determined by LPA Agent/Consultant Carpenter Planning Consultants 6533 B1 Other Consultees determined by LPA Agent/Consultant Carter Jonas 8313 B1 Other Consultees determined by LPA Agent/Consultant Carter Jonas 6560 B1 Other Consultees determined by LPA Agent/Consultant Casely & Whale Studio 83 6531 B1 Other Consultees determined by LPA Agent/Consultant Cassidy and Ashton Planning 671 B1 Other Consultees determined by LPA Agent/Consultant CB Richard Ellis Limited 8348 B1 Other Consultees determined by LPA Agent/Consultant CBRE Ltd

4 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7090 B1 Other Consultees determined by LPA Agent/Consultant CDN Planning 8010 B1 Other Consultees determined by LPA Agent/Consultant Chapman Warren 7757 B1 Other Consultees determined by LPA Agent/Consultant Chapman Warren Plc 8034 B1 Other Consultees determined by LPA Agent/Consultant Chartered Town Planner 8316 B1 Other Consultees determined by LPA Agent/Consultant Christal Planning Services Ltd 603 B1 Other Consultees determined by LPA Agent/Consultant Clough & Co 8031 B1 Other Consultees determined by LPA Agent/Consultant Colin Buchanan & Partners 6547 B1 Other Consultees determined by LPA Agent/Consultant Colliers CRE London Office 8362 B1 Other Consultees determined by LPA Agent/Consultant Colliers International 8337 B1 Other Consultees determined by LPA Agent/Consultant Concept Town Planning Ltd 8289 B1 Other Consultees determined by LPA Agent/Consultant Cunliffe Planning Consultancy 882 B1 Other Consultees determined by LPA Agent/consultant Cushman & Wakefield 7558 B1 Other Consultees determined by LPA Agent/Consultant D R Consultants 7029 B1 Other Consultees determined by LPA Agent/Consultant D. S. Jones & Co. 821 B1 Other Consultees determined by LPA Agent/Consultant Dalton & Co 7836 B1 Other Consultees determined by LPA Agent/Consultant David A Griffiths Partnership 1939 B1 Other Consultees determined by LPA Agent/Consultant David Cartwright Solicitor 832 B1 Other Consultees determined by LPA Agent/consultant David L Walker Chartered Surveyors 7055 B1 Other Consultees determined by LPA Agent/Consultant David L Walker Ltd 843 B1 Other Consultees determined by LPA Agent/consultant David Owen Architectural Services 738 B1 Other Consultees determined by LPA Agent/Consultant David Owen Associates 6999 B1 Other Consultees determined by LPA Agent/Consultant Davis Meade Property Consultants 157 B1 Other Consultees determined by LPA Agent/Consultant Denton Clark 478 B1 Other Consultees determined by LPA Agent/Consultant Development Consultant 100 B1 Other Consultees determined by LPA Agent/Consultant Development Planning Partnership 6011 B1 Other Consultees determined by LPA Agent/Consultant Dixon Webb 7693 B1 Other Consultees determined by LPA Agent/Consultant Dixon Webb 7102 B1 Other Consultees determined by LPA Agent/Consultant DLP Planning Ltd 8333 B1 Other Consultees determined by LPA Agent/Consultant DMS Architectural and Surveying Services 7097 B1 Other Consultees determined by LPA Agent/Consultant Douglas Hughes Architects LTD 7553 B1 Other Consultees determined by LPA Agent/Consultant DPDS Consulting 5 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7683 B1 Other Consultees determined by LPA Agent/Consultant Drivers Jonas 107 B1 Other Consultees determined by LPA Agent/Consultant DTZ Pieda Consulting 7233 B1 Other Consultees determined by LPA Agent/Consultant E.Wyles & Son 223 B1 Other Consultees determined by LPA Agent/Consultant Edmund Kirby 8325 B1 Other Consultees determined by LPA Agent/Consultant ERW Consulting 8327 B1 Other Consultees determined by LPA Agent/Consultant Fisher German 8419 B1 Other Consultees determined by LPA Agent/Consultant Fisher German 7623 B1 Other Consultees determined by LPA Agent/Consultant Fitzsimon Planning 8331 B1 Other Consultees determined by LPA Agent/Consultant Forge Property Ltd 806 B1 Other Consultees determined by LPA Agent/Consultant Frampton 8253 B1 Other Consultees determined by LPA Agent/Consultant Fuller Peiser 8399 B1 Other Consultees determined by LPA Agent/Consultant Fusion Online Ltd 279 B1 Other Consultees determined by LPA Agent/Consultant G. Raymond Jones & Associates 289 B1 Other Consultees determined by LPA Agent/Consultant Garston Partnership 772 B1 Other Consultees determined by LPA Agent/Consultant George & Tomos 8032 B1 Other Consultees determined by LPA Agent/Consultant Gerald Eve 7440 B1 Other Consultees determined by LPA Agent/Consultant GL Hearn 7038 B1 Other Consultees determined by LPA Agent/Consultant Gladman (on behalf of Ruabon Sales Ltd) 7549 B1 Other Consultees determined by LPA Agent/Consultant GLHearn 8288 B1 Other Consultees determined by LPA Agent/Consultant Glyndwr University Racecourse Stadium 162 B1 Other Consultees determined by LPA Agent/Consultant Goodwin Planning Service Ltd 7684 B1 Other Consultees determined by LPA Agent/Consultant Grant Thornton 8324 B1 Other Consultees determined by LPA Agent/Consultant Greenspace Architects Ltd 181 B1 Other Consultees determined by LPA Agent/Consultant Guy Woodcock & Company 8155 B1 Other Consultees determined by LPA Agent/Consultant GVA Grimley 229 B1 Other Consultees determined by LPA Agent/Consultant Gwilym Hughes & Partners 8179 B1 Other Consultees determined by LPA Agent/Consultant Hadens Solicitors 6994 B1 Other Consultees determined by LPA Agent/Consultant Halls 8315 B1 Other Consultees determined by LPA Agent/Consultant Halls Holdings Ltd 135 B1 Other Consultees determined by LPA Agent/Consultant Harmers Ltd 81 B1 Other Consultees determined by LPA Agent/Consultant Harris Lamb 6 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7557 B1 Other Consultees determined by LPA Agent/Consultant Harrow Estates 939 B1 Other Consultees determined by LPA Agent/Consultant Haston Reynolds Ltd 8417 B1 Other Consultees determined by LPA Agent/Consultant Heaton Planning on behalf of Lafarge Tarmac Trading Ltd 8297 B1 Other Consultees determined by LPA Agent/Consultant Hendersons Global Investors 7095 B1 Other Consultees determined by LPA Agent/consultant Heritage Planning Consultancy 675 B1 Other Consultees determined by LPA Agent/Consultant Higham & Co 672 B1 Other Consultees determined by LPA Agent/Consultant Hourigan Connolly 8382 B1 Other Consultees determined by LPA Agent/Consultant Hourigan Connolly 6467 B1 Other Consultees determined by LPA Agent/Consultant HOW Planning 880 B1 Other Consultees determined by LPA Agent/consultant HOW Planning LLP 6981 B1 Other Consultees determined by LPA Agent/Consultant HOW Planning LLP 8409 B1 Other Consultees determined by LPA Agent/Consultant HOW Planning LLP on behalf of Kingmoor Park Properties 836 B1 Other Consultees determined by LPA Agent/consultant Incorporated Surveyor 8002 B1 Other Consultees determined by LPA Agent/Consultant Insignia Richard Ellis 41 B1 Other Consultees determined by LPA Agent/Consultant ISP Architects 724 B1 Other Consultees determined by LPA Agent/Consultant J Ross Developments 186 B1 Other Consultees determined by LPA Agent/Consultant J. Bradburne, Price & Co 155 B1 Other Consultees determined by LPA Agent/Consultant J10 Planning Ltd 854 B1 Other Consultees determined by LPA Agent/Consultant James Barr - Chartered Surveyors 191 B1 Other Consultees determined by LPA Agent/Consultant JIG Architects Ltd 8352 B1 Other Consultees determined by LPA Agent/Consultant Jones Lang LaSalle 461 B1 Other Consultees determined by LPA Agent/Consultant Jones Peckover 599 B1 Other Consultees determined by LPA Agent/Consultant Jones Peckover 8335 B1 Other Consultees determined by LPA Agent/Consultant Jones Peckover Chartered Surveyors 8266 B1 Other Consultees determined by LPA Agent/Consultant Kemberton Consulting 234 B1 Other Consultees determined by LPA Agent/Consultant Kent Jones 233 B1 Other Consultees determined by LPA Agent/Consultant Kent Jones & Company 707 B1 Other Consultees determined by LPA Agent/Consultant Kent Jones & Done Solicitors 604 B1 Other Consultees determined by LPA Agent/Consultant Kerry James Planning

7 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 8298 B1 Other Consultees determined by LPA Agent/Consultant L.S Planning 8346 B1 Other Consultees determined by LPA Agent/Consultant Land Planning Ltd 434 B1 Other Consultees determined by LPA Agent/Consultant Lawray Partnership 158 B1 Other Consultees determined by LPA Agent/Consultant Legat Owen 8374 B1 Other Consultees determined by LPA Agent/Consultant Legat Owen 7726 B1 Other Consultees determined by LPA Agent/Consultant Loxley Estates 8152 B1 Other Consultees determined by LPA Agent/Consultant Malcolm Judd & Partners 7689 B1 Other Consultees determined by LPA Agent/Consultant Mark Dafydd Design & Developments 7690 B1 Other Consultees determined by LPA Agent/Consultant Mark Dafydd Design & Developments 8228 B1 Other Consultees determined by LPA Agent/Consultant Matthews & Goodman 8350 B1 Other Consultees determined by LPA Agent/Consultant Matthews & Goodman 818 B1 Other Consultees determined by LPA Agent/Consultant McCormick Architecture 169 B1 Other Consultees determined by LPA Agent/Consultant McCormick Architecture Ltd 841 B1 Other Consultees determined by LPA Agent/consultant McDyre & Co 7696 B1 Other Consultees determined by LPA Agent/Consultant MCP Planning 6472 B1 Other Consultees determined by LPA Agent/Consultant MDB Architecture Ltd 8304 B1 Other Consultees determined by LPA Agent/Consultant Miles Designs Ltd 6481 B1 Other Consultees determined by LPA Agent/Consultant MJCA 324 B1 Other Consultees determined by LPA Agent/Consultant Modular Design 967 B1 Other Consultees determined by LPA Agent/Consultant Morris Marshall & Poole 6558 B1 Other Consultees determined by LPA Agent/Consultant Morston Assets 8387 B1 Other Consultees determined by LPA Agent/Consultant Morston Assets 8414 B1 Other Consultees determined by LPA Agent/Consultant Mosaic Town Planning 873 B1 Other Consultees determined by LPA Agent/consultant MTP Town Planning 883 B1 Other Consultees determined by LPA Agent/consultant MWA Planning & Development 1972 B1 Other Consultees determined by LPA Agent/Consultant Nathaniel Lichfied & Partners 833 B1 Other Consultees determined by LPA Agent/consultant Nathaniel Lichfield & Partners 7304 B1 Other Consultees determined by LPA Agent/Consultant Nigel Thorns Planning Consultancy 8364 B1 Other Consultees determined by LPA Agent/Consultant NJL 6406 B1 Other Consultees determined by LPA Agent/Consultant Norman Lloyd & Co 8130 B1 Other Consultees determined by LPA Agent/Consultant North West Developments 8 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 612 B1 Other Consultees determined by LPA Agent/Consultant Parry Davies Partnership 737 B1 Other Consultees determined by LPA Agent/Consultant Paul F. Rowley & Co 8033 B1 Other Consultees determined by LPA Agent/Consultant PB Developments Limited 664 B1 Other Consultees determined by LPA Agent/Consultant Peacock and Smith 209 B1 Other Consultees determined by LPA Agent/Consultant Pegasus Planning Group 7288 B1 Other Consultees determined by LPA Agent/Consultant Pegasus Planning Group 879 B1 Other Consultees determined by LPA Agent/consultant Planning & Law 7663 B1 Other Consultees determined by LPA Agent/Consultant Planning and Development Surveyor, Carter Jonas LLP 89 B1 Other Consultees determined by LPA Agent/Consultant Planning Bureau Limited 174 B1 Other Consultees determined by LPA Agent/Consultant Planning Consultant 966 B1 Other Consultees determined by LPA Agent/Consultant Planning Consultant 6473 B1 Other Consultees determined by LPA Agent/Consultant Planning Department - Lambert Smith Hampton 6513 B1 Other Consultees determined by LPA Agent/Consultant Planning Potential 6557 B1 Other Consultees determined by LPA Agent/Consultant Planning Potential Ltd 8391 B1 Other Consultees determined by LPA Agent/Consultant Planware 659 B1 Other Consultees determined by LPA Agent/Consultant Pritchard Associates 6537 B1 Other Consultees determined by LPA Agent/Consultant Quadrant Business and Property Consultants 8287 B1 Other Consultees determined by LPA Agent/Consultant Renew Planning 8341 B1 Other Consultees determined by LPA Agent/Consultant Rhian Evans Architect:Pensaer 6482 B1 Other Consultees determined by LPA Agent/Consultant Richard Draper Planning 8003 B1 Other Consultees determined by LPA Agent/Consultant Robert Turley Associates 7568 B1 Other Consultees determined by LPA Agent/Consultant Roger Parry & Partners 8338 B1 Other Consultees determined by LPA Agent/Consultant Roger Parry & Partners Ltd 8351 B1 Other Consultees determined by LPA Agent/Consultant Roger Parry & Partners Ltd 8299 B1 Other Consultees determined by LPA Agent/Consultant Roger Parry and Partners 785 B1 Other Consultees determined by LPA Agent/Consultant Roger Parry Chartered Surveyors 663 B1 Other Consultees determined by LPA Agent/Consultant Ross Stewart Associates 6478 B1 Other Consultees determined by LPA Agent/Consultant Rostons Land & Property Specialists 170 B1 Other Consultees determined by LPA Agent/Consultant Rostons Limited 860 B1 Other Consultees determined by LPA Agent/consultant RPS

9 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 99 B1 Other Consultees determined by LPA Agent/Consultant RPS Group 7248 B1 Other Consultees determined by LPA Agent/Consultant Russell Taylor Associates 499 B1 Other Consultees determined by LPA Agent/Consultant S. Murray & Associates 108 B1 Other Consultees determined by LPA Agent/Consultant Savills 7546 B1 Other Consultees determined by LPA Agent/Consultant Savills 8328 B1 Other Consultees determined by LPA Agent/Consultant Savills (UK) Ltd 6413 B1 Other Consultees determined by LPA Agent/Consultant Schofield Brothers 6485 B1 Other Consultees determined by LPA Agent/Consultant Scott Wilson Ltd 5236 B1 Other Consultees determined by LPA Agent/Consultant Sedgewick Associates 7669 B1 Other Consultees determined by LPA Agent/Consultant Sedgewick Associates 1954 B1 Other Consultees determined by LPA Agent/Consultant Shire Consulting 218 B1 Other Consultees determined by LPA Agent/Consultant Simon Richardson Planning and Law 448 B1 Other Consultees determined by LPA Agent/Consultant Sloane Mead 451 B1 Other Consultees determined by LPA Agent/Consultant Smiths Gore 845 B1 Other Consultees determined by LPA Agent/consultant Smiths Gore 8307 B1 Other Consultees determined by LPA Agent/Consultant Smiths Gore 8360 B1 Other Consultees determined by LPA Agent/Consultant Spawforths 7530 B1 Other Consultees determined by LPA Agent/Consultant Steer Ethelston Rural Ltd 8365 B1 Other Consultees determined by LPA Agent/Consultant Steve Goodwin Planning 7004 B1 Other Consultees determined by LPA Agent/Consultant Steven Abbott Associates LLP 662 B1 Other Consultees determined by LPA Agent/Consultant Stewart Ross Associates 159 B1 Other Consultees determined by LPA Agent/Consultant Strutt & Parker 7666 B1 Other Consultees determined by LPA Agent/Consultant Strutt and Parker LLP 8257 B1 Other Consultees determined by LPA Agent/Consultant Symonds 230 B1 Other Consultees determined by LPA Agent/Consultant T A C P 876 B1 Other Consultees determined by LPA Agent/consultant TACP (Cardiff Office) 8336 B1 Other Consultees determined by LPA Agent/Consultant TACP Architects Ltd 88 B1 Other Consultees determined by LPA Agent/Consultant Terence O' Rourke 5623 B1 Other Consultees determined by LPA Agent/Consultant The Planning Consultancy on behalf of Redrow Homes 868 B1 Other Consultees determined by LPA Agent/Consultant Town Planning Consultancy

10 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 670 B1 Other Consultees determined by LPA Agent/Consultant Turley Associates 6503 B1 Other Consultees determined by LPA Agent/Consultant Turley Associates 7039 B1 Other Consultees determined by LPA Agent/Consultant Turley Associates 8332 B1 Other Consultees determined by LPA Agent/Consultant URS Infrastructure & Environment UK Ltd 8410 B1 Other Consultees determined by LPA Agent/Consultant Vincent and Gorbing 6544 B1 Other Consultees determined by LPA Agent/Consultant Vortex Planning Ltd 454 B1 Other Consultees determined by LPA Agent/Consultant Walker Smith Way Solicitors 6443 B1 Other Consultees determined by LPA Agent/Consultant Wheat, Edwards & Associates 727 B1 Other Consultees determined by LPA Agent/Consultant Whitmore & Humphreys 8369 B1 Other Consultees determined by LPA Agent/Consultant William Hall & Co 457 B1 Other Consultees determined by LPA Agent/Consultant Wingetts 6506 B1 Other Consultees determined by LPA Agent/Consultant Wingetts 7703 B1 Other Consultees determined by LPA Agent/Consultant Wingetts 7773 B1 Other Consultees determined by LPA Agent/Consultant Wood Frampton 205 B1 Other Consultees determined by LPA Agent/Consultant Wright Manley 7070 B1 Other Consultees determined by LPA Agent/Consultant Wright Manley 8320 B1 Other Consultees determined by LPA Agent/Consultant Wright Manley 7735 B1 Other Consultees determined by LPA Developer Atmore Developments Ltd 8007 B1 Other Consultees determined by LPA Developer BG Property 7734 B1 Other Consultees determined by LPA Developer Bryn Property Co Ltd 221 B1 Other Consultees determined by LPA Developer City Residential 7736 B1 Other Consultees determined by LPA Developer Eardley Property Co. Ltd 7727 B1 Other Consultees determined by LPA Developer Hawk Developments 398 B1 Other Consultees determined by LPA Developer Mark Dafydd Developments Ltd 799 B1 Other Consultees determined by LPA Developer Morbaine Ltd 775 B1 Other Consultees determined by LPA Developer National Trust 7730 B1 Other Consultees determined by LPA Developer Nunndale Ltd 7732 B1 Other Consultees determined by LPA Developer Parkhill Estates Ltd 8363 B1 Other Consultees determined by LPA Developer Pro active 7682 B1 Other Consultees determined by LPA Developer Ridgefield Developments 8411 B1 Other Consultees determined by LPA Developer Taylor Wimpey Strategic Land 11 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 734 B1 Other Consultees determined by LPA Developer Tudor Griffiths 708 B1 Other Consultees determined by LPA Developer United COOP Property Group 8314 B1 Other Consultees determined by LPA Developer WCE Properties Ltd 8367 B1 Other Consultees determined by LPA Developer Whitley Group 462 B1 Other Consultees determined by LPA House Builder K Roberts 7661 B1 Other Consultees determined by LPA House Builder Bobby Williams 613 B1 Other Consultees determined by LPA House Builder Anwyl Construction Co Ltd 7573 B1 Other Consultees determined by LPA House Builder Barrat Homes Manchester Office 6494 B1 Other Consultees determined by LPA House Builder Barratt Homes 102 B1 Other Consultees determined by LPA House Builder Barratt Homes Planning Manager 184 B1 Other Consultees determined by LPA House Builder Barratt Homes South Wales Office 163 B1 Other Consultees determined by LPA House Builder Bell Developments 8358 B1 Other Consultees determined by LPA House Builder Bloor Homes 8372 B1 Other Consultees determined by LPA House Builder Bloor Homes 7737 B1 Other Consultees determined by LPA House Builder Bloor Homes Ltd 228 B1 Other Consultees determined by LPA House Builder Castlemead Group Ltd 8361 B1 Other Consultees determined by LPA House Builder David Wilson Homes 6142 B1 Other Consultees determined by LPA House Builder Edwards Homes Ltd 8373 B1 Other Consultees determined by LPA House Builder Elan Homes Ltd 7098 B1 Other Consultees determined by LPA House Builder Emerton Homes Ltd 677 B1 Other Consultees determined by LPA House Builder Fairclough Homes 7733 B1 Other Consultees determined by LPA House Builder George Wimpey Manchester Ltd 392 B1 Other Consultees determined by LPA House Builder Gordon Mytton Developments 8449 B1 Other Consultees determined by LPA House Builder Gower Homes 7728 B1 Other Consultees determined by LPA House Builder Harron Homes 523 B1 Other Consultees determined by LPA House Builder Jones-Roberts Brothers 7771 B1 Other Consultees determined by LPA House Builder Leason Homes Ltd 8403 B1 Other Consultees determined by LPA House Builder Lingfield Homes & Property Development Ltd 389 B1 Other Consultees determined by LPA House Builder Llay Hall Investments 8370 B1 Other Consultees determined by LPA House Builder Lovell 8368 B1 Other Consultees determined by LPA House Builder Macbryde Homes Ltd 12 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 793 B1 Other Consultees determined by LPA House Builder Miller Homes 7667 B1 Other Consultees determined by LPA House Builder Miller Homes 704 B1 Other Consultees determined by LPA House Builder Morris Developments (North) Ltd 8371 B1 Other Consultees determined by LPA House Builder Muller Property Holding 7731 B1 Other Consultees determined by LPA House Builder Oak Homes Ltd 8375 B1 Other Consultees determined by LPA House Builder Persimmon Homes 7088 B1 Other Consultees determined by LPA House Builder Persimmon Homes North West 204 B1 Other Consultees determined by LPA House Builder Pochin Developments Limited 8389 B1 Other Consultees determined by LPA House Builder Redrow 8390 B1 Other Consultees determined by LPA House Builder Redrow 8404 B1 Other Consultees determined by LPA House Builder Redrow 7048 B1 Other Consultees determined by LPA House Builder Redrow Homes North West 8366 B1 Other Consultees determined by LPA House Builder Taylor Wimpey 8376 B1 Other Consultees determined by LPA House Builder Wain Homes 7616 B1 Other Consultees determined by LPA House Builder Watkin Jones Homes 605 B1 Other Consultees determined by LPA Housing Association Clwyd Alyn housing Association 600 B1 Other Consultees determined by LPA Housing Association Cymdeithas Tai Clwyd 601 B1 Other Consultees determined by LPA Housing Association Cymdeithas Tai Clwyd 7671 B1 Other Consultees determined by LPA Housing Association Cymdeithas Tai Clwyd 7674 B1 Other Consultees determined by LPA Housing Association First Choice Housing 147 B1 Other Consultees determined by LPA Housing Association First Choice Housing Association 730 B1 Other Consultees determined by LPA Housing Association Habinteg 7670 B1 Other Consultees determined by LPA Housing Association North Wales Housing Association 7659 B1 Other Consultees determined by LPA Housing Association Pennaf 610 B1 Other Consultees determined by LPA Housing Association Pennaf Housing Group 7657 B1 Other Consultees determined by LPA Housing Association Property Purchase Assessor, Cymdeithas Tai Clwyd 142 B1 Other Consultees determined by LPA Housing Association Wales & West Housing Association Ltd 143 B1 Other Consultees determined by LPA Housing Association Wales & West Housing Association Ltd 7665 B1 Other Consultees determined by LPA Housing Association Wales & West Housing Association Ltd 7082 B1 Other Consultees determined by LPA Housing Association WG & Pennaf

13 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7664 B1 Other Consultees determined by LPA Internal WCBC Building Control Manager WCBC 8425 B1 Other Consultees determined by LPA Internal WCBC Conservation Officer 8420 B1 Other Consultees determined by LPA Internal WCBC Development Surveyor WCBC 7451 B1 Other Consultees determined by LPA Internal WCBC Ecologist WCBC 7660 B1 Other Consultees determined by LPA Internal WCBC Economic Development Manager WCBC 227 B1 Other Consultees determined by LPA Internal WCBC Gypsy & Traveller Multi Agency Forum WCBC 71 B1 Other Consultees determined by LPA Internal WCBC Head of Assets and Economic Development WCBC 8430 B1 Other Consultees determined by LPA Internal WCBC Integrated Services Co-ordinator for Families First 67 B1 Other Consultees determined by LPA Internal WCBC Interim Strategic Housing Manager WCBC 8295 B1 Other Consultees determined by LPA Internal WCBC Investment and Business Development Manager WCBC 8296 B1 Other Consultees determined by LPA Internal WCBC Network and Safety Engineer WCBC 7711 B1 Other Consultees determined by LPA Internal WCBC Parks/Countryside and Rights of Way Manager 8423 B1 Other Consultees determined by LPA internal WCBC Planning Officer 8424 B1 Other Consultees determined by LPA Internal WCBC Planning Officer 1918 B1 Other Consultees determined by LPA Internal WCBC Play Developer Co-ordinator WCBC 8426 B1 Other Consultees determined by LPA Internal WCBC Senior Development Control Engineer 8422 B1 Other Consultees determined by LPA Internal WCBC Senior Engineer 8421 B1 Other Consultees determined by LPA Internal WCBC Senior Legal Officer WBC 8290 B1 Other Consultees determined by LPA Internal WCBC Senior School Improvement Officer WCBC 7042 B1 Other Consultees determined by LPA Internal WCBC Strategic Assets Manager WCBC 7526 B1 Other Consultees determined by LPA Internal WCBC Tree officer - Planning WCBC 247 B1 Other Consultees determined by LPA Local Councillor (WCBC) Arfon Jones 256 B1 Other Consultees determined by LPA Local Councillor (WCBC) Andy Williams 257 B1 Other Consultees determined by LPA Local Councillor (WCBC) Brian Cameron 263 B1 Other Consultees determined by LPA Local Councillor (WCBC) G W Griffiths 271 B1 Other Consultees determined by LPA Local Councillor (WCBC) D J Griffiths 273 B1 Other Consultees determined by LPA Local Councillor (WCBC) Bernie McCann 274 B1 Other Consultees determined by LPA Local Councillor (WCBC) Colin Powell 275 B1 Other Consultees determined by LPA Local Councillor (WCBC) Michael Williams 14 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 280 B1 Other Consultees determined by LPA Local Councillor (WCBC) Paul Rogers 292 B1 Other Consultees determined by LPA Local Councillor (WCBC) Krista Childs 293 B1 Other Consultees determined by LPA Local Councillor (WCBC) David Kelly 295 B1 Other Consultees determined by LPA Local Councillor (WCBC) Barbara Roxburgh 300 B1 Other Consultees determined by LPA Local Councillor (WCBC) Neil Rogers 302 B1 Other Consultees determined by LPA Local Councillor (WCBC) T Alan Edwards 344 B1 Other Consultees determined by LPA Local Councillor (WCBC) Terry Boland 350 B1 Other Consultees determined by LPA Local Councillor (WCBC) Carole O'Toole 355 B1 Other Consultees determined by LPA Local Councillor (WCBC) J A Kelly, KSG 356 B1 Other Consultees determined by LPA Local Councillor (WCBC) Geoff Lowe 359 B1 Other Consultees determined by LPA Local Councillor (WCBC) William Baldwin 361 B1 Other Consultees determined by LPA Local Councillor (WCBC) Andrew Bailey 367 B1 Other Consultees determined by LPA Local Councillor (WCBC) M J Edwards 369 B1 Other Consultees determined by LPA Local Councillor (WCBC) Anne Evans 420 B1 Other Consultees determined by LPA Local Councillor (WCBC) David A Bithell 423 B1 Other Consultees determined by LPA Local Councillor (WCBC) Dana Davies 437 B1 Other Consultees determined by LPA Local Councillor (WCBC) Phil Wynn 438 B1 Other Consultees determined by LPA Local Councillor (WCBC) Graham Rogers 441 B1 Other Consultees determined by LPA Local Councillor (WCBC) R J Dutton, OBE 444 B1 Other Consultees determined by LPA Local Councillor (WCBC) R Alun Jenkins 458 B1 Other Consultees determined by LPA Local Councillor (WCBC) A. Keith Gregory 480 B1 Other Consultees determined by LPA Local Councillor (WCBC) R D Prince 488 B1 Other Consultees determined by LPA Local Councillor (WCBC) M G Morris 504 B1 Other Consultees determined by LPA Local Councillor (WCBC) John C Phillips 509 B1 Other Consultees determined by LPA Local Councillor (WCBC) Paul H Pemberton 513 B1 Other Consultees determined by LPA Local Councillor (WCBC) Kevin Hughes 514 B1 Other Consultees determined by LPA Local Councillor (WCBC) J M Lowe 518 B1 Other Consultees determined by LPA Local Councillor (WCBC) Mark Owens 536 B1 Other Consultees determined by LPA Local Councillor (WCBC) Derek Wright 539 B1 Other Consultees determined by LPA Local Councillor (WCBC) Paul Blackwell 541 B1 Other Consultees determined by LPA Local Councillor (WCBC) David Taylor 15 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 548 B1 Other Consultees determined by LPA Local Councillor (WCBC) Mark Pritchard 562 B1 Other Consultees determined by LPA Local Councillor (WCBC) Terry Evans 563 B1 Other Consultees determined by LPA Local Councillor (WCBC) I Roberts 597 B1 Other Consultees determined by LPA Local Councillor (WCBC) M C King, OBE 622 B1 Other Consultees determined by LPA Local Councillor (WCBC) J M B Roberts 632 B1 Other Consultees determined by LPA Local Councillor (WCBC) P Jeffares 748 B1 Other Consultees determined by LPA Local Councillor (WCBC) Lloyd Kenyon 769 B1 Other Consultees determined by LPA Local Councillor (WCBC) J R Skelland 1315 B1 Other Consultees determined by LPA Local Councillor (WCBC) David I Bithell MBE 7104 B1 Other Consultees determined by LPA Local Councillor (WCBC) Hugh Jones 7590 B1 Other Consultees determined by LPA Local Councillor (WCBC) John Pritchard 7591 B1 Other Consultees determined by LPA Local Councillor (WCBC) Steve Wilson 7574 B1 Other Consultees determined by LPA Local Partnership Forum Wrexham Local Access Forum 7630 B1 Other Consultees determined by LPA Wrexham Local Service Board Wrexham Local Service Board 6454 B2 Specific Consultation Bodies Adjoining Community Council Corwen Community Council 6455 B2 Specific Consultation Bodies Adjoining Community Council Cynwyd Community Council 6452 B2 Specific Consultation Bodies Adjoining Community Council Hope Community Council 6457 B2 Specific Consultation Bodies Adjoining Community Council Llandegla Community Council 6459 B2 Specific Consultation Bodies Adjoining Community Council Llandrillo Community Council 6453 B2 Specific Consultation Bodies Adjoining Community Council Llanfyllin Community Council 7134 B2 Specific Consultation Bodies Adjoining Community Council Llanfynydd Community Council 6458 B2 Specific Consultation Bodies Adjoining Community Council Llangollen Community Council 6456 B2 Specific Consultation Bodies Adjoining Community Council Llantysilio Community Council 3302 B2 Specific Consultation Bodies Adjoining Community Council Pen-y-ffordd Community Council 6540 B2 Specific Consultation Bodies Adjoining Local Authority Cheshire West and Chester Council 592 B2 Specific Consultation Bodies Adjoining Local Authority Denbighshire County Council 197 B2 Specific Consultation Bodies Adjoining Local Authority Flintshire County Council 7306 B2 Specific Consultation Bodies Adjoining Local Authority Flintshire County Council - Planning Policy 225 B2 Specific Consultation Bodies Adjoining Local Authority Powys County Council 7601 B2 Specific Consultation Bodies Adjoining Local Authority Shropshire Council

16 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7523 B2 Specific Consultation Bodies Adjoining Local Health Board Personal Assistant: Countess of Chester NHS Foundation Trust 172 B2 Specific Consultation Bodies Community Council (WCB) Abenbury Community Council 6541 B2 Specific Consultation Bodies Community Council (WCB) Acton Community Council 397 B2 Specific Consultation Bodies Community Council (WCB) Bangor Isycoed Community Council 764 B2 Specific Consultation Bodies Community Council (WCB) Bronington Community Council 250 B2 Specific Consultation Bodies Community Council (WCB) Broughton Community Council 6510 B2 Specific Consultation Bodies Community Council (WCB) Brymbo Community Council 483 B2 Specific Consultation Bodies Community Council (WCB) Caia Park Community Council 527 B2 Specific Consultation Bodies Community Council (WCB) Cefn Community Council 625 B2 Specific Consultation Bodies Community Council (WCB) Ceiriog Ucha Community Council 558 B2 Specific Consultation Bodies Community Council (WCB) Chirk Town & Community Council 265 B2 Specific Consultation Bodies Community Council (WCB) Coedpoeth Community Council 33 B2 Specific Consultation Bodies Community Council (WCB) Erbistock Community Council 547 B2 Specific Consultation Bodies Community Council (WCB) Esclusham Community Council 619 B2 Specific Consultation Bodies Community Council (WCB) Glyntraian Community Council 357 B2 Specific Consultation Bodies Community Council (WCB) Gresford Community Council 436 B2 Specific Consultation Bodies Community Council (WCB) Gwersyllt Community Council 747 B2 Specific Consultation Bodies Community Council (WCB) Hanmer Community Council 470 B2 Specific Consultation Bodies Community Council (WCB) Holt Community Council 248 B2 Specific Consultation Bodies Community Council (WCB) Isycoed Community Council 627 B2 Specific Consultation Bodies Community Council (WCB) Llangollen Rural Community Council 6525 B2 Specific Consultation Bodies Community Council (WCB) Llansantfraid/Glyn Ceiriog Community Council 345 B2 Specific Consultation Bodies Community Council (WCB) Llay Community Council 410 B2 Specific Consultation Bodies Community Council (WCB) Maelor South Community Council 305 B2 Specific Consultation Bodies Community Council (WCB) Marchwiel Community Council 291 B2 Specific Consultation Bodies Community Council (WCB) Minera Community Council 463 B2 Specific Consultation Bodies Community Council (WCB) Offa Community Council 403 B2 Specific Consultation Bodies Community Council (WCB) Overton Community Council 502 B2 Specific Consultation Bodies Community Council (WCB) Penycae Community Council 510 B2 Specific Consultation Bodies Community Council (WCB) Rhos Community Council

17 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 477 B2 Specific Consultation Bodies Community Council (WCB) Rhosddu Community Council 354 B2 Specific Consultation Bodies Community Council (WCB) Rossett Community Council 507 B2 Specific Consultation Bodies Community Council (WCB) Ruabon Community Council 347 B2 Specific Consultation Bodies Community Council (WCB) Sesswick Community Council 767 B2 Specific Consultation Bodies Community Council (WCB) Willington/Worthenbury Community Council 179 B2 Specific Consultation Bodies Electricity Supplier Scottish Power Energy Networks - Environmental Planning 551 B2 Specific Consultation Bodies Electricity Supplier Scottish Power Estates Department 8311 B2 Specific Consultation Bodies Electricity Supplier SP Energy Networks 8436 B2 Specific Consultation Bodies Electricity Supplier SP Networks 7602 B2 Specific Consultation Bodies Electronics Comm Code Airwave Solutions 706 B2 Specific Consultation Bodies Electronics Comm Code Hutchison 3G UK Ltd 8448 B2 Specific Consultation Bodies Electronics Comm Code Mobile Operators Association 219 B2 Specific Consultation Bodies Electronics Comm Code Mono Consultants Ltd on behalf of Mobile Operators Association 690 B2 Specific Consultation Bodies Electronics Comm Code Newnet 694 B2 Specific Consultation Bodies Electronics Comm Code NTL National Networks Limited 705 B2 Specific Consultation Bodies Electronics Comm Code O2 Plc 93 B2 Specific Consultation Bodies Electronics Comm Code Orange Limited 6959 B2 Specific Consultation Bodies Electronics Comm Code Schneider Electric 80 B2 Specific Consultation Bodies Electronics Comm Code T-Mobile Ltd 802 B2 Specific Consultation Bodies Electronics Comm Code UK Broadband 692 B2 Specific Consultation Bodies Electronics Comm Code Vodaphone Ltd 658 B2 Specific Consultation Bodies Gas Supplier British Gas plc 132 B2 Specific Consultation Bodies Gas Supplier Wales and West Utilities Ltd 7629 B2 Specific Consultation Bodies Local Health Board Betsi Cadwaladr University Halth Board (BCUHB) 8450 B2 Specific Consultation Bodies Local Health Board Betsi Cadwaladr University Halth Board (BCUHB) 7658 B2 Specific Consultation Bodies Local Health Board Betsi Cadwaladr University Health Board (BCUHB) 8434 B2 Specific Consultation Bodies Local Health Board Betsi Cadwaladr University Health Board (BCUHB)

18 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7626 B2 Specific Consultation Bodies Local Health Board Chief Executive, Betsi Cadwaladr University Health Board (BCUHB) 484 B2 Specific Consultation Bodies Local Health Board Clwyd Community Health Council 7633 B2 Specific Consultation Bodies Local Health Board National Public Health Service 187 B2 Specific Consultation Bodies Local Health Board National Public Health Service Wales - Flintshire Office 133 B2 Specific Consultation Bodies Local Health Board NHS Wales Shared Services Partnership - Facilities Services 8292 B2 Specific Consultation Bodies Local Health Board Principal Health Impact Assessment Officer - Health Impact Assessment Unit 7589 B2 Specific Consultation Bodies Local Health Board Public Health Wales 8294 B2 Specific Consultation Bodies Local Health Board Public Health Wales 611 B2 Specific Consultation Bodies Local Health Board Welsh Ambulance Services NHS Trust 445 B2 Specific Consultation Bodies Local Health Board Wrexham Maelor Hospital 8306 B2 Specific Consultation Bodies National Grid National Grid c/o Amec Environment & Infrastructure UK Limited 7586 B2 Specific Consultation Bodies National Grid National Grid Wales 7491 B2 Specific Consultation Bodies Natural Resources Wales Natural Resources Wales Planning Consultations 7611 B2 Specific Consultation Bodies Sewerage Undertaker Asset Strategy and Planning - Welsh Water 145 B2 Specific Consultation Bodies Sewerage Undertaker Welsh Water / Dwr Cymru 8406 B2 Specific Consultation Bodies Sewerage Undertaker Welsh Water/Dwr Cymru 7612 B2 Specific Consultation Bodies Water Undertaker Dee Valley Water 552 B2 Specific Consultation Bodies Water Undertaker Dee Valley Water plc 8379 B2 Specific Consultation Bodies Water Undertaker Glandwr Cymru, Canal and River Trust 82 B2 Specific Consultation Bodies Water Undertaker Severn Trent Water Strategist - Infrastructure Capacity 104 B2 Specific Consultation Bodies Welsh Government Welsh Government 105 B2 Specific Consultation Bodies Welsh Government Welsh Government 7542 B2 Specific Consultation Bodies Welsh Government Welsh Government 7636 B2 Specific Consultation Bodies Welsh Government Welsh Government 8384 B2 Specific Consultation Bodies Welsh Government Welsh Government 8442 B2 Specific Consultation Bodies Welsh Government Welsh Government

19 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 6640 B4 General Consultation Bodies Business Body Chirk and Ceiriog Valley Partnership 7606 B4 General Consultation Bodies Business Body Department for Business, Innovation & Skills 7604 B4 General Consultation Bodies Business Body West Cheshire and North Wales Chamber of Commerce 7605 B4 General Consultation Bodies Business Body Wrexham Industrial Estate 7646 B4 General Consultation Bodies Business Body Wrexham Town Centre Forum 440 B4 General Consultation Bodies Disability Body Advance Brighter Futures Wrexham 7608 B4 General Consultation Bodies Disability Body Deaf Access Cymru 7655 B4 General Consultation Bodies Disability Body Deaf Forum 7600 B4 General Consultation Bodies Disability Body Hafal 7653 B4 General Consultation Bodies Disability Body Keyring 123 B4 General Consultation Bodies Disability Body Mind Cymru 468 B4 General Consultation Bodies Disability Body Multiple Sclerosis Society 7645 B4 General Consultation Bodies Disability Body Neurological Alliance 7656 B4 General Consultation Bodies Disability Body Visual Impairment Forum 139 B4 General Consultation Bodies Disability Body Wales Council for the Blind 144 B4 General Consultation Bodies Disability Body Wales Council for The Deaf 482 B4 General Consultation Bodies Disability Body Wrexham Social Club for the Blind 7643 B4 General Consultation Bodies Racial/Ethnic Body African Community Centre 7592 B4 General Consultation Bodies Racial/Ethnic Body Black Association of Women Step Out (BAWSO) 211 B4 General Consultation Bodies Racial/Ethnic Body Ethnic Minority Foundation 644 B4 General Consultation Bodies Racial/Ethnic Body North Wales Race Equality Network 7642 B4 General Consultation Bodies Racial/Ethnic Body Race Council Cymru 7595 B4 General Consultation Bodies Racial/Ethnic Body Welsh Refugee Council 6440 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and Community Law Partnership Travellers) 7647 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and G&T Officer Social Inclusion Team, Welsh Travellers) Government 6438 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and Inclusion Unit Communities Directorate Travellers) 6441 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and Phillip Brown Associates Travellers) 20 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 6436 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and The Gypsy Council for Health, Education and Travellers) Welfare 6439 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and The National Federation of Gypsy Liaison Travellers) Groups 6437 B4 General Consultation Bodies Racial/Ethnic Body (Gypsies and Wrexham Traveller Health Project Steering Travellers) Group 128 B4 General Consultation Bodies Religious Body Church in Wales 6641 B4 General Consultation Bodies Religious Body Church In Wales 29 B4 General Consultation Bodies Religious Body Diocese of Wrexham 7651 B4 General Consultation Bodies Religious Body Islamic Cultural Centre 7599 B4 General Consultation Bodies Religious Body Methodist Church 651 B4 General Consultation Bodies Religious Body Orthodox Church in Wales 253 B4 General Consultation Bodies Religious Body Salvation Army 243 B4 General Consultation Bodies Religious Body St Mary’s Cathedral 7652 B4 General Consultation Bodies Religious Body Tangnefedd 258 B4 General Consultation Bodies Religious Body Wrexham Cytun 203 B4 General Consultation Bodies Religious Body Wrexham North Congregation of Jehovah's Witnesses 7644 B4 General Consultation Bodies Religious Body Wrexham Street Pastors 6444 B4 General Consultation Bodies Voluntary Body Access Group 236 B4 General Consultation Bodies Voluntary Body Age Concern Wrexham & South Clwyd 124 B4 General Consultation Bodies Voluntary Body Age Cymru 237 B4 General Consultation Bodies Voluntary Body AVOW 8309 B4 General Consultation Bodies Voluntary Body AVOW 647 B4 General Consultation Bodies Voluntary Body CAIS NE Wales Regional Office 8305 B4 General Consultation Bodies Voluntary Body Community Liaison Officer, Stonewall Cymru 120 B4 General Consultation Bodies Voluntary Body Council for Wales Voluntary Youth Services 7654 B4 General Consultation Bodies Voluntary Body North Wales Public Sector Equality Network 561 B4 General Consultation Bodies Voluntary Body Over 50's Forum 7598 B4 General Consultation Bodies Voluntary Body Over 50's Forum 7648 B4 General Consultation Bodies Voluntary Body Wrexham Diversity Forum 7596 B4 General Consultation Bodies Voluntary Body Wrexham Women's Aid

21 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 4 B4 General Consultation Bodies Voluntary Body Wrexham Youth Service 776 B4 General Consultation Bodies Welsh Body Cymdeithas yr Iaith Gymraeg - Welsh Language Society 652 B4 General Consultation Bodies Welsh Body Cymuned 239 B4 General Consultation Bodies Welsh Body Menter Iaith Maelor 680 B5 Other LDP Consultees British Aggregates Association British Aggregates Association 136 B5 Other LDP Consultees British Geological Survey British Geological Survey 207 B5 Other LDP Consultees British Waterways British Waterways North Wales and Borders 6997 B5 Other LDP Consultees British Waterways Inland Waterways Association 688 B5 Other LDP Consultees Centre for Ecology and Hydrology Centre for Ecology and Hydrology 800 B5 Other LDP Consultees Civil Aviation Authority Civil Aviation Authority 8357 B5 Other LDP Consultees Civil Aviation Authority Magellan Aerospace (UK) Ltd 682 B5 Other LDP Consultees Coal Authority Coal Authority 1932 B5 Other LDP Consultees Coal Authority Confederation of UK Coal Producers 7572 B5 Other LDP Consultees Country Land and Business Association CLA Wales 400 B5 Other LDP Consultees Country Landowners Association Country Landowners Association 790 B5 Other LDP Consultees Crown Estate Office Crown Estate Office 110 B5 Other LDP Consultees Design Commission for Wales Design Commission for Wales 148 B5 Other LDP Consultees Disability Wales Disability Wales / Anabledd Cymru 7587 B5 Other LDP Consultees Disabled Persons Transport Advisory Disabled Persons Transport Advisory Committee Committee Secretariat 3733 B5 Other LDP Consultees Electricity Supplier Npower Renewables 716 B5 Other LDP Consultees Environment Services Agency Welsh Environmental Services Association (Waste) 222 B5 Other LDP Consultees Environmental Group Allerton Trust 532 B5 Other LDP Consultees Environmental Group Campaign for the Protection of Rural Wales 118 B5 Other LDP Consultees Environmental Group Civic Trust for Wales 192 B5 Other LDP Consultees Environmental Group Clwyd Badger Group 774 B5 Other LDP Consultees Environmental Group Clwyd Powys Archaeological Trust 8001 B5 Other LDP Consultees Environmental Group Coed Cadw/Woodland Trust 430 B5 Other LDP Consultees Environmental Group CPRW - Wrexham Branch 650 B5 Other LDP Consultees Environmental Group Farming & Wildlife Advisory Group 22 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 6504 B5 Other LDP Consultees Environmental Group Friends of the Earth Cymru 199 B5 Other LDP Consultees Environmental Group Friends of the Earth Cymru (North Wales) 493 B5 Other LDP Consultees Environmental Group Groundwork Wrexham 182 B5 Other LDP Consultees Environmental Group North East Wales Wildlife 196 B5 Other LDP Consultees Environmental Group North Wales Wildlife Trust (local office) 7620 B5 Other LDP Consultees Environmental Group Northern Marches Cymru 7532 B5 Other LDP Consultees Environmental Group Royal Society for the Protection of Birds 8151 B5 Other LDP Consultees Environmental Group The National Trust 683 B5 Other LDP Consultees Environmental Group UK Rainwater Harvesting Association 2 B5 Other LDP Consultees Environmental Group Welsh Historic Gardens Trust 95 B5 Other LDP Consultees Equality and Human Rights Commission Equality and Human Rights Commission 778 B5 Other LDP Consultees Farmers Union Wales Farmers Union of Wales 7607 B5 Other LDP Consultees Federation of Small Businesses Federation of Small Businesses Wales 125 B5 Other LDP Consultees Fields In Trust Fields In Trust 7637 B5 Other LDP Consultees Fire & Rescue Service Ambulance Service 7627 B5 Other LDP Consultees Fire & Rescue Service Fire Service 7635 B5 Other LDP Consultees Fire & Rescue Service Fire Service 37 B5 Other LDP Consultees Fire & Rescue Service North Wales Fire & Rescue Service Head Office 7584 B5 Other LDP Consultees Fire & Rescue Service North Wales Fire and Rescue Service - Wrexham Office 8392 B5 Other LDP Consultees Fire & Rescue Service NW Ambulance Service 7585 B5 Other LDP Consultees Fire & Rescue Service Welsh Ambulance Service North Region 596 B5 Other LDP Consultees Forestry Commission Forestry Commission - North Wales Office 2093 B5 Other LDP Consultees Forestry Commission Forestry Commission - Wales 114 B5 Other LDP Consultees Freight Transport Association Freight Transport Association 7583 B5 Other LDP Consultees Gypsy Council Gypsy Council 703 B5 Other LDP Consultees Health and Safety Executive Health and Safety Executive North West and Wales Office 8408 B5 Other LDP Consultees Home Builders Federation Home Builders Federation Ltd 111 B5 Other LDP Consultees Local CBI CBI Wales 2263 B5 Other LDP Consultees Local Community/Amenity Group 1st Cefn Mawr Scout Group 23 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 432 B5 Other LDP Consultees Local Community/Amenity Group Abbeyfield Wrexham Society 537 B5 Other LDP Consultees Local Community/Amenity Group Acrefair Community Association 1830 B5 Other LDP Consultees Local Community/Amenity Group Acton and Maesydre Residents and Tenants Association 8110 B5 Other LDP Consultees Local Community/Amenity Group Afon Residents Group 8293 B5 Other LDP Consultees Local Community/Amenity Group AVOW and Healthy Eating and Being More Active (HEBMA) 6639 B5 Other LDP Consultees Local Community/Amenity Group Black Park Chapel Trust 7100 B5 Other LDP Consultees Local Community/Amenity Group Branch Contact, Chester and South Clwyd Camra 8166 B5 Other LDP Consultees Local Community/Amenity Group British Horse Society 134 B5 Other LDP Consultees Local Community/Amenity Group British Trust for Conservation Volunteers 3 B5 Other LDP Consultees Local Community/Amenity Group Bronington Village Hall Committee 6656 B5 Other LDP Consultees Local Community/Amenity Group Brymbo Community Association 7529 B5 Other LDP Consultees Local Community/Amenity Group Brymbo Heritage Group 3494 B5 Other LDP Consultees Local Community/Amenity Group Brymbo Residents Action Group 447 B5 Other LDP Consultees Local Community/Amenity Group Bryn Offa Tenant & Resident Association 485 B5 Other LDP Consultees Local Community/Amenity Group Caia Park Communities First Ltd 466 B5 Other LDP Consultees Local Community/Amenity Group Caia Park Partnership 79 B5 Other LDP Consultees Local Community/Amenity Group Campaign for Real Ale Ltd 7580 B5 Other LDP Consultees Local Community/Amenity Group Chester Shrewsbury Rail Partnership 517 B5 Other LDP Consultees Local Community/Amenity Group Chester-Shrewsbury Rail Users Association 616 B5 Other LDP Consultees Local Community/Amenity Group Clwyd Bat Group 39 B5 Other LDP Consultees Local Community/Amenity Group Coedpoeth Tenant Association 544 B5 Other LDP Consultees Local Community/Amenity Group Communities First 578 B5 Other LDP Consultees Local Community/Amenity Group Cymdeithas Tai Hafan 36 B5 Other LDP Consultees Local Community/Amenity Group Dee Valley Community Partnership 173 B5 Other LDP Consultees Local Community/Amenity Group Envirowatch UK 5 B5 Other LDP Consultees Local Community/Amenity Group Erlas Horticultural Project 7649 B5 Other LDP Consultees Local Community/Amenity Group Friends of Caia Park, Pandy, Acton and Bellevue 1823 B5 Other LDP Consultees Local Community/Amenity Group Garden Village Residents Association

24 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 7314 B5 Other LDP Consultees Local Community/Amenity Group Glan Aber Court Tenants Association 7364 B5 Other LDP Consultees Local Community/Amenity Group Glyn Valley Tramway Trust 6629 B5 Other LDP Consultees Local Community/Amenity Group Glyn Valley Tramway Trust 1614 B5 Other LDP Consultees Local Community/Amenity Group Gwynfryn Residents Association 7075 B5 Other LDP Consultees Local Community/Amenity Group Healthy Eating and Being More Active Group 7593 B5 Other LDP Consultees Local Community/Amenity Group Hightown Communities First 8112 B5 Other LDP Consultees Local Community/Amenity Group Johnstown Community Tenants & Residents Assoc 8113 B5 Other LDP Consultees Local Community/Amenity Group Kingsley Tenants & Residents Association 7550 B5 Other LDP Consultees Local Community/Amenity Group Llangollen Civic Society 639 B5 Other LDP Consultees Local Community/Amenity Group Llangollen Railway Trust Ltd 1362 B5 Other LDP Consultees Local Community/Amenity Group Llanna Panna Residents Association 864 B5 Other LDP Consultees Local Community/Amenity Group Llay Community Residents Association 7008 B5 Other LDP Consultees Local Community/Amenity Group Local Access Forum 8437 B5 Other LDP Consultees Local Community/Amenity Group Local Community Amenity Group 8114 B5 Other LDP Consultees Local Community/Amenity Group Maesydre Tenants & Residents Association 418 B5 Other LDP Consultees Local Community/Amenity Group Marchwiel Residents Group 30 B5 Other LDP Consultees Local Community/Amenity Group Masonic Hall Company Wrexham 490 B5 Other LDP Consultees Local Community/Amenity Group Millennium Eco Centre 452 B5 Other LDP Consultees Local Community/Amenity Group NACRO The Crime Reduction Charity 8115 B5 Other LDP Consultees Local Community/Amenity Group Napier Square & Gatefield Residents Association 6910 B5 Other LDP Consultees Local Community/Amenity Group North East Wales Bridleways and Wrexham Local Access Forum 7625 B5 Other LDP Consultees Local Community/Amenity Group North Wales Local Medical Committee 8283 B5 Other LDP Consultees Local Community/Amenity Group North Wales Working Party on Aggregates 3253 B5 Other LDP Consultees Local Community/Amenity Group Offa's Dyke Association 8451 B5 Other LDP Consultees Local Community/Amenity Group Overton Local Access Forum 8116 B5 Other LDP Consultees Local Community/Amenity Group Pant Tenants & Residents Association 1589 B5 Other LDP Consultees Local Community/Amenity Group Pentre Gwyn, Tan y Coed & Coed y Bryn Community Association

25 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 8118 B5 Other LDP Consultees Local Community/Amenity Group Penycae Tenants & Residents Association 901 B5 Other LDP Consultees Local Community/Amenity Group Plas Bennion Residents Association 7081 B5 Other LDP Consultees Local Community/Amenity Group Plas Kynaston Canal Group 7084 B5 Other LDP Consultees Local Community/Amenity Group Plas Kynaston Canal Group 729 B5 Other LDP Consultees Local Community/Amenity Group Ramblers' Association (Oswestry) 307 B5 Other LDP Consultees Local Community/Amenity Group RECAP 321 B5 Other LDP Consultees Local Community/Amenity Group Recap & Rossett Community Council 6551 B5 Other LDP Consultees Local Community/Amenity Group Red Passion 6535 B5 Other LDP Consultees Local Community/Amenity Group Red Passion Online Community 1162 B5 Other LDP Consultees Local Community/Amenity Group Reserve Manager Marchwiel Marsh 1923 B5 Other LDP Consultees Local Community/Amenity Group Residents of Cefn Road, Bwlchgwyn 7325 B5 Other LDP Consultees Local Community/Amenity Group Residents of Hall View 238 B5 Other LDP Consultees Local Community/Amenity Group Retired and Senior Volunteer Programme 1867 B5 Other LDP Consultees Local Community/Amenity Group Rhosddu Youth Football Club 8119 B5 Other LDP Consultees Local Community/Amenity Group Rhosnesni Tenants & Residents Association 8120 B5 Other LDP Consultees Local Community/Amenity Group Rhosymedre & Newbridge Tenants & Residents Assoc 40 B5 Other LDP Consultees Local Community/Amenity Group Ruabon Tenant Association 8429 B5 Other LDP Consultees Local Community/Amenity Group Senedd Yr Ifanc 8433 B5 Other LDP Consultees Local Community/Amenity Group Senedd Yr Ifanc 7061 B5 Other LDP Consultees Local Community/Amenity Group Shrewsbury-Chester Rail Users' Association (SCRUA) 8122 B5 Other LDP Consultees Local Community/Amenity Group Smithfield Residents & Tenants Association 8123 B5 Other LDP Consultees Local Community/Amenity Group Spring Lodge Tenants Association 8435 B5 Other LDP Consultees Local Community/Amenity Group Together Creating Communities 7025 B5 Other LDP Consultees Local Community/Amenity Group Top of Cefn Mawr Residents Association 7650 B5 Other LDP Consultees Local Community/Amenity Group Ty Nos - Homeless Centre 8125 B5 Other LDP Consultees Local Community/Amenity Group Walden Crescent Residents Association 198 B5 Other LDP Consultees Local Community/Amenity Group Wats Dyke Way Association 770 B5 Other LDP Consultees Local Community/Amenity Group Woodland Trust Wales 594 B5 Other LDP Consultees Local Community/Amenity Group Wrexham & District Bridleways Association

26 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 376 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Area Civic Society 348 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Birdwatchers 296 B5 Other LDP Consultees Local Community/Amenity Group Wrexham District Scout Council 7028 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Heritage Forum 450 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Night Shelter W.A.T.C.H 475 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Railway Society 6543 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Supporters Trust 297 B5 Other LDP Consultees Local Community/Amenity Group Wrexham Tenants Federation 22 B5 Other LDP Consultees Local Transport Operator Bryn Melyn Ltd 24 B5 Other LDP Consultees Local Transport Operator D Jones & Son 25 B5 Other LDP Consultees Local Transport Operator E. Jones & Sons 19 B5 Other LDP Consultees Local Transport Operator George Edwards & Son 7581 B5 Other LDP Consultees Local Transport Operator GHA Coaches 762 B5 Other LDP Consultees Local Transport Operator Huxley's Coaches 301 B5 Other LDP Consultees Local Transport Operator John's Travel 773 B5 Other LDP Consultees Local Transport Operator Lloyds Coaches 602 B5 Other LDP Consultees Local Transport Operator M & H Coaches 26 B5 Other LDP Consultees Local Transport Operator Pats Coaches Ltd 720 B5 Other LDP Consultees Local Transport Operator Tanat Valley Coaches & Motors 21 B5 Other LDP Consultees Local Transport Operator Townlynx 7089 B5 Other LDP Consultees National Farmers Union for Wales NFU Cymru 7576 B5 Other LDP Consultees One Voice Wales One Voice Wales 116 B5 Other LDP Consultees Planning Aid Wales Planning Aid Wales 43 B5 Other LDP Consultees Police - Crime Prevention Design Community Safety Officer, North Wales Police Advisors 7575 B5 Other LDP Consultees Post Office Property Holdings Post Office Property Holdings 8164 B5 Other LDP Consultees Post Office Property Holdings Post Office Property Holdings 1930 B5 Other LDP Consultees Professional Body Arts Council of Wales 106 B5 Other LDP Consultees Professional Body Audit Commission in Wales 7093 B5 Other LDP Consultees Professional Body British Driving Society North East Wales 137 B5 Other LDP Consultees Professional Body CADW Welsh Historic Monuments

27 Wrexham LDP – Issues and Options Consultation Responses List of Consultees - Issues and Options Consultation 2nd March - 10th April 2015 ID Type Sub-type Name/Organisation 685 B5 Other LDP Consultees Professional Body Chartered Institute of Waste Management 7556 B5 Other LDP Consultees Professional Body CIH Cymru Policy and Public Affairs Manager 115 B5 Other LDP Consultees Professional Body Institute of Civil Engineers Wales Office 202 B5 Other LDP Consultees Professional Body RICS Contact Centre 481 B5 Other LDP Consultees Professional Body RIGS (Geological) 113 B5 Other LDP Consultees Professional Body WLGA 7555 B5 Other LDP Consultees Professional Body WLGA, Housing 714 B5 Other LDP Consultees Quarry Products Association Wales Quarry Products Association Wales 710 B5 Other LDP Consultees Rail Freight Group Rail Freight Group 126 B5 Other LDP Consultees Sports Council for Wales Sports Wales 224 B5 Other LDP Consultees Train Operating Company Arriva Customer Services 117 B5 Other LDP Consultees Train Operating Company Arriva Trains Wales 7613 B5 Other LDP Consultees Train Operating Company BRB (Residuary) Ltd 7579 B5 Other LDP Consultees Train Operating Company Mersey Rail 665 B5 Other LDP Consultees Train Operating Company Network Rail 919 B5 Other LDP Consultees Train Operating Company Spacia (Network Rail) 7578 B5 Other LDP Consultees Train Operating Company Virgin Trains 91 B5 Other LDP Consultees Traveller Law Reform Coalition Traveller Law Reform Coalition 7010 B5 Other LDP Consultees Traveller Law Reform Project Traveller Law Reform Project 121 B5 Other LDP Consultees Wales Council for Voluntary Action Wales Council for Voluntary Action 777 B5 Other LDP Consultees Wales Environmental Link Wales Environmental Link 797 B5 Other LDP Consultees Water Company United Utilities

28 Wrexham LDP – Issues and Options Consultation Responses

2. List of Respondents to Issues and Options Consultation

29 Wrexham LDP – Issues and Options Consultation Responses List of Respondents to Issues and Options Consultation

Consultee Type Sub-type I & O Organisation First Name Surname ID Consultee

8468 B1 Other Consultees Agent/Consultant N Barton Wilmore (on behalf of Barratt Vincent Ryan determined by LPA Developments PLC) 8412 B1 Other Consultees Agent/Consultant Y Berrys Chartered Surveyors & Helen Howie determined by LPA Valuers (on behalf of Toni Jones and Richard Tomlinson) 8452 B1 Other Consultees Agent/Consultant Y Berrys Chartered Surveyors and Helen Howie determined by LPA Valuers (on behalf of R&C Homes Ltd) 6533 B1 Other Consultees Agent/Consultant Y Carter Jonas C Sussums determined by LPA 6531 B1 Other Consultees Agent/Consultant Y Cassidy and Ashton Planning Guy Evans determined by LPA 1939 B1 Other Consultees Agent/Consultant Y David Cartwright Solicitor H.G. Cartwright determined by LPA 7623 B1 Other Consultees Agent/Consultant Y Fitzsimon Planning Dave Fitzsimon determined by LPA 181 B1 Other Consultees Agent/Consultant Y Guy Woodcock & Company Robin A.H. Morris determined by LPA 8458 B1 Other Consultees Agent/Consultant N Guy Woodcock Surveyors (on behalf Barbara Blanchard determined by LPA of Robin Morris) 8315 B1 Other Consultees Agent/Consultant Y Halls Holdings Ltd Shaun Jones determined by LPA 8417 B1 Other Consultees Agent/Consultant Y Heaton Planning (on behalf of Lafarge Liam Toland determined by LPA Tarmac Trading Ltd) 8409 B1 Other Consultees Agent/Consultant Y HOW Planning LLP (on behalf of Rhian Harris determined by LPA Kingmoor Park Properties) 155 B1 Other Consultees Agent/Consultant Y J10 Planning Ltd Justin Paul determined by LPA 8298 B1 Other Consultees Agent/Consultant Y L.S Planning Leslie Smith determined by LPA 169 B1 Other Consultees Agent/Consultant Y McCormick Architecture Ltd Phil McCormick determined by LPA 8453 B1 Other Consultees Agent/Consultant N Mineral Product Association Malcolm Ratcliff determined by LPA 30 Wrexham LDP – Issues and Options Consultation Responses List of Respondents to Issues and Options Consultation Consultee Type Sub-type I & O Organisation First Name Surname ID Consultee

5623 B1 Other Consultees Agent/Consultant Y The Planning Consultancy (on behalf Matthew Gilbert determined by LPA of Redrow Homes) 7734 B1 Other Consultees Developer Y Bryn Property Co Ltd determined by LPA 7732 B1 Other Consultees Developer Y Parkhill Estates Ltd M Ferguson determined by LPA 8411 B1 Other Consultees Developer Y Taylor Wimpey Strategic Land Jessica Bond determined by LPA 7628 B1 Other Consultees Higher Education N Coleg Cambria Steve Jackson determined by LPA Establishment 462 B1 Other Consultees House Builder Y NA K Roberts determined by LPA 8449 B1 Other Consultees House Builder Y Gower Homes Mike Forgrave determined by LPA 304 B1 Other Consultees Individual N NA D M Edwards determined by LPA 3095 B1 Other Consultees Individual N NA Carl Richards determined by LPA 7474 B1 Other Consultees Individual N NA Peter Guy determined by LPA 7475 B1 Other Consultees Individual N NA Bryn Richards determined by LPA 8454 B1 Other Consultees Individual N NA Daniel Guy determined by LPA 8455 B1 Other Consultees Individual N NA Michael Dixon determined by LPA 8456 B1 Other Consultees Individual N NA Maureen Williams determined by LPA 8457 B1 Other Consultees Individual N NA F Massey determined by LPA 8462 B1 Other Consultees Individual N NA Nia Lloyd determined by LPA 8463 B1 Other Consultees Individual N NA Sara Williams determined by LPA

31 Wrexham LDP – Issues and Options Consultation Responses List of Respondents to Issues and Options Consultation Consultee Type Sub-type I & O Organisation First Name Surname ID Consultee

8467 B1 Other Consultees Individual N NA Gill Wilson determined by LPA Butterworth 8469 B1 Other Consultees Individual N NA Wendy Sime determined by LPA 8430 B1 Other Consultees Internal WCBC Y Integrated Services Co-ordinator for Jillian McBreaty- determined by LPA Families First Gilliam 67 B1 Other Consultees Internal WCBC Y Interim Strategic Housing Manager Mike Jenkins determined by LPA WCBC 8295 B1 Other Consultees Internal WCBC Y Investment and Business Peter Scott determined by LPA Development Manager WCBC 1918 B1 Other Consultees Internal WCBC Y Play Developer Co-ordinator WCBC Mike Barclay determined by LPA 8426 B1 Other Consultees Internal WCBC Y Senior Development Control Engineer Peter Douthwaite determined by LPA 247 B1 Other Consultees Local Councillor Y Local Councillor - Gwersyllt West Arfon Jones determined by LPA (WCBC) 257 B1 Other Consultees Local Councillor Y Local Councillor - Whitegate Brian Cameron determined by LPA (WCBC) 292 B1 Other Consultees Local Councillor Y Local Councillor - Coedpoeth Krista Childs determined by LPA (WCBC) 293 B1 Other Consultees Local Councillor Y Local Councillor - Minera David Kelly determined by LPA (WCBC) 302 B1 Other Consultees Local Councillor Y Local Councillor - Broughton T Alan Edwards determined by LPA (WCBC) 438 B1 Other Consultees Local Councillor Y Local Councillor - Hermitage Graham Rogers determined by LPA (WCBC) 504 B1 Other Consultees Local Councillor Y Local Councillor - Penycae John C Phillips determined by LPA (WCBC) 769 B1 Other Consultees Local Councillor Y Local Councillor – Bronington J R Skelland determined by LPA (WCBC) 6540 B2 Specific Adjoining Local Y Cheshire West and Chester Council Catherine Morgetroyd Consultation Bodies Authority 592 B2 Specific Adjoining Local Y Denbighshire County Council Angela Loftus Consultation Bodies Authority

32 Wrexham LDP – Issues and Options Consultation Responses List of Respondents to Issues and Options Consultation Consultee Type Sub-type I & O Organisation First Name Surname ID Consultee

7306 B2 Specific Adjoining Local Y Flintshire County Council - Planning Adrian Walters Consultation Bodies Authority Policy 6541 B2 Specific Community Council Y Acton Community Council Carole Roberts Consultation Bodies (WCB) 483 B2 Specific Community Council Y Caia Park Community Council M G Morris Consultation Bodies (WCB) 265 B2 Specific Community Council Y Coedpoeth Community Council Michael Dixon Consultation Bodies (WCB) 357 B2 Specific Community Council Y Gresford Community Council M Paddock Consultation Bodies (WCB) 436 B2 Specific Community Council Y Gwersyllt Community Council P J Mullen Consultation Bodies (WCB) 305 B2 Specific Community Council Y Marchwiel Community Council V M Jones Consultation Bodies (WCB) 291 B2 Specific Community Council Y Minera Community Council Emma Topham Consultation Bodies (WCB) 463 B2 Specific Community Council Y Offa Community Council Karen Benfield Consultation Bodies (WCB) 403 B2 Specific Community Council Y Overton Community Council Katrina Chalk Consultation Bodies (WCB) 477 B2 Specific Community Council Y Rhosddu Community Council E N Hodges Consultation Bodies (WCB) 507 B2 Specific Community Council Y Ruabon Community Council Mike Blackshaw Consultation Bodies (WCB) 347 B2 Specific Community Council Y Sesswick Community Council Stephen Nott Consultation Bodies (WCB) 219 B2 Specific Electronics Comm Y Mono Consultants Ltd (on behalf of Jacquelyn Fee Consultation Bodies Code Mobile Operators Association) 8450 B2 Specific Local Health Board Y Betsi Cadwaladr University Health Ian Howard Consultation Bodies Board (BCUHB) 145 B2 Specific Sewerage Undertaker Y Welsh Water / Dwr Cymru Dewi Griffiths Consultation Bodies 8379 B2 Specific Water Undertaker Y Glandwr Cymru, Canal and River Alison Truman Consultation Bodies Trust

33 Wrexham LDP – Issues and Options Consultation Responses List of Respondents to Issues and Options Consultation Consultee Type Sub-type I & O Organisation First Name Surname ID Consultee

8442 B2 Specific Welsh Government Y Welsh Government Heledd Cressy Consultation Bodies 652 B4 General Welsh Body Y Cymuned Carrie Harper Consultation Bodies 682 B5 Other LDP Coal Authority Y Coal Authority Rachael Bust Consultees 703 B5 Other LDP Health and Safety Y Health and Safety Executive North NA NA Consultees Executive West and Wales Office 8408 B5 Other LDP Home Builders Y Home Builders Federation Ltd Mark Harris Consultees Federation 8293 B5 Other LDP Local Y AVOW and Healthy Eating and Being Janet Radford Consultees Community/Amenity More Active (HEBMA) Group 639 B5 Other LDP Local Y Llangollen Railway Trust Ltd Steve Jones Consultees Community/Amenity Group 6910 B5 Other LDP Local Y North East Wales Bridleways and Tim Stratton Consultees Community/Amenity Wrexham Local Access Forum Group 8451 B5 Other LDP Local Y Overton Local Access Forum Penelope Coles Consultees Community/Amenity Group 7081 B5 Other LDP Local Y Plas Kynaston Canal Group David Metcalf Consultees Community/Amenity Group 307 B5 Other LDP Local Y RECAP Whiles Consultees Community/Amenity Group 1930 B5 Other LDP Professional Body Y Arts Council of Wales Carys Wynne- Consultees Williams

34 Wrexham LDP – Issues and Options Consultation Responses

3. Officer Responses to Stakeholder Comments

35 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses

Q.2. Comments on Vision

ID Name Organisation Comment Officer Response 67 Mike Jenkins Wrexham County The vision is wide and covers a large Noted. There should be Borough Council - range of areas - doesn't mention reference to housing either in Strategic Housing housing specifically i.e. refer to the vision or objectives. The Services Council Plan strategic theme PL1 - vision will be reworded. 'homes that meet people’s needs and aspirations' - should the vision include working towards this? 247 Arfon Jones WCBC Local Councillor No objection to the proposed Vision Noted. This, however, is not for the LDP, consider that the Vision considered necessary as it is should be extended so as to national policy which the LDP recognise the importance of will have to demonstrate and ensuring that the provision of large will be assessed through the amounts of new development should tests of soundness. go hand in hand with the provision of employment opportunities. 265 Michael Dixon Coedpoeth Community This is an excellent statement and I This support is welcomed. Council support it. 292 Krista Childs WCBC Although I would like to be optimistic All comments and suggestions re this I feel very uncertain and received during the rather disillusioned re this statement, consultation will be considered as I feel that some consultation and will be used to help shape has/is not fully or sensitively the Preferred Strategy. acknowledged and taken into account. 403 Penelope S J Coles Overton Community I think that not enough emphasis has Noted. Vision to be reworded Council been placed on Welsh culture. I as suggested. think that the last sentence in the vision statement should read ". that positively responds to and promotes the quality and distinctiveness of our natural built heritage and welsh culture.

36 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response 436 Peter Mullen Gwersyllt Community Although the Community Council Noted. This, however, is not Council has no objection to the proposed considered necessary as it is Vision for the LDP, it considers that national policy which the LDP the Vision should be extended so as will have to demonstrate and to recognise the importance of will be assessed through the ensuring that the provision of large tests of soundness. amounts of new development should go hand in hand with the provision of employment opportunities. 483 Cllr Marc Jones Caia Park Appears to be meaningless words. Noted. It is not intended for Community Council This LDP will not in itself help the LDP to achieve all of the achieve any of these goals. goals, but to support and help Arguably, it will reduce the quality deliver the goals and policies and distinctiveness of our natural of other plans that are directly and built heritage. It is unclear how related to the future 13,000 homes will make it a place of development of the County safety and inclusiveness, reducing Borough. It is essential that inequality. the LDP recognises these to ensure that all future development takes account of other related plans and proposals. It has not been claimed that providing 13,000 homes will make Wrexham safe and inclusive. New development will however need to ensure that it is designed in a way that creates safe and inclusive places. 592 Angela Loftus Denbighshire County A minor amendment should be made Noted. Vision to be updated. Council to the wording of the LDP vision - include 'County Borough' behind Wrexham to ensure that there is no confusion with a vision for the town itself. The vision should be inclusive and supported by all residents within the administrative area of WCBC.

37 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response 652 Carrie Harper Plaid Cymru This statement really doesn't mean The vision does not indicate anything. Wrecsam is already a that Wrexham is within North place where people can live active, West England, it states that it healthy and independent lives, how is within ‘close proximity’ to the does the LDP contribute to this, or North West of England, of not? Our location is not 'within the which it is recognised that north West of England', it is only in there are close economic links north east Wales, statement is as set out in the Wales Spatial inaccurate. Why does our economy Plan. in Wrecsam need to be 'responsive' to the north West of England as implied here? Why do we not need to be responsive to north West Wales for instance? Very one dimensional view. This could improve by going back to the drawing board, get local input on what the vision should be. 1930 Carys Wynne-Williams Arts Council of Wales With additional reference to the arts Noted. But not considered such as arts and cultural assets necessary to reword.. 5623 Mr M Gilbert, The on behalf of Redrow There is nothing within the Vision Noted. . Planning Consultancy Homes Ltd that acknowledges an intention to respond to and provide for the needs of the existing and future population in terms of the provision of housing, employment and social facilities, in our view this should also be included. It may be a typographical point, but Wrexham is not in the North-West of England, the reference should, presumably be to the North East Wales/North West England Sub-Region. 6533 Charlene Sussums-Lewis Carter Jonas Strong economy also means Noted. supporting the economy in rural areas such as Iscoyd where a number of rural enterprises exist.

38 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response 6910 Tim Stratton Wrexham Local Access The Countryside and Rights of Way Noted. The majority of this Forum Act 2000 makes new provision for comment refers to other public access to the countryside. legislation and plans with Section 60 of the Act requires the some reference to PPW and local highway authority to prepare a the national cycle network. Rights of Way Improvement Plan. Not necessary to duplicate Section 60(2) states that the plan requirements of other should assess (a) the extent to legislation or indeed PPW. which local rights of way meet the present and likely future needs of the public, and (b) the opportunities provided by local rights of way for exercise and other forms of open-air recreation and the enjoyment of the authority’s area. Section 60(3) states that the authority by whom a rights of way improvement plan is published shall, not more than ten years after first publishing it and subsequently at intervals of not more than ten years (a)make a new assessment of the matters specified in subsection (2), and (b)review the plan and decide whether to amend it. The Welsh Assembly Government has laid out targets for improving the health and fitness of the nation (Welsh Assembly Government Strategy for Sport and Physical Activity - Climbing Higher 2005) which establishes the Government’s commitment to improving Public Rights of Way and people’s access to the countryside. Planning Policy Wales (Edition 7, July 2014) is the land use planning policy for Wales and should be taken into account when preparing development plans. 39 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response Section 8.2.2 states that where appropriate, planning authorities should also seek to assist the completion of the national cycle network and of key links to and from the network. Section 11.1.13 states that local authorities should seek to protect and enhance the rights of way network as a recreational and environmental resource. They are also encouraged to promote the national cycle network, long distance footpaths, bridleways, canals, and the use of inland waters and disused railways as greenways for sustainable recreation. Wrexham UDP Policy T9 states that development proposals will be required to provide walking and cycling routes, where feasible and appropriate, that link with existing or proposed walking and cycling routes, and integrate with the public transport system. Opportunities for horse riding along these routes will be secured where appropriate. Wrexham CBC has a statutory duty to write and publish Rights of Way Improvement Plan and to record and keep open public rights of way. This duty also includes providing a Definitive Map. Wrexham CBC published the Wrexham Rights of Way Improvement Plan (ROWIP) in 2007. In accordance with Section 60(3) of the CROW 2000 Act the authority is required to review the plan before 2017. The Wrexham 40 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response LDP 2013-2028 (March 2015) - Green infrastructure and access to the countryside do appear in sections of the plan. However, they should be read as a continuous theme throughout the document in order that the Vision and Objectives can be achieved. Examples are included in response to the questions below. A more detailed statement will follow. The Vision - Replace 'responds to' with 'responds to and enhances' to add a proactive attitude towards our assets.

7081 David Metcalfe Plas Kynaston Canal It should be, and we are enthusiastic Noted. Group about making positive site specific recommendations for inclusion in the LDP2 to help attain the stated objectives for both our community and Wrexham as a whole. 7628 Steve Jackson Coleg Cambria Inclusion of tourism/visitors to link in Noted. However it is with the heritage and culture assets. considered that this is referred 41 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response to in the objectives in relation to the delivery of the vision (objective 5). 8408 Mark Harris Home Builders The Vision appears very ‘wordy’ Noted. Federation (HBF) covering a lot of issues, however, it doesn’t acknowledge an intention to respond to and provide for the needs of the existing and future population in terms of the provision of housing, employment and social facilities. This is particular important if the plan chooses the employment led growth strategy, which HBF will support in our responses to the further questions. The Vision should state the aspirational aims of the plan and positively encourage investment to support the growth strategy. 8412 Helen Howie Berrys on behalf of Tony The vision emphasises the economy Noted. Jones and Richard and the environment but there is no Tomlinson recognition of the importance of suitable housing to residents' quality of life. I would suggest an addition to the last sentence as follows: "Wrexham will be a place where everyone feels safe and included which reduces inequalities and a place that provides for everyone’s needs as well as positively responding to the quality and distinctiveness of our natural, built heritage and culture assets." 8430 Susan Evans WCBC, CYP Service, The Vision has clear links to the The LDP, once adopted, will PSC Department Council plan priorities and the have to be monitored annually priorities of the Local service Board. against a set of indicators as Would suggest that the review required by PPW and the LDP timescales for the plan are included regulations. Where these

42 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response for information within the final targets are not being met, the document to allow for amendment to Plan may need to be reviewed. the vision and objectives over the 15 The monitoring indicators will years of the plan should a change of be included in the Deposit direction/focus be required. LDP. 8451 Penelope S J Coles Overton Local Access I think that not enough emphasis has Noted Forum been placed on Welsh culture. I think that the last sentence in the vision statement should read “that positively responds to and promotes the quality and distinctiveness of our natural built heritage and Welsh culture. 8452 Helen Howie Berrys on behalf of R & The vision emphasises the economy Noted. C Homes and the environment but there is no recognition of the importance of suitable housing to residents' quality of life. I would suggest an addition to the last sentence as follows: "Wrexham will be a place where everyone feels safe and included which reduces inequalities and a place that provides for everyone’s housing needs as well as positively responding to the quality and distinctiveness of our natural, built heritage and culture assets." 8455 Michael Dixon Local resident This is an excellent statement and I Noted. support it. 8456 Maureen Williams Local resident Based on previous plans the vision Noted. is aspirational rather than achievable. All I have witnessed as a resident of Summerhill is over development in housing with no growth in employment, an increase in commutes into England and Wrexham, an increase in traffic and

43 Wrexham LDP – Issues and Options Consultation Responses Q.2. Comments on Vision and Officer Responses ID Name Organisation Comment Officer Response associated congestion on roads in the village not built to accommodate them, and a negative impact on village life living with the consequences of bad planning decisions. 8468 Vincent Ryan Barton Wilmore On Generally supportive of the Vision - Noted. Behalf of Barratt Wrexham Town has the potential to Developments PLC deliver housing growth in locations with excellent links to existing and potential locations for employment in parallel with the town's strong retail and service offer. Benefits from linkages to North West England and North Wales. Recommend that reference is made to market and affordable housing and new employment opportunities having been delivered where people have the choice to live and work in sustainable communities. 8293; Janet Radford AVOW, Public Health The vision statement is rather long, it Noted. 237; Wales, Wrexham County could be shortened somewhat in line 7075; Borough Council Health with the comments made at the 8309 Promotion - working recent Key Stakeholder Forum. together through Public Health Commissioning Group

44 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses

Q.4. Comments on Objectives

ID Name: Organisation: Comment Officer Response

67 Mike Jenkins Wrexham County From a Strategic Housing It is not necessary to include Borough Council - perspective we consider that the affordable housing as a Strategic Housing delivery of affordable housing separate objective. Objective Services currently referred to in objective 2 2 is aiming to deliver mixed should be included as a separate communities which will be objective. Whilst we agree with the achieved by delivering a mix of principles of objective 9 new both market and affordable development is often constrained by housing. Detailed policies in existing locations (particularly in the LDP will cover this issue. relation to brownfield sites) and therefore sustainable travel options It is considered that in relation should not out way otherwise viable to last point – this is too development opportunities. There detailed to be included within may be scope to include reference to the objectives. However, we the developing role of co-operative can explore the options for and self-build housing which may be delivery via the mechanisms in given priority as a means of the LDP. delivering housing in rural communities. 145 Dewi Griffiths Dwr Cymru Welsh Water Not answered NA 155 Justin Paul J10 Planning Ltd Allocations must be expressed as a Noted. Such issues are minimum and be in balance, considered at application proportionate and ambitious. Key stage. The Coal Authority will settlements out of Wrexham should also be consulted on any not be ignored; they too are part of proposed allocations to Wrexham's "distinctiveness" and determine site constraints and should be allowed to grow with new future deliverability. housing, employment and retail offers thus maximising their sustainability. We accept the 45 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

principle of "Provision of an adequate supply and protect valuable mineral resources", but this needs to be properly qualified by the Council. Mineral reserves that cannot be extracted due to site constraints, including potential significant adverse impacts (i.e. noise and air pollution) on local settlements, should not be protected. 169 Philip Mc Cormick RIBA Mc Cormick Architecture More flexibility needed to ensure Noted. Ltd. appropriate level and variety of housing is supplied to the benefit of all communities, not just in Wrexham itself. 247 Arfon Jones WCBC Local Councillor No objection to the proposed Noted. This, however, is not strategic objectives, subject to the considered necessary as it is following comments: Objective 1 - national policy which the LDP Meeting the future needs of a will have to demonstrate and growing population - It would will be assessed through the perhaps be appropriate to extend tests of soundness. this objective to include reference to the need to ensure that the provision of large amounts of new development should go hand in hand with the provision of employment opportunities. Objective 2 - Affordable homes - more needs to be done to ensure the successful implementation of the Authority's policy on the provision of affordable housing and would welcome an assurance that the Authority will take such steps as are necessary to 46 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

require developers to fulfil their obligations in this regard. Objectives 9 and 10 - Reducing the need to travel by car and to prepare and maximise resistance to climate change - It is essential to re- emphasise the importance of these objectives and to highlight the needed for improvements in public transport.

265 Michael Dixon Coedpoeth Community A challenging list, but it should be Noted. Council achievable if adequately supported. We have opportunities to use the considerable local structures already in place to develop evolutionary changes - to the benefit of all: residents, employers and visitors. 305 Mrs V Jones Marchwiel Community Wrexham desperately needs new Noted. The Wrexham Town Council independent shops to bring the Centre Master Plan is intended deserted run down town back to life. to address issues in Wrexham People will then be drawn in to Town Centre. This plan forms obtain the creative one off purchases part of the evidence base for like Shrewsbury offers. the Local Development Plan. 403 Penelope S J Coles Overton Community I think objective 6 should read “... Noted. Council designing safe, secure communities that are walk able , where it is safe to cycle and where provision is made for all outdoor activities such as horse riding, water sports and climbing”. To objective 9 it needs to be added that more cycle lanes need to be constructed on Wrexham’s main roads. Bullet point 3 I do not 47 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

agree that the County Borough is over represented in manufacturing. The fact that manufacturing is a declining sector of the economy needs to be addressed, and manufacturing should be encouraged. Bullet point 6. I think that there are not yet enough cycle lanes on our roads. Perhaps you could add “... and more cycle lanes need to be constructed on Wrexham’s main roads” 436 Peter Mullen Gwersyllt Community The Council has no objection to the Noted. This, however, is not Council proposed strategic objectives, considered necessary as it is subject to the following comments: national policy which the LDP Objective 1 - Meeting the future will have to demonstrate and needs of a growing population - It will be assessed through the would perhaps be appropriate to tests of soundness. extend this objective to include reference to the need to ensure that the provision of large amounts of new development should go hand in hand with the provision of employment opportunities. Objective 2 - Affordable homes - The Council considers that more needs to be done to ensure the successful implementation of the Authority's policy on the provision of affordable housing and would welcome an assurance that the Authority will take such steps as are necessary to require developers to fulfil their obligations in this regard. 48 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

Objectives 9 and 10 - Reducing the need to travel by car and to prepare and maximise resistance to climate change - The Council considers it essential to re-emphasise the importance of these objectives and to highlight the need for improvements in public transport.

652 Carrie Harper Plaid Cymru The plan in the main relies on Noted. The 2011 based housing development levels that are household projections were not sustainable and not needed produced by Welsh locally, therefore the driver for the Government in February 2014 plan is not local need. There is in and form the basis of the fact very little local input into it at all. Strategic Growth Options. In addition to these projections Carl Sargent (Minister for Natural Resources) has stated that LPAs must provide for the level of housing based on all sources of evidence.. 769 Cllr Rodney Skelland WCBC Concerns that there is not enough Noted. emphasis on economic development which in turn leads to an improved quality of life and all the advantages that bring to an area.

49 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

1918 Mike Barclay WCBC Play Section 11 of the Children and Noted. The Local Development Development Team Families (Wales) Measure 2010 Plan will need take account of places a statutory duty on all local open space and sport and authorities to assess and secure recreation facilities as it sufficient play opportunities for emerges. children. The Welsh Government commenced the first part of this duty . on 2 November 2012 with Wrexham consequently submitting its first Play Sufficiency Assessment (PSA) to the Welsh Government on 1 March 2013. Wrexham’s assessment concluded by stating that more of an emphasis needed to be placed on promoting children’s free time and space for play within the wider public realm. This focus was encapsulated within the following twelve priorities identified as a result of the play sufficiency assessment and subsequently endorsed by the Executive Board in April 2013: • Priority 1 Increase object play-time during term-time • Priority 2 Enhance opportunities for playing in Winter • Priority 3 Secure safer streets for play • Priority 4 Secure a wider range of spaces for play • Priority 5 Secure spaces for play in close proximity to children’s homes • Priority 6 Ensure quality design for play value • Priority 7 Secure a greater range of provision for young people • Priority 8 Improve 50 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

children’s subjective experience of time & space • Priority 9 Increase parental permission for play • Priority 10 Improve support for disabled and marginalised children • Priority 11 Improve generalised negative attitudes towards children & their play • Priority 12 Improve people’s perception of young people The Welsh Government then commenced the second part of the duty in July 2014 placing a requirement on local authorities to take action to secure sufficient play opportunities with regards to their PSA, so far as is reasonably practicable. The statutory guidance associated with this duty repeatedly stresses the importance of both maintaining existing strengths and addressing shortcomings identified through the assessment process and encourages local authorities to: “make a firm commitment to work strenuously within their own structures; with partner organisations; with children and their families and communities to ensure that children have access to the play opportunities that they want and have a right to expect”. In particular the guidance goes on to recommend that: “local authorities should use all practical means available to them to 51 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

maintain provision and services, and to increase and improve play opportunities for all children in their areas”. Furthermore research in Wrexham has also shown that children and parents talk about how improving opportunities for play can make an area a better place to live, in particular: “the more free-time children have to play in their neighbourhood, the stronger their attachment to the place may be” and that more people playing out more of the time in more places can improve community cohesion and strengthen intergenerational relationships. It is also clear that parents value the respite from direct caring duties when children are out playing and feel that this helps them to be better, less stressed, parents at other times. All of this will be of particular importance to children and families who also have to cope with the potentially damaging effects of living in poverty, recognising that with access to quality play opportunities “children can enjoy their childhood despite experiencing financial and social disadvantage”. Children playing out can therefore be seen as an indicator of a ‘safe’ and child friendly community, one that values children enough to ensure their 52 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

needs are considered alongside those of adults, recognising that children and their play are not separate from other aspects of community life but instead are an essential part of it and so should have as much right (not more) to time and space as any other resident. I would therefore suggest that the strategic objectives should include a reference to the local authority's statutory duty to secure sufficient opportunities for play, recognizing children's ability to play as an indicator for many of the positives included in the overall vision and that this agenda relates closely to other issues associated with increasing people's independent mobility, road safety and access to the natural environment. 1930 Carys Wynne-Williams Arts Council of Wales For point 8 - Conserve, enhance and It is not considered necessary promote the local - add - the vibrant to expand, particularly given arts - culture and character and that culture can include a distinctiveness of Wrexham - this will range of activities including art. highlight the need for the arts and the bring forward a reference to the arts and culture development currently taking within Wrexham town - which is to be highly commended.

53 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

5623 Mr M Gilbert, The on behalf of Redrow There is nothing within the Noted. Planning Consultancy Homes Ltd documents that acknowledges that these are broad objectives which at times may be in conflict with one another, in our view this needs to be recognised so that there can be a balanced approach to future development. In particular, we make the following comments: 2. This objective should be expanded to make clear that it is the Council's intention to meet the full objectively assessed need for housing. 3. The supply of jobs should be to meet the needs of the existing and future population as well as being a means to promote greater prosperity. 7. It must be recognised that this objective is likely to be in conflict with development requirements and, therefore, the objective should be applied "where reasonably possible". 10. Rather than maximising resistance, shouldn't the objective be to minimise climate change insofar as it is reasonably possible commensurate with other objectives?

54 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

6533 Charlene Sussums-Lewis Carter Jonas The Vision states that the economy Noted. It is considered that the will be strong and resilient, but 3.1 approach taken in assessing suggests that development will only the various settlements which be considered in accessible make up the rural areas of the locations, which is contrary to County Borough is in Paragraph 5.23 on page 19 of the accordance with National consultation document which refers Policy. In relation to Iscoyd to not writing Local Service Centres being identified as a tier 4/5 off as unsustainable due to them settlement, no map has been having a lesser number of facilities provided to show the extent of and reliance on cars. Rural areas by where a settlement boundary their very nature are not always should be drawn in this area. readily accessible by a range of The economic activity in this regular public transport services, but area is acknowledged, some Rural areas do contribute however, it is not currently heavily to the economy and provide identified as a settlement in the employment for those living in the County Borough and given the rural areas. Therefore limited dispersed nature of residential development should be development within the Iscoyd permitted to strengthen these Rural area, it therefore not settlements, such as Iscoyd. considered appropriate

55 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

6910 Tim Stratton Wrexham Local Access The Objectives are generally Noted. It is considered that Forum positive. However, the theme of Objective 6 – including all green infrastructure and access to these other modes of travel is the countryside is lost amongst other too detailed, ‘accessible’ priorities and therefore does not should be sufficient. support strongly enough the Council’s Vision and statutory duty as a running theme through the plan. Objectives 5, 6, 7 and 8 touch on this topic. Within the Objectives we suggest the following word(s) could be included – green infrastructure, access to the countryside, urban and rural areas, leisure, and recreation. Interlinks is an important part of Green Infrastructure. Objective 5 - include 'leisure' in addition to tourism and economic development opportunities? Objective 6 - replace 'protecting' with 'protecting and enhancing' to encourage planning for improvement rather than just conserving. Also 'walk able' is too limiting (and does not include more active and diverse recreation - riding, angling, climbing, paragliding, canoeing etc.) 'Accessible' included as an addition? Objective 7 – urban and rural? Objective 8 - replace 'protecting' with 'enhancing'. As phrased, this is negative.

56 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

8298 Leslie Smith L S Planning Ltd Any plan must have regard to the Noted. reality of how people actually live. The Wrexham hinterland requires travel by car and this should be accommodated rather than acted against. 8379 Alison Truman Canal and River Trust Generally supportive of the vision Noted. and objectives. In particular, supports Objective 5 in relation to protecting and enhancing the Pontcysyllte Aqueduct and Canal World Heritage Site. 8408 Mark Harris Home Builders The Objectives clearly build on the Noted. Federation (HBF) vision and give a lot more detail, however as already stated we do consider that one of the plans key messages around housing and employment growth is currently reflected in the vision. In addition to the list of objectives it is suggested that there needs to be a statement that acknowledges that these are broad objectives which at times may be in conflict with one another and that if development is to be encouraged then a balanced approach will have to be taken. In particular, we make the following comments with regard to the current points: 2. Would suggest including some additional wording - ‘delivering a range of types and locations of housing. 3. The supply of jobs should be to meet the needs of the 57 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

existing and future population as well as being a means to promote greater prosperity. 7. It must be recognised that this objective is likely to be in conflict with development requirements and, therefore, the objective should be applied "where reasonably possible", or in areas where there are specific levels of protections as a result of formal designations such as an SSSI. 10. In addition to maximising resistance, shouldn't the objective be to minimise climate change insofar as it is reasonably possible taking account of other objectives? 8412 Helen Howie Berrys on behalf of Tony The vision needs expanding to Noted. Jones and Richard capture the essence of providing for Tomlinson the county borough's full needs for housing and infrastructure - see our response to question 1. 8417 Liam Toland Heaton Planning Ltd on Support principle of Objective 11, the Noted. This will be dealt with behalf of Lafarge Tarmac supply of adequate mineral is at the detailed plan stage Trading Ltd invaluable particularly as the Plan is when setting out mineral seeking significant growth. Mineral resource protection areas. extraction at Borras Quarry is an Any sites before being important resource for Wrexham and allocated in the LDP will need the wider region and it should be to take account of mineral ensured that mineral resources such protection or extraction issues. as Borras Quarry are protected from non-mineral development. Concerned that there is a conflict between Objective 11 and Spatial Options 1 and 2. 58 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

8430 Susan Evans WCBC, CYP Service, In relation to objective 9 above the These comments are noted. PSC Department service feel that this would support impact of rural poverty, this would Objective 12 – consultation on also need to be supported by relevant policies will be carried improved transport links across the out through the LDP Deposit Borough. In relation to objective 12 stage. the service feels that there should be a wide consultation with members of The Council acknowledges the public regarding how this that the LDP needs to be objective will be actioned and should founded on sound evidence fracking be an element within this, base documents. The further consultation would be evidence highlighted is needed. With regards to objective 8 ongoing (as set out in there is a feeling that the local Appendix 3 of the consultation culture of Wrexham may need to be document). The list in the redefined given the increase in consultation document is not polish and Portuguese residents for meant to be exhaustive and example. There is little mention in the Council will take account of the document about ethnicity or other published documents or meeting the needs of particular commission further research groups of people including children, during the preparation of the young people, parents, lone parents, LDP as necessary. disabled people, carers etc. Potentially these groups will need In reference to supporting the specific types of support if objectives needs of specific people, this are to be achieved for the whole is assumed to be in terms of Wrexham population and this needs social support. It is not the to be taken into consideration in the intention of the Plan to set out development of the action plan for such provision, but rather the the strategy. Has there been any development of land, which will research of information gathered of course need to account for about the financial impact on Council inclusive design. departments of developments within Wrexham. For example private In terms of impact upon 59 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

children’s care homes in Wrexham Council resources, it is not the have had a significant resource aim of the Plan to assess this, impact on the CYP Department but to assess and identify the including Corporate Parenting, future land requirements within Education, YJS, also Health and the County Borough and North Wales Police. The impact of where this would be best any development on the Council’s located. resources should be an area for assessment and this could be included within the objectives of the strategy.

8449 Michael Forgrave Gower Homes The less sustainable locations Noted. It is considered that the should not be ignored. The approach taken in assessing 'Wrexham Villages' are part of the various settlements which Wrexham's distinctiveness and make up the rural areas of the should be allowed to grow - many County Borough is in people (like to live (and work) in accordance with National these villages and so their children Policy. should be allowed to too. 8450 Ian Howard BCUHB Objective 6 could be strengthened to Noted. Reference to objective include reference to the healthy and 13 has been taken as inclusive communities agenda. reference to objective 9. Objective 13 could be broader - e.g. promoting alternative travel choices. 8451 Penelope S J Coles Overton Local Access I think objective 6 should read “… Noted. Forum designing safe, secure communities that are walk able , where it is safe Objective 6 – could expand to cycle and where provision is made this objective to support for all outdoor activities such as outdoor activities but not horse riding, water sports and considered necessary to list all climbing”. To objective 9 it needs to activities. be added that more cycle lanes need to be constructed on Wrexham’s Objective 9 does refer to 60 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

main roads. Bullet point 3 I do not locating new development in agree that the County Borough is locations that are accessible to over represented in manufacturing. a range of travel options, The fact that manufacturing is a including cycling, but does not declining sector of the economy mention improving the needs to be addressed, and provision of cycle routes – this manufacturing should be does need to be considered. encouraged. Bullet point 6 ‘I think that there are not yet enough cycle In relation to bullet point 6, lanes on our roads. Perhaps you although it refers to A483 trunk could add “… and more cycle lanes road constraints and town need to be constructed on centre accessibility constraints, Wrexham’s main roads” there is no mention of constraints that surround alternative forms of travel such as cycling. This needs to be looked into further. 8452 Helen Howie Berrys on behalf of R & The Vision needs expanding to Noted. C Homes capture the essence of providing for the county borough's full needs for housing - see our response to question 1. 8453 Malcolm Ratcliff Mineral Products Strategic Objective 11 - Minerals. Noted. Association This objective should refer to the provision of a steady and adequate supply of construction materials that will be sufficient for planned levels of growth. 8455 Michael Dixon local resident A challenging list, but it should be Noted. achievable if adequately supported. We have opportunities to use the considerable local structures already in place to develop evolutionary changes - to the benefit of all: 61 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

residents, employers and visitors.

8456 Maureen Williams Local resident Many are empty promises, unless Noted. translated into workable options. Objective 1 – sustainable and accessible locations? Planners need to visit Summerhill to witness the damage to community cohesion in the village caused by years of wrong planning decisions and over development. I am the fourth generation of my family who were born, lived, worked a, married and raised families in Summerhill – I speak from a position of strength. 8467 Gill Wilson Butterworth Local Resident Generally agree, however country Noted. people will always need a flexible mode (of transport) to accommodate their working and family lives. For us a car is essential and expensive. 8468 Vincent Ryan Barton Wilmore On The objectives broadly align with the Noted. Behalf of Barratt vision, The Wales Spatial Plan and Developments PLC Planning Policy Wales (PPW). 8469 Wendy Sime Local Resident Generally agree, however country Noted. people will always need a flexible mode (of transport) to accommodate their working and family lives. For us a car is essential and expensive.

62 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

8293; Janet Radford AVOW, Public Health Although we agree with the Noted. The consultation 237; Wales, Wrexham County objectives we feel that there is scope document at para 5.3 7075; Borough Council Health for revisiting the wording of a acknowledges that 8309 Promotion - working number of them. In particular infrastructure improvements together through Public Objective 6 and 9 are connected, but need to be aligned with new Health Commissioning both contain weak phrasing. The development, including Group promotion of well-being is important improvements to transport in view of preventing ill-health, we networks, utilities, green would wish to see a policy protecting infrastructure , health, community assets. The creation of education and social facilities. vibrant sustainable communities is vital. This approach could be reflected in objective 1. Associated with this objective is the need to ensure the right mix of health care services and educational provision is developed alongside housing and employment growth in order to ensure the NHS and schools keep pace with increased community needs. One of the major factors related to choice with respect to health behaviours is the environment. The term Obesogenic Environment is used by public health professionals to describe "the sum of influences that the surroundings, opportunities or conditions of life have on promoting obesity". The built environment can have a significant impact on levels of physical activity, and access to healthy food options can be determined by transport and location 63 Wrexham LDP – Issues and Options Consultation Responses Q.4. Comments on Objectives and Officer Responses ID Name: Organisation: Comment Officer Response

of retail and takeaway outlets. We would wish to see a bold statement that the LDP will seek to improve the health of the population though promoting the creation of an environment that encourages positive lifestyle behaviours. We would like to see objective 6 and 9 combined and strengthened to reflect this approach.

64 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses

Q.5. Comments on Issues

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County Whilst we agree with the majority of Noted. Affordable housing is Borough Council - the key issues and drivers we would not an infrastructure Strategic Housing make the following comments and requirement. It is not Services suggestions: Bullet point 5: The considered necessary to go need to address the housing into detail at this stage about requirements of an ageing POS being redefined. population will continue to develop as a major housing and support In relation to the delivery of requirement and should be reflected affordable housing, it is as a separate issue. Same for acknowledged that this is a affordable housing given the difficult issue. However, shortage identified in the current provision is based upon (2014) and previous HMA viability. assessments. The consideration of requiring all new residential In relation to the comment development to meet lifetime homes about brownfield capacity, this standards should be seriously is addressed via bullet point 2 considered to meet the accessible of the consultation document. homes requirement. Bullet point 9: Should this include a statement here to the effect that as brownfield capacity is limited this will need to be considered as a limited development option. Bullet point 11: Is affordable housing an infrastructure requirement? Bullet pint 14: POS needs to be re-defined and this is underway but this should be referred to here? As a general comment the delivery of AH through the planning process often suffers due to competing requirements of other areas such as education. This is likely to be exacerbated once CIL is 65 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response introduced. Given both the local and national shortage of both housing and affordable housing we don't feel either is adequately reflected here.

66 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd Concern is expressed at a lack of Noted. The Revised Delivery progress made in having a sound Agreement December 2014 evidence base despite the fact that it establishes a realistic timetable is now over 2 years since LDP1 was for the preparation of the withdrawn. The Topic Papers add Wrexham Local Development little new evidence or direction and Plan. actually appear to reflect the very problems and challenges faced by The LDP needs to be founded the Authority in having to withdraw on sound evidence base LDP1 and have not addressed the documents. The evidence concerns expressed by the highlighted is ongoing (as set Inspector. We agree with many of out in Appendix 3 of the the key issues and drivers (e.g. lack consultation document). The of brownfield) however, we cannot list in the consultation agree to the notion that household document is not meant to be growth in some lower order exhaustive and the Council will settlements is fully constrained. We take account of other also disagree that the transport published documents or infrastructure, the A483 and town commission further research centre accessibility is unduly during the preparation of the constrained; no evidence is available LDP as necessary. to support this conjecture. We also consider that too much priority is placed upon enhancing local biodiversity and tree conservation; SLA's and agricultural land quality. Our summary response on this is as follows: •Strengthening Wrexham Town as a key settlement of national importance with a focus for investment in future employment, housing, retail, leisure and services. We agree that this a key issue and it will be appropriate to sufficiently focus investment, infrastructure and services in and around Wrexham Town, at sustainable locations, which creates a critical mass to 67 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response necessitate the delivery of a hub that can self-sufficiently grow as a ‘town of national importance’. • There is a lack of brownfield capacity to accommodate projected household growth in the County Borough. We agree with this. Without a co- ordinated and proactive planning response that unlocks land currently designated as Green Barrier, then the vision and objectives set within the LDP to deliver sustainable communities and raise Wrexham’s national importance cannot be met. • The County Borough is over- represented in declining sectors of the economy such as manufacturing and the quality and diversity of the employment offer needs improving. A homogenous effort is required to deliver the systems and networks to improve the economic make-up of Wrexham, so as to break away from the reliance on declining sectors. Here and now there is an opportunity to enhance existing successful sectors and reinvent to attract new ones. • “Significant population and household growth is predicted over the Plan period but the capacity of some settlements may be constrained”. It is accepted that significant population growth is predicted. We accept that the constraints around some settlements are likely for many reasons. It is therefore recommended a proportionate level of growth is 68 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response tailored based upon a settlement hierarchy and understanding of local capacity issues. It is suggested that the Council prepare a proper and full assessment to balance this ambitious vision so that development within the outer settlements (including Minor villages and Local Service Centres) is limited and proportionate so as not to burden these areas. As explained in later answers, it is considered that primarily new growth can and will have to be accommodated around Wrexham town, with our preference that this is to the West of the town. We note that whilst Background Paper No 2 - Settlement Hierarchy and Development Potential, March 2015 goes some way to considering high level constraints, this should include sustainability (i.e. some towns are very detached from community infrastructure, public transport, employment etc.), and thus advancing growth here will undermine the sustainability agenda. The constraints list also needs to include Special Landscape Areas and other similarly important designations. Market viability should also be factor to consider in this list. Some settlements, regardless of need, will not have the ability to deliver housing or employment due to a weak local market or site context. Accordingly, it would undermine the robustness and 69 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response soundness of the Plan, if areas are allocated for housing that are unlikely to come forward for housing in the 15 year Plan Period. • There are (potential) transport infrastructure capacity and constraints along the A483 trunk road and accessibility within Wrexham Town Centre is constrained. Evidence is required by the Council to justify this and how these may be mitigated. So far no formal evidence has been published to demonstrate any capacity issues and constraints and we do not concur with this statement. However, should this be proven, there is a real opportunity to respond to these in a positive way, with major development projects expected to help fund and facilitate ways to improve this current position. • There are education capacity constraints in many of the schools in the County Borough, particularly in Wrexham Town. This may be so, albeit no evidence is provided within the Council’s supporting documentation. Major new housing proposals can help alleviate capacity issues and it should be seen as an opportunity to enhance current facilities. But a critical mass is needed for development proposals to properly respond in a meaningful way. • Most of the settlements in the County Borough are surrounded by Green Barrier and Special 70 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response Landscape Areas, which also tend to include the Best and Most Versatile Agricultural Land (BMVL) as well as Mineral Resources of national and regional significance. Each of these needs to be weighed against land release. Whilst important they are not equal and their weighting will vary depending on local context and priorities. For example, Green Barriers are common across the County Borough, and their loss against Special Landscape Areas, which are less common, should be given less weight. Equally Mineral Resources of national and regional significance should be assessed on the quality and accessibility of the minerals. For some mineral designations, the truth is that they will not be extracted due to their close proximity to existing settlement areas and resultant adverse impact such extraction would have on harming local amenity etc. Accordingly, the Council must consider such designations now and determine whether they should remain, otherwise they unduly act to constrain housing development.

71 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 247 Arfon Jones WCBC Local Councillor Agree in principle with the key issues Noted. The ‘Brownfield and drivers, it considers that the capacity’ known as the UCS is following issues need to be looked at frequently updated and will be more closely: Brownfield capacity published as part of the - The Council considers it imperative evidence base in due course. that the development of brownfield Public open space is already sites should be revisited since some referred to in bullet point 14 settlements, especially the larger ones, are constrained already. There is, regrettably, nothing in the consultation document to suggest that this will happen. Public open space and play provision - the need for children to be able to play safely near their homes should be recognised and acknowledged as a key issue and driver. 436 Peter Mullen Gwersyllt Community Although the Council agrees in Noted. The ‘Brownfield Council principle with the key issues and capacity’ known as the Urban drivers, it considers that the following Capacity Study is frequently issues need to be looked more updated and will be published closely: Brownfield capacity - The as part of the evidence base in Council considers it imperative that due course. Public open the development of brownfield sites space is already referred to in should be revisited since some bullet point 14. settlements, especially the larger ones, are constrained already. There The LDP needs to be founded is, regrettably, nothing in the on sound evidence base consultation document to suggest documents. The evidence that this will happen Public open highlighted is ongoing (as set space and play provision - In out in Appendix 3 of the addition, the Council considers that consultation document). The the need for children to be able to list in the consultation play safely near their homes should document is not meant to be be recognised and acknowledged as exhaustive and the Council will a key issue and driver. take account of other published documents or

72 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response commission further research during the preparation of the LDP as necessary.

463 Ms Karen Benfield Offa Community Council New housing estates - roads are Noted. However, this is a often too narrow, no footpaths - detailed design issue. creates problems, driveways too narrow inadequate open space. Connected cycle routes needed. 1918 Mike Barclay WCBC Play I would suggest that play sufficiency Noted. The LDP needs to be Development Team should also be considered as a key founded on sound evidence issue with the Wrexham Play base documents. The Sufficiency Assessment being used evidence highlighted is as the evidence base. This issue is ongoing (as set out in related to the green infrastructure Appendix 3 of the consultation network and the provision of public document). The list in the open space but also road safety, consultation document is not independent mobility, community meant to be exhaustive and cohesion and perceptions of safety. the Council will take account of other published documents or commission further research during the preparation of the LDP as necessary.

73 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 1930 Carys Wynne-Williams Arts Council of Wales We would recommend that you add Noted. best practice within design to your vision so that this is adopted as a key driver within your work. We also would recommend you add that you will involve the end user in all your development plans so that the user's voice is captured as part of the development, again this is working to best practice standards. 1939 Howard Cartwright David Cartwright Solicitor I do have a reservation as to the Noted. denigrating reference to manufacturing, given the current revival nationally, albeit with problems of getting productivity rising again. 6533 Charlene Sussums-Lewis Carter Jonas The issues need to address the rural Noted. economy and enhancement of those areas which should be living working communities, not retirement villages.

74 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 6541 Mrs Carole Roberts - Clerk Acton Community Acton Community Council generally Noted. to the Council Council agrees with the key issues set out in the Consultation document. It Ensuring low density for new strongly agrees with the following development is not a useful issues: • There are education way to utilise scarce land capacity constraints for the Schools resources and will require in the Acton Community • There is a more land take. need to prioritise infrastructure requirements through new The Public Open Space Study development, e.g. education, is currently being updated and highways & public open space • will be published as part of the Maintaining, enhancing, restoring or evidence base in due course. adding to local biodiversity, landscape and tree conservation Many of the latter points raised interests • There is a need to in this comment refer to identify, manage, expand, retain and detailed design considerations. enhance the Green infrastructure Only strategic issues are being network, to include areas of public looked at, at this stage. open space such as Acton Park, the Nine Acre Field at Chester Road, the Holt Road/ Dean Road Recreation Ground, School playing Fields, Children’s Playgrounds at Aran Road, Acton Park, Ffordd Garmonydd and the Redrow Estate off the Holt Road and other open spaces in public and private housing developments • The 2009 Open Spaces assessment identified a deficit in playing fields in the Acton Community The Community Council considers the following issues to be high priority:- • To ensure a feeling of “openness” through conserving existing highway verges and street trees • To ensure low density for any new developments • Resisting over- 75 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response development of plots • Retaining existing stone and other boundary walls • Any new housing developments should provide open space that will enhance the landscape, include conservation of existing valuable trees and new planting of a wide species of trees to improve diversity as identified in the 2013 Wrexham iTree eco study.

76 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 6910 Tim Stratton Wrexham Local Access Yes there is a need to prioritise Noted. Forum infrastructure requirements through new development. The list should also include Green Infrastructure. In the sentence “There is a need to identify, manage, expand and enhance the County Borough’s Green Infrastructure network, including areas of public open space and recognising its importance in delivering local environmental, socio economic and health benefits;” suggest adding in ' and greater access to the countryside' after public open space. The LAF is reviewing access to the countryside and continues to work with Cyfoeth Naturiol Cymru/Natural Resources Wales in related matters. The LAF would like to work more closely with and support the Council in achieving the statements above (which could be via the ROWIP).

77 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 7732 Matt Ferguson Brymbo Developments Given the lack of brownfield capacity Noted. The LDP needs to be Ltd in the Borough, it is vitally important founded on sound evidence to make full use of that brownfield base documents. The land which is currently or potentially evidence highlighted is available, which is very much the ongoing (as set out in case in and around Brymbo. It is not Appendix 3 of the consultation considered that the presence of document). The list in the Green Barrier should be seen as a consultation document is not major constraint. Green Barriers meant to be exhaustive and were originally defined as limits to the Council will take account of the various settlements in order to other published documents or control spread. The likelihood of commission further research coalition is in many cases remote during the preparation of the and the land within the Green LDP as necessary. Barriers has no intrinsic value. It is clearly within the gift of the Council In relation to the Green Barrier to modify the Green Barrier Review, this is currently in boundaries as part of the Local Plan progress and such will be exercise. available in due course.

8408 Mark Harris Home Builders The HBF believe greater clarity Noted. The Revised Local Federation (HBF) could be provided over the need to Delivery Agreement December provide housing and employment 2014, sets the community opportunities to take full potential of involvement scheme outlining the areas opportunity for growth. the Council’s policy regarding Reference should also be made to who, how and when it will the Councils position in the wider engage in the process. North Wales and North West Adjoining Local Authorities are England Region and the need for Key Stakeholders. close cross border working.

78 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 8430 Susan Evans WCBC, CYP Service, The group felt that there is a real Noted. PSC Department need to ensure that the Council aims to develop/regenerate what we already have in place for e.g. derelict and empty town centre buildings before creating anything new. Regeneration work may also be more likely to attract other sources of funding. 8449 Michael Forgrave Gower Homes Yes, I broadly agree these are the Noted. key issues however; • I very much agree that there is a distinct lack of brownfield capacity, Gower Homes’ last 9 sites (311 houses) have all been brownfield which I’m sure is the case with many other house builders so as a consequence many of the more viable brownfield sites are now developed. • I disagree that household growth in some settlements is constrained. • I also disagree that the transport infrastructure, the A483 and town centre accessibility is unduly constrained. Yes the roads are busy during peak hours but so are the roads around all major towns. Wrexham road network is far less congested than many towns and cities in the U.K. • I think too much priority is placed on enhancing local biodiversity and tree conservation - we have a huge amount of countryside and trees in the borough.

79 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response 8450 Ian Howard BCUHB In addition: - need to undertake Noted. In terms of Health Impact Assessment on future contributions to health developments - need to add infrastructure, this needs to developer contributions for health discussed and addressed at a infrastructure also - need to note later stage of the plan difficulties in GP recruitment in rural preparation process. areas but also in Wrexham centre 8453 Malcolm Ratcliff Mineral Products There is no mention of the role of The objectives are intended to Association minerals in underpinning the show how the Vision will be objectives. We suggest the following achieved through the LDP. additional key driver, "Levels of Objective 11 highlights the construction arising from growth led importance of ensuring the strategies are between 166% and provision of an adequate 213% of completions experienced supply of minerals. Whilst the during the last 10-13 years. Such cross sectoral importance of increases in construction activity will minerals are recognised this need to be supported by will be detailed within the proportionately higher levels of evidence base supporting the mineral extraction". LDP. 8456 Maureen Williams Local resident I believe there is an abundance of Noted. It is not considered suitable brownfield sites. that there is an abundance of Developers are the stumbling block; brownfield sites available for they are interested in developing the delivery of housing over greenfield sites to maximise profit the lifetime of the Plan. than on cleaning polluted brownfield land. The tail is wagging the dog here. No mention of designing safe door step play areas for children by as far as is possible separating children and cars. 8468 Vincent Ryan Barton Wilmore On We support the Key Issues and Noted. Behalf of Barratt Drivers for the LDP, in particular the Developments PLC need to strengthen Wrexham Town as a key settlement of national importance, which should be the focus for the future investment in employment, housing, retail, leisure

80 Wrexham LDP – Issues and Options Consultation Responses Q.5. Comments on Issues and Officer Responses ID Name Organisation Comments Officer Response and services.

8293; Janet Radford AVOW, Public Health Although we broadly agree with the Noted. In reference to the use 237; Wales, Wrexham County drivers, there is a complete absence of Rapid Health Impact 7075; Borough Council Health of reference to population health and Assessments on all major 8309 Promotion - working well-being. Wrexham has high developments can be together through Public population levels of overweight and considered at detailed policy Health Commissioning obesity, chronic health conditions preparation stage. Group and disability, this combined with the changing demographic projects is a driver for health improvement and promotion of well-being. Evidence can be provided from Public Health Wales Observatory and from BCUHB Needs Assessment. There is a compelling case to ensure that Planning Policy is used to create an environment which is supportive of population health and well-being. We would advocate the use of Rapid Health Impact Assessment on all major developments to allow for a proper examination of the impact on health and well-being.

81 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses

Q.6. Comments on Option A

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County We support this option as the higher the Noted. Borough Council - number of homes required the higher Strategic Housing the likelihood of more AH being Services delivered pro-rata. 155 Justin Paul J10 Planning Ltd We consider that this option of 870 units Noted. per annum is the most realistic and robust figure based upon the evidence base available. It should be taken forward and expressed as a minimum and believe there is much greater scope for both the housing and employment figures to be increased above 13,010 new homes and 61ha of employment land respectively. However, the Inspector's Preliminary Comments of Feb 2012 recommended that for the 13 years remaining of the LDP1 plan period a total requirement net of vacancy and slippage would need to be 11,786 units which is equivalent to 906 units per annum based upon WG figures. If this was used now then the 15 year plan period for LDP2 would result in a requirement for 13,590 units; moreover 945 units per annum is known to be the highest past completion rate and if used this would generate a figure of 14,175 - we would advocate that this should be the preferred base figure to be used. Given that Wrexham has high levels of economic activity, 74% compared to 71.4% across North Wales and 68.9% for the whole of Wales, and given that that this is during a time when 82 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response the economy across the UK is starting to pick up pace, following a deep-rooted global recession, one would expect this economic activity to significantly increase. Accordingly, it must be expected that Wrexham’s economic standing will improve and thus employment projections should be increased from the required 61ha of employment land and projected 8700 job growth. The fact is that LDP1 recommended 70ha for a lesser period (5.3 ha per annum), so it is unusual why just 61 ha (4 ha per annum) is identified for a longer period and particularly when the Inspector raised concerns about lack of ambition, lack of high quality sites and the imbalance between housing and economic growth. This too would not fit with the emerging LDP’s objective ‘to ensure Wrexham becomes a key settlement of national importance’. Additionally, it has ignored the need for rural employment opportunities and the figure should be expressed as a minimum. A step- change is required as is ambition; both are presently lacking and we would advocate allocating 8 ha per annum which would generate a min. of 120 ha over the plan period; this figure being based upon LDP1 allocations + a review of existing allocations and a need to compensate for loss of extant UDP allocations. Employment-led projections rely on either predictions of job numbers or employment land requirements as a starting point for 83 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response future growth to then work out population and household growth, and is based on the premise that as job numbers grow, so will in-migration and the demand for new housing. Whilst it is true that there is a link between the two, there are many other factors which dictate housing growth. It is clear within the evidence base provided, specifically Background Paper 1 - Population and Household Projections with Dwelling and Employment Impacts, March 2015 that the increase in single family households is a burgeoning trend that will increase the demand for housing further. This needs to be considered as part of this overall projection. If in- migration is directly related to employment opportunities, then this too needs to be considered in the whole with employment projections. The evidence base assumes an overall household size of 2.25 as a minimum for employment led projections. We consider it will be less than this. Chart A2.2: average age profile of migrants in Wrexham, 2003/04 to 2012/13 [Background Paper 1], clearly shows a substantial proportion of total in- migration is by the 20-24 and 25-29 age group, respectively. It is further noted explained within this Paper, that since 2005/06, migration in Wrexham has been particularly driven by international migration, mainly as a result of the economic migration of people from the 8 countries which were admitted to the EU in 2004. Levels of net international 84 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response migration have been at least +400 people a year Since 2005/06, reaching a peak of +860 in 2008/09. Accordingly, given the principal in- migration age groups, these people are likely to be single or certainly not have children, given the trend to marry and have children later in life, and thus we consider the national average household size of 2.25 to be too high, and should be reduced. This would require the housing growth figure to increase. Specifically this projection assumes housing growth is determined by economic growth, but fails to realise and appreciate the built up latent demand for new housing in Wrexham, which has been a result of limited housing supply and growth due to the constraints of restrictive Green Barrier designations around Wrexham and other Urban Settlements. This needs to be factored into the respective housing growth figures. 169 Phillip Mc Cormick RIBA Mc Cormick Difficult to predict based on statistics Noted. Architecture Ltd provided. This option provides more flexibility for the future WCBC figures show a massive under achievement of residential completions in the past 12 months.

85 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response 247 Arfon Jones WCBC Local Councillor Inclined to support Option A Noted. Although this comment (Employment led Projection) although would suggest that option C is the provision of 13,010 new homes is supported, which provides for too high a target and recommend the 10,000 homes. implementation of a revised, more achievable target of 10,000 new homes. 257 Cllr Brian Cameron WCBC Whitegate Ward Concern on projected figures i.e. homes Noted and jobs 265 Michael Dixon Coedpoeth Community Wrexham County Borough is growing Noted. Council and should place itself to capture appropriate employment opportunities. We have many trading and light business sites as well as some more modest manufacturing. These should be supported and encouraged. In this way supporting local (and so reduced) travel - to the benefit of all. 292 Krista Childs WCBC Figures are potential Noted. 304 Dr Denis Edwards Local Resident Merging settlements to north west Noted. Although comment is Wrexham will lose local identity due to not relevant to this section. loss of green areas as new homes needed will be limited to Wrexham town. 305 Mrs V Jones Marchwiel Community Villages need to have the infrastructures Noted. Council in place. Schools, Doctors, roads able to cope with volume of traffic. Villages do not want to lose their identities. Marchwiel school is full to capacity. 347 Steve Nott Abenbury Community The Council cannot make an informed Noted. Council view, in the time we had to discuss this. 403 Penelope S J Coles Overton Community It is essential to concentrate on Noted. Council employment, but the employment of local people is most important to the people of Wrexham.

86 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response 436 Peter Mullen Gwersyllt Community Although the Council is inclined to Noted. Although this comment Council support Option A (Employment led would suggest that option C is Projection), it considers that the supported, which provides for provision of 13,010 new homes is too 10,000 homes. high a target and recommends the implementation of a revised, more achievable target of 10,000 new homes. 438 Cllr Graham Rogers WCBC - Local My concern: are the options given, Noted. The options have to Councillor realistic in the real world of growth, take account of Welsh growth being a difficult area to prioritize. Government projections and national planning policy as a starting point and are as realistic as they can be based upon the evidence available. 483 CLLR MARC JONES CAIA PARK Unsustainable. Even in the housing Noted. COMMUNITY boom 930 homes per annum were not COUNCIL completed. The development of flats in 2006/7 was an exception and distorted the figures. Housing cannot be based on theoretical jobs and should reflect actual needs 1939 Howard Cartwright David Cartwright On balance, I have to disagree with the Noted. Linking housing to Solicitor housing component of this option. employment provision is There is strong inflow to work in the national policy. Statistics do County Borough from other local not show that there is a strong authority areas, by choice of many inflow of workers in the County workers rather than necessity. Borough (see Joint Employment Land Review, March 2015) 3095 Carl Richards Local Resident The problem with option A is that it Noted. However the comments concentrates further development too appear to relate to the spatial specifically. Whilst it is important to options rather than the growth maximise the potential for our existing options. infrastructure it is also important to realise that in some cases we have natural or man-made boundaries which will limit the possibilities. I believe it 87 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response would be a better option to design a new key settlement area around and to the south of the A483/Ruthin road junction. Where it does prove necessary to build on greenfield sites they should be targeted to avoid over- straining the infrastructure on existing villages. Instead it makes more sense to develop new villages with all of the necessary infrastructure that they require, ideally in close proximity to the existing national road network. There is a distinct risk of local communities losing identity if large-scale development is carried out which either dwarf the existing community or result in that community becoming 'linked' to another through loss of the existing greenfield barriers. 5623 Mr M Gilbert, The on behalf of Redrow Whilst we understand the general Noted. Planning Consultancy Homes Ltd approach of linking employment and housing growth, given that the take up rate of employment land over the past ten years, including the recession years, has been 3.9 ha/annum, we consider 61 ha over the course of the Plan to be a level which is likely to be below the potential of the Borough. In a period of positive growth the Borough ought to be capable of achieving a take up rate in excess of 3.9 ha/annum, which would also indicate a consequent need for an increased housing requirement above that presently identified.

88 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response 6531 Guy Evans Cassidy and Ashton In respect of the Wrexham County Noted. Before testing different Borough LDP (2006 – 2021) (Now growth scenarios for the withdrawn). The Inspector’s County Borough consideration preliminary findings report noted: • A was given to the factors which significant shortfall in the supply of influence change, including the housing and the associated conflicting demographic profile of Plan strategy to confine general housing Wrexham, economic growth; to within settlement boundaries. • A the Inspector’s failure to take reasonable steps to recommendations for the secure an appropriate supply of withdrawn 2006-2021 LDP and affordable housing. • A failure in the the Council’s aspirations for Plan to respond to its own evidence the new LDP. base. It is submitted that, in light of the above comment, the local authority must ensure that the shortfall in the supply of housing land is addressed and that the maximum figure of new homes over the course of the plan period sought. Not only would Strategic Growth Option A address the identified and significant shortfall but it would also support economic growth aspirations within the proposed LDP and provide housing for levels of population growth in the upper range over the past 20 years Strategic Growth Option B has the potential to, and C would almost certainly result in a shortfall in housing land supply and fail to address the findings of the Planning Inspector. 6910 Tim Stratton Wrexham Local Access Appendices 1 and 2 do not appear to, No, historic completions do not Forum historically, support the projections. support the projections. It should be noted that the projections are based upon anticipated population growth and household size.

89 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response 7081 David Metcalfe Plas Kynaston Canal This is based in Wrexham town only Noted. However, the figures Group and ignores the rest of the county. for growth relate to the entire County Borough. 7628 Steve Jackson Coleg Cambria Figures appear to be consistent with Noted. planning assumptions. Plan should be ambitious in Wrexham's ability to grow and attract employment opportunities to provide high value jobs. 7732 Matt Ferguson Brymbo Developments Whichever Growth Option is selected it Noted. Ltd is apparent from past housing completions (Appendix 2) that the Council needs to be fully supportive of all sustainable development proposals if any of the projections are to be met. 8298 Leslie Smith L S Planning Ltd You must go for the highest number of Noted. the options available 95% of a lot is more than 100% of not many. 8408 Mark Harris Home Builders Although the HBF consider this the Noted. However a vacancy Federation (HBF) most appropriate option and we rate of 4% has been applied as understand the general approach of set out in the Population and linking employment and housing growth, Household Projections with given that the average take up rate of dwelling and employment employment land over the past ten impacts Background Paper years, including the recession years, 2015. has been 3.9 ha, we consider 61 ha to be a level which is likely to be below the In calculating the residual potential of the Borough. In a period of requirement as set out in positive growth the Borough ought to be Appendix 1, completions for capable of achieving a take up rate in 2013-2014 have been excess of 3.9 ha/annum, which would subtracted. No flexibility also lead to the need for a greater allowance has been added to housing requirement. We also completed sites. question the total housing figure shown for this option as broken down in Appendix 1 firstly this table does not show the addition of the % vacancy rate to the housing requirement, further the 90 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response addition of a 10% flexibility has been calculated incorrectly (10% of 11850 = 1185). In terms of the vacancy rate at recent inquiries in Cardiff and NPT a 4% rate has been accepted and a similar rate is suggested for Wrexham. However if a lower rate can be evidenced this evidence should be provided and whatever the figure is should then be used rather than as suggested in para. 6.14 Population and household projections Background paper 1 ‘a figure of about’ is used. If 4% vacancy rate were applied and a 10% flexibility the total figure would be 13,042. 8409 Rhian Harris HOW Planning on Option A is based on an employment Noted. behalf of Kingmoor led projection which will support the Park Properties Ltd Council's economic growth aspirations and vision of a strong, resilient economy, responsive to its strategic location within North East Wales. It also responds to local evidence, the Employment Land Review, which demonstrates the demand and need to allocate further employment land at Wrexham Industrial Estate. Option A is therefore strongly supported. 8411 Kate McClean Taylor Wimpey We support the employment led Noted. projection that supports housing growth to complement the Council's ambitious economic strategy.

91 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response 8412 Helen Howie Berrys on behalf of Growth is the primary way to reduce Noted. Tony Jones and inequality and secure prosperity for the Richard Tomlinson entire population, and so should be embraced as a positive force for improving Wrexham County Borough.

8430 Susan Evans WCBC, CYP Service, The group all agreed with this option as Noted. PSC Department it provides the highest number of jobs and the dwellings. Some concern was raised regarding the use of a high proportion of greenfield to progress this option, however it was agreed that due to the location of Wrexham within NWales and close access to the greenfield land across NWales that the land would be best used to support the economy and Wrexham to develop. 8451 Penelope S J Coles Overton Local Access It is essential to concentrate on Noted. Forum employment, but the employment of local people is most important to the people of Wrexham. 8452 Helen Howie Berrys on behalf of R & Growth is the primary way to reduce Noted. C Homes inequality and secure prosperity for the entire population, and so should be embraced as a positive force for improving Wrexham County Borough. 8455 Michael Dixon local resident Wrexham County Borough is growing Noted. and should place itself to capture appropriate employment opportunities. We have many trading and light business sites as well as some more modest manufacturing. These should be supported and encouraged. In this way supporting local (and so reduced) travel - to the benefit of all.

92 Wrexham LDP – Issues and Options Consultation Responses Q.6. Comments on Option A and Officer Responses ID Name Organisation Comments Officer Response 8456 Maureen Williams Local resident Over optimistic projections for additional Noted. Projecting employment homes based on employment and housing land requirements assumptions rather than hard data. can never be accurate. However, hard facts are used together with realistic assumptions about them in order to predict what the future requirements might be. 8468 Vincent Ryan Barton Wilmore On Option A will deliver the greatest social Noted. Behalf of Barratt and economic benefits for Wrexham. If Developments PLC a lower level of growth is proposed there is a risk that the LDP will not deliver the jobs, housing and infrastructure needed to secure the economic growth and social improvements that Wrexham is capable of achieving. With the right approach to the allocation of land for development, the LDP can deliver the growth for option A in a sustainable and timely manner. The negative conclusions set out in the Initial Sustainability Appraisal (Feb 2015) in relation to the impacts of option A on carbon emissions, reduced travel, biodiversity and landscape impacts are premature and should be afforded little weight. Support the growth and further development of Wrexham Industrial Estate as a nationally significant employment facility, as well as being sufficient to meet projected housing needs. 8469 Wendy Sime Local Resident I am not in a position to be able to Noted. comment on the accuracy of the figures but my gut feeling is that the figures are rather high.

93 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses

Q.7 Comments on Option B

ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd See response to Q6. The Option is Noted. Before testing different called household growth led projection, growth scenarios for the but is in fact an in-migration led County Borough consideration projection (2011 based, over a period was given to the factors which 2006-2011) as detailed in Background influence change, including the Paper 1. This is misleading, as demographic profile of household led growth implies all factors Wrexham, economic growth; affecting household growth have been the Inspector’s considered collectively. In-migration can recommendations for the be a result of the need to find work or withdrawn 2006-2021 LDP and relocating for education or social the Council’s aspirations for purposes. Whilst this can lead to a the new LDP. greater requirement for housing, this projection fails to appreciate other housing factors that can determine growth. For example, there is no appreciation of the latent demand for housing irrespective of in-migration. This demand has built up over the life of the existing Development Plan due to very restrictive land use policies, specifically the Green Barrier, which has undermined the delivery of new homes, desperately needed by the County Borough population. This constrained housing supply pushes up houses prices as demand outstrips supply, and results in children having to live at home with their parents for longer than they want or move to other conurbations and cities where they can buy a house. What’s more if the housing market becomes sluggish due to under delivery, movement in the market becomes 94 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response equally slow as there are fewer than needed new properties for movement up and down the ‘housing ladder’. Accordingly, this adversely affects housing offer and choice. It is considered that the projection figures are far too low. It is explained in the evidence base that projections are founded on past trends and only take what has happened in the past to see what would happen if those trends continue. Accordingly this status quo can undermine future forecasts based on new and changing events. Specifically this relates to the economy. The 2011 in- migration projections where sampled between mid 2006-mid 2011, and thus for four out of the 5 years, the economy was entering and in the middle of the deepest global economic recession faced by the UK and Wales. This will have significantly reduced economic prospects which in turn are partly related to in- migration. Yet the Authority has insisted that this projection is still plausible as it “meets advice from Ministers to avoid replicating a period of poor growth, as migration was not depressed in Wrexham, bucking the national trend”. We disagree with this statement. Whilst the trend was bucked in Wrexham, it was still during a period of overwhelming and unprecedented poor economic growth. So whilst in-migration was still strong, a buoyant economy would have likely seen even stronger numbers of in-migration, which would have contributed towards this projection. Accordingly we consider 95 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response this Option to still be a depressed projection which suppresses future growth potential. In addition, as much of Europe struggles with slow economic growth forecasts, and the UK’s economy picks up pace, one would expect in- migration from other EU and non-EU countries to increase and Wrexham, with recent and emerging employment successes, offers new employment prospects which will only serve to attract more in-migrants. 169 Phillip Mc Cormick RIBA Mc Cormick See comments re Option A See response to Q.6. Architecture Ltd. 257 Cllr Brian Cameron WCBC Whitegate Make reference to above (concern Noted. Ward expressed about projected figures). 265 Michael Dixon Coedpoeth Option A is the more forward looking and Noted. Community Council so to be preferred. WCBC would also run the considerable risk of not providing adequate housing again. 292 Krista Childs WCBC As before See response to Q.6. 304 Dr Denis Edwards Local Resident New housing spread over Wrexham and Noted. However, comment is primary key settlements so less loss of not relevant to this section. green areas in Wrexham town. 438 Cllr Graham Rogers WCBC - Local Same as option A. See response to Q.6. Councillor 483 Cllr Marc Jones Caia Park Community See comments under option A See response to Q.6. Council 507 Mike Blackshaw Ruabon Community This is more achievable by providing a Noted. Council realistic target. In taking this approach consideration should be given to develop brownfield sites as a priority over greenfield sites.

96 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response 639 Mr Steve Jones Llangollen Railway Enhanced non-car dependent transport Noted. However, comment is infrastructure to the outlying village not relevant to this section. communities would strengthen the potential growth for this option.

769 Cllr Rodney Skelland WCBC Agree with the housing projection based Whilst predicting employment on Welsh Governments projected land requirements is not a population increase 2011-2028 for definitive science, the 100ha Wrexham which is 20400. Disagree with proposed is a very simplistic the employment land allocation of 48ha approach and does not given that the existing Wrexham account for any qualitative Industrial Estate is 550 ha employing evidence. Furthermore, no 7000, suggest that the need on the evidence was submitted in Industrial Estate would be nearer 100 ha support of this proposal and it to cater for some of the 6900+ jobs would require a higher level of required. housing provision. 1939 Howard Cartwright David Cartwright I can see no adequate reason to differ Noted. However, no reasoning Solicitor from the Welsh Government 5 years or justification is given for this. migration (principal) household Background Paper 1 of the projection. evidence base provides reasoning for the other projections considered.

97 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response 3095 Carl Richards Local Resident I know from experience that many of the Noted. However, comment is key settlement areas are already over- not relevant to this section. burdened in their infrastructure, and to add more housing in those areas could result in major difficulties for both the people living in those communities and the public services which will have to cope with the problems. For example, in the past 40 years the Gwersyllt area has expanded massively and still further in the past 10 years. It is true to say that the roads, utility structures, health services and schools are now at or above saturation levels in some parts and the prospect of further large-scale building work in this key settlement area is difficult to accept. The council will recall the animosity generated when some of the more recent building projects were in progress. This problem has been seen in the other named key settlement areas. There is a natural limit to the expansion of these key settlements and it is important that we recognise that, and propose either building in other areas or consider creating brand new key settlements if necessary.

98 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response 5623 Mr M Gilbert, The on behalf of Redrow Whilst we understand the basis of the Noted. Before testing different Planning Consultancy Homes Ltd methodology employed, we do not think growth scenarios for the that it is appropriate to base the County Borough consideration calculations on migration assumptions was given to the factors which which relate to the period of recession influence change, including the (see the WG Minister's comments at demographic profile of para 2.5 of your Background Paper no. Wrexham, economic growth; 1). We also note your comments within the Inspector’s the Background Paper (paras 3.5 and recommendations for the 5.8) that migration was not depressed withdrawn 2006-2021 LDP and during this period in Wrexham, however, the Council’s aspirations for we do not think it is reasonable to the new LDP. conclude that the recession had no impact on migration during this period, the more logical approach is that whilst the migration rates remained generally constant, without the recession they would in all probability have been higher. Consequently, a more appropriate approach would be to adopt a higher migration rate which would more logically relate to a period of growth, which in our view is what we should be planning for; this would result in a higher requirement for housing and employment land. 6531 Guy Evans Cassidy and Ashton Strategic Growth Option B has the Noted. potential to result in a shortfall in housing land supply and go against the findings of the Planning Inspector. Perusing Strategic Growth option B may result in the plan being found ‘unsound’ by a Planning Inspector during examination. 6910 Tim Stratton Wrexham Local Appendices 1 and 2 do not appear to, Noted. See response to Q.6. Access Forum historically, support the projections. 7081 David Metcalfe Plas Kynaston Canal This is a little bit better than option A, Noted. However, none of the Group however a lot of the county is still left out. growth options refer to any specific part of the County 99 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response Borough.

7628 Steve Jackson Coleg Cambria 2011 based 5 year projection figures Noted. However, no reasons need to be reviewed. Sufficient housing are given for this. New required to meet projected demand. projections, when they are published by Welsh Government will need to be accounted for. The next projections due will be 2013 based. 7732 Matt Ferguson Brymbo Whichever Growth Option is selected it is Noted. Developments Ltd apparent from past housing completions (Appendix 2) that the Council needs to be fully supportive of all sustainable development proposals if any of the projections are to be met.

8298 Leslie Smith L S Planning Ltd Please see previous comment See response to Q.6.

100 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders Whilst we understand the basis of the Noted. Before testing different Federation (HBF) methodology employed, we do not think growth scenarios for the that it is appropriate to base the County Borough consideration calculations on migration assumptions was given to the factors which which relate to the period of recession influence change, including the (see the WG Minister's comments at demographic profile of para 2.5 of your Background Paper no. Wrexham, economic growth; 1). We also note your comments within the Inspector’s the Background Paper (paras 3.5 and recommendations for the 5.8) that migration was not depressed withdrawn 2006-2021 LDP and during this period in Wrexham, however, the Council’s aspirations for we do not think it is reasonable to the new LDP. conclude that the recession had no impact on migration during this period, the more logical approach is that whilst the migration rates remained generally constant, without the recession they would in all probability have been higher. Consequently, a more appropriate approach would be to adopt a higher migration rate which would more logically relate to a period of growth, which in our view is what we should be planning for; this would result in a higher requirement for housing. We also note that this results in a housing requirement below that of the 11, 800 recommended by the inspector in the previous withdrawn LDP. 8409 Rhian Harris HOW Planning on No consideration appears to have been Noted. Before testing different behalf of Kingmoor given to local circumstances in relation to growth scenarios for the Park Properties Ltd these options. They rely on the 2011 5 County Borough consideration and 10 year migration based household was given to the factors which projections only. influence change, including the demographic profile of Wrexham, economic growth; the Inspector’s recommendations for the

101 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response withdrawn 2006-2021 LDP and the Council’s aspirations for the new LDP

8412 Helen Howie Berrys on behalf of These household projections are the Noted. Tony Jones and most robust currently available, and Richard Tomlinson demonstrate the success of Wrexham County Borough as a place that people wish to live in. 8430 Susan Evans WCBC, CYP Service, No specific comments made, group Noted. PSC Department agreed with the figures and rationale as presented. 8452 Helen Howie Berrys on behalf of R These household projections are the Noted. & C Homes most robust currently available, and demonstrate the success of Wrexham County Borough as a place that people wish to live in. 8455 Michael Dixon local resident Option A is the more forward looking and Noted. so to be preferred. WCBC would also run the considerable risk of not providing adequate housing again.

8456 Maureen Williams Local resident Over optimistic projections for additional Noted. Projecting employment homes based on employment and housing land requirements assumptions rather than hard data. can never be accurate. However, hard facts are used together with realistic assumptions about them in order to predict what the future requirements might be. 8467 Gill Wilson Butterworth Local Resident Wrexham needs jobs and houses, I hope Noted. this plan is viable.

102 Wrexham LDP – Issues and Options Consultation Responses Q.7. Comments on Option B and Officer Responses ID Name Organisation Comments Officer Response 8468 Vincent Ryan Barton Wilmore On Although the approach avoids replicating Noted. Behalf of Barratt a period of poor growth given that Developments PLC Wrexham 'bucked the trend' and experienced high population growth over the recession with migration not being depressed during this time, there is concern that the household projections are recessionary based and have been suppressed by the historic under supply of housing, affordability and lack of employment. The Welsh Government projections are therefore likely to have under-estimated future housing requirements in Wrexham. The evidence sets out that migration has halved to what it was annually over the 5 and 10 year basis - therefore concerned that this will result in an unreliable evidence base - since migration was not depressed in Wrexham during the recession, the 2011 based projections remain recessionary based. The failure of options B and C to align with the economic growth aspirations of the LDP is a significant case against them. 8469 Wendy Sime Local Resident As above. See response to Q.6.

103 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses

Q8. Comments on Option C

ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd See response to Q6. Similar to the Noted. reasons explained in our response to Q7 (Option B), we consider Option C’s growth expectations to be far too low and unrealistic. Not only do we consider in- migration to be directly related to economic growth potential, and as the economy improves at pace, in-migration to increase with it, but we believe other housing factors including latent demand, housing choice and offer, can all add to housing growth, and these have been missed from the projection’s growth context. 169 Philip Mc Cormick RIBA Mc Cormick See Comments on Option 'A' See response to Q.6. Architecture Ltd 257 Cllr Brian Cameron WCBC Whitegate As per previous question 7 See response to Q.7. Ward 265 Michael Dixon Coedpoeth Option A is the more forward looking and Noted. Community Council so to be preferred. WCBC would also run the considerable risk of not providing adequate housing again.

292 Krista Childs WCBC As before See response to Q.6. 304 Dr Denis Edwards Local Resident New infrastructure requirements would Noted. However, as the be too great and use of cars would be proposed housing and greater under this option. employment requirements under this option are the lowest of the 3, the impact referred to would be the least under this option. 438 Cllr Graham Rogers WCBC - Local Same as option A. See response to Q.6. Councillor

104 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses ID Name Organisation Comments Officer Response 463 Ms Karen Benfield Offa Community Page 18 Table 6 - the figures for the past Disagree. The past 5 years Council 5 years are most relevant - claims for reflect a recessionary period. options A and B are over stated. 483 Cllr Marc Jones Caia Park Community Housing numbers are still too high and Noted. Before testing different Council based on top down projections rather growth scenarios for the than bottom up community need and County Borough consideration demand. Employment allocations too was given to the factors which ambitious based on previous completions influence change, including the over many years whilst it may provide demographic profile of flexibility it should not be linked to Wrexham, economic growth; housing requirements. Past growth a the Inspector’s prefect story of 1) EU Migrants 2) recommendations for the Glyndwr University expansion 3) withdrawn 2006-2021 LDP and Overflow from Chester - to be repeated. the Council’s aspirations for the new LDP. 639 Mr Steve Jones Llangollen Railway Enhanced non-car dependent transport Noted. Not relevant to this infrastructure to the outlying village question. communities would strengthen the potential growth for this option. 1939 Howard Cartwright David Cartwright I am not sure this will be an adequate Before testing different growth Solicitor forward provision of housing capacity, scenarios for the County given the gradual fall in median Borough consideration was household size, plus the projected given to the factors which increases in number of elderly residents influence change, including the and population generally. demographic profile of Wrexham, economic growth; the Inspector’s recommendations for the withdrawn 2006-2021 LDP and the Council’s aspirations for the new LDP.

105 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses ID Name Organisation Comments Officer Response 3095 Carl Richards Local Resident Option C has the advantage of No, not necessarily. As this recognising the need to spread the option is lower it may not availability of new facilities to the more achieve this. Also it only remote parts of our county. If we do not relates to figures, it does not improve the housing and employment in specify where development will the more outlying areas then we run the go. risk of recreating our very own North/South divide on a local scale, with Wrexham town being the London of the area and the rest of the country/county complaining about the lack of investment that it gets. 5623 Mr M Gilbert, The on behalf of Redrow Our comments on this option are very Noted Planning Consultancy Homes Ltd similar to those in relation Option B, whilst the period is longer, it nevertheless, also includes the period of recession. The fact that the resulting figures are lower suggests that it reflects a period where, in part due to planning policies pertaining at the time, growth was unrealistically constrained, this does not provide an adequate reflection of circumstances that we should seek to plan for in the future in order to positively address problems of affordability. 6531 Guy Evans Cassidy and Ashton Strategic Growth Option C would almost Noted. certainly result in a significant shortfall in housing land supply and go against the findings of the Planning Inspector. Perusing option c would likely result in the plan being found ‘unsound’ by a Planning Inspector during examination. 6910 Tim Stratton Wrexham Local Appendices 1 and 2 do not appear to, Noted. See response to Q.6. Access Forum historically, support the projections.

106 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses ID Name Organisation Comments Officer Response 7081 David Metcalfe Plas Kynaston Canal Of the three options offered in the LDP Noted. However, it is not Group this would seem the most sensible. necessary at this stage to However although housing numbers are show how employment clearly stated it is not shown how opportunities or ‘anything else’ employment opportunities or anything will be provided. This will else that is referred to is going to be come at a later stage of the provided for or created other than Plan. quoting land areas etc., which in the case of Cefn Mawr are incorrect. 7628 Steve Jackson Coleg Cambria Sufficient housing required to meet Noted. Assume this to be forecast demand. ‘sufficient housing is required’. 7732 Matt Ferguson Brymbo Whichever Growth Option is selected it is Noted. Developments Ltd apparent from past housing completions (Appendix 2) that the Council needs to be fully supportive of all sustainable development proposals if any of the projections are to be met. 8298 Leslie Smith L S Planning Ltd Please see previous comment See response to Q.6. 8408 Mark Harris Home Builders Our comments on this option are very Noted. Federation (HBF) similar to those in relation Option B, whilst the period is longer, it nevertheless, also includes the period of recession. The fact that the resulting figures are lower suggests that it reflects a period where, in part due to planning policies pertaining at the time, growth was unrealistically constrained, this does not provide an adequate reflection of circumstances that we should seek to plan for in the future in order to positively address problems of affordability. We also note that this results in a housing requirement below that of the 11, 800 recommended by the inspector in the withdrawn LDP.

107 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses ID Name Organisation Comments Officer Response 8409 Rhian Harris HOW Planning on No consideration appears to have been Noted. behalf of Kingmoor given to local circumstances in relation to Park Properties Ltd these options. They rely on the 2011 5 and 10 year migration based household projections only. 8412 Helen Howie Berrys on behalf of The 10 year projection is less robust, and Noted. Before testing different Tony Jones and does not fully consider the inflow of growth scenarios for the Richard Tomlinson people moving to Wrexham County County Borough consideration Borough. Migration flows reflect the was given to the factors which success of the County Borough as an influence change, including the attractive place to live, and should be demographic profile of embraced. In any event, people will Wrexham, economic growth; continue to migrate to Wrexham CB and the Inspector’s to ignore this fact will simply lead to an recommendations for the increase in house prices and under- withdrawn 2006-2021 LDP and provision of infrastructure and the Council’s aspirations for employment opportunities. the new LDP. 8430 Susan Evans WCBC, CYP Service, No specific comments made, group Noted. PSC Department agreed with the figures and rationale as presented. 8452 Helen Howie Berrys on behalf of R The 10 year projection is less robust, and Noted. Before testing different & C Homes does not fully consider the inflow of growth scenarios for the people moving to Wrexham County County Borough consideration Borough. Migration flows reflect the was given to the factors which success of the County Borough as an influence change, including the attractive place to live, and should be demographic profile of embraced. In any event, people will Wrexham, economic growth; continue to migrate to Wrexham CB and the Inspector’s to ignore this fact will simply lead to an recommendations for the increase in house prices and under- withdrawn 2006-2021 LDP and provision of infrastructure and the Council’s aspirations for employment opportunities. the new LDP. 8455 Michael Dixon local resident Option A is the more forward looking and Noted. so to be preferred. WCBC would also run the considerable risk of not providing adequate housing again.

108 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses ID Name Organisation Comments Officer Response 8456 Maureen Williams Local resident Whilst closer to the mark, the Noted. employment forecast is not evidence based and is unlikely to be achieved bearing in mid future projections of a decline in manufacturing as more businesses develop capacity in Africa and Asia, Jobs in the digital economy will need our most talented and gifted people to remain in Wrexham and not move to better paid jobs in England which is now the case. 8468 Vincent Ryan Barton Wilmore On Although the approach avoids replicating Noted. Before testing different Behalf of Barratt a period of poor growth given that growth scenarios for the Developments PLC Wrexham 'bucked the trend' and County Borough consideration experienced high population growth over was given to the factors which the recession with migration not being influence change, including the depressed during this time, there is demographic profile of concern that the household projections Wrexham, economic growth; are recessionary based and have been the Inspector’s suppressed by the historic under supply recommendations for the of housing, affordability and lack of withdrawn 2006-2021 LDP and employment. The Welsh Government the Council’s aspirations for projections are therefore likely to have the new LDP. under-estimated future housing requirements in Wrexham. The evidence sets out that migration has halved to what it was annually over the 5 and 10 year basis - therefore concerned that this will result in an unreliable evidence base - since migration was not depressed in Wrexham during the recession, the 2011 based projections remain recessionary based. The failure of options B and C to align with the economic growth aspirations of the LDP is a significant case against them.

109 Wrexham LDP – Issues and Options Consultation Responses Q.8. Comments on Option C and Officer Responses ID Name Organisation Comments Officer Response 8469 Wendy Sime Local Resident We are not in a position to judge the Disagree. The options are all accuracy of the figures but as all these based on evidence. No options are educated guesses, our guess evidence has been submitted would be that option C is realistic. with this comment to justify why option c is the most realistic. 8293; Janet Radford AVOW, Public Health Neither AVOW nor the Public Health Noted. However, this comment 237; Wales, Wrexham Commissioning Group member is not relevant to this question. 7075; County Borough organisations have a particular viewpoint 8309 Council Health on growth projects, however we do have Promotion - working the following observations: There is a together through need to ensure that homes are built to Public Health lifetime standards that all development Commissioning Group should be of mixed tenure to promote diverse cohesive communities. There is a need for more rental accommodation and smaller units for single householders (notwithstanding the need for space for visitors/non-resident children to stay). Important services (health, education, shops, community facilities etc.) should be accessible. Residential developments should include ample space for and encourage through design the uptake of play and physical activity.

110 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses

Q9. Reasons/comments for preferred Growth Option

ID Name Organisation Preferred Comments Officer Response Option 67 Mike Jenkins Wrexham County A As outlined in previous page Noted. Borough Council - Strategic Housing Services 145 Dewi Griffiths Dwr Cymru Not DCWW has no real preference regarding Noted. The Council will Welsh Water answered. the strategic growth options being continue to consult with Welsh considered by the Wrexham Local Water as the Local Development Plan (LDP) 2013-2028. As a Development Plan progresses. provider of sewerage infrastructure in the County we are primarily governed by the Water Industry Act 1991 (as amended) whereby we have a duty to extend and improve our assets to accommodate future growth. We aim to ensure that sufficient infrastructure exists for domestic development, and we seek to address deficiencies through capital investment in our 5 year Asset Management Plans (AMP). DCWW have to put forward a business plan for investment for each AMP cycle, and as part of this work we require some certainty in terms of growth areas and site development proposals. An adopted Local Development Plan with identified growth options helps strengthen the case Welsh Water can put forward in relation to projects requiring AMP funding. Our industry regulator, Ofwat, do not usually provide investment for infrastructure to serve unconfirmed growth.

111 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 155 Justin Paul J10 Planning Ltd A Our preferred Option is A, but we Noted. categorically believe this to be too low. Specifically it needs to be considered in the context of: • latent demand that has been building over the last 15 years due to restrictive Green Barrier policy which has resulted in under delivery of housing; • Improved economic growth potential based on new and constantly improving projections. We understand that the UK economy is picking up pace far quicker and more robustly than even National Government had anticipated, and is leaving the rest of Europe behind. This will directly improve Wrexham’s economic position, especially given the town’s National standing within Wales, where it is clear investment, infrastructure and business opportunities are focused; • New investment potential including gaining Welsh Government funding for regeneration initiatives though the Vibrant and Viable Places (VVP) programme with almost £11m being provided via the grant, and private investment support in the region of £14m; and a masterplan for Wrexham Town Centre; the Super Prison, success stories such as Moneypenny and the fact that new investment is being attracted to the County Borough , will add to strengthen the robustness and attractiveness of the town which will improve its economic position further and result in more housing demand; and • LDP Vision and Objectives which strive to Strengthen Wrexham Town as a key settlement of national importance with a 112 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option focus for investment in future employment, housing, retail, leisure and services. Therefore, strong growth projections need to be embedded within the Option to necessity high growth targets, as a means to achieving the aspirations set by the Authority. Wrexham needs to compete within North Wales and NW of England - it is a key service hub and must be allowed to punch (above) its weight; the lack of ambition expressed in the Options is disappointing and nothing less than Option A should be advanced. Please also see our comments to Q6 - Q8 above.

169 Phillip Mc Mc Cormick A See comments re : Question 6 Noted. Cormick RIBA Architecture Ltd 181 Barbara ref Robin Morris, A A moderate plan with room for flexibility. Noted. Blanchard Guy Woodcock Surveyors 247 Arfon Jones WCBC Local A Inclined to support Option A (Employment Noted. However, the Councillor led Projection) although the provision of comments seem to indicate 13,010 new homes is too high a target and support for option C. recommend the implementation of a revised, more achievable target of 10,000 new homes. 257 Cllr Brian WCBC Whitegate A as already instructed in option a Noted. Cameron Ward 265 Michael Dixon Coedpoeth A Option A allows for greater growth and it is Noted. Community for such growth that we should be Council planning, lest we risk greater failure in the County Borough. WCBC has the opportunity to strike forward and should do so.

113 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 292 Krista Childs WCBC Not If I have understood correctly none at this Noted. answered stage - See 5.4 as data sets continually updated need to be taken into account - allowing for flexibility

293 Cllr David WCBC - local Not None NA Kelly councillor answered 304 Dr Denis Local Resident B See above and the primary key Noted. However, the comment Edwards settlements would benefit or would benefit is not relevant to this question. from new services which would come with increased population of these areas. 403 Penelope S J Overton C It is important that people should reside Noted. Although comment is Coles Community not too far away from their place of work. not relevant to this question. Council 436 Peter Mullen Gwersyllt A Although the Council is inclined to support Noted. However, the Community Option A (Employment led Projection), it comments suggest that Option Council considers that the provision of 13,010 new C is the preferred choice. homes is too high a target and recommends the implementation of a revised, more achievable target of 10,000 new homes. 438 Cllr Graham WCBC - Local C I feel this option C is a realistic one. Noted. Rogers Councillor 463 Ms Karen Offa Community B In favour of more affordable housing in Noted. Benfield Council best locations to meet the needs of the people of Wrexham. 483 Cllr Marc Caia Park Not Unrealistic to expect housing to treble or Noted. Assumed that Jones Community answered quadruple from current level given reference to ‘A’ as being the Council anticipated public sector cuts. The lowest lowest should be ‘C’. option (option a) is the least objectionable.

114 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 639 Mr Steve Llangollen B This option reduced pressure on the Noted. However, comment is Jones Railway central urban core Wrexham Town area, not relevant to the question. and gives a more balanced development growth pattern around the supporting outlying centres of the county area, helping to strengthen the peripheral village community economies. 769 Cllr Rodney WCBC B WG 2011-2028 population increase Noted. However based upon Skelland projection for Wrexham is almost 20500 the comments, this would which would suggest that new homes mean that option A is figure is about right, though the 2001-2011 preferable if 48ha is LDP never had the opportunity to be considered inadequate and implemented properly and a substantial should be doubled. housing shortfall carryover has been experienced plus 14000 migrant workers coming to NW 2004-2008 most coming to North East Wales (Police figures) not recorded in the census (big increase in HMO's and rented property demand). 48ha of employment land is woefully inadequate, Wrexham Industrial Estate employs just over 7000 people and is 550 ha, over £30 million spent by WG on improving accessibility to cater for population increase employment, I would suggest no Welsh Government "driven" LP Inspector would accept 48ha as adequate employment land and should be at least doubled even at this stage in the consultation document. 1930 Carys Wynne- Arts Council of Not We would encourage you to work with a Noted. Williams Wales answered range of communities across the county to capture their voice as part of this planning phase,

115 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 1939 Howard David Cartwright B It would be hard to categorise this growth Noted. Although second part of Cartwright Solicitor option as inadequate to meet the projected comment is not relevant to this population increase. Drainage impact question. outside the County Borough also has to be borne in mind. All run -off arrives in the lower Dee and capacity to sustain the continued expansion of Wrexham will at some point require works outside/not wholly within Wales. 3095 Carl Richards Local Resident C Option A offers what appears to be an Noted. Although, a full easy solution to our development explanation why option C problems, but masks the many issues would spread development which will result from over-burdening our across the County Borough is key settlement communities. Option B is not given. flawed as it does not even recognise that there are 'cons' to those proposals. I believe that many of our key settlements are approaching or beyond their saturation points and to increase their burdens even more will make them unattractive and create more social problems. Despite some drawbacks option C has to be the preferred option since it will spread development more widely across the borough whilst still looking to maximise development in the centre of Wrexham town.

116 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 5623 Mr M Gilbert, on behalf of A Our preference for Option A is subject to Noted. The Planning Redrow Homes our comments in relation to the need for Consultancy Ltd the figure to be increased to reflect a greater need for housing and employment during the emerging Plan period, given that the recession now appears to be ending. However, we note the previous LDP Inspector's comments about the desirability of providing for consistency between economic growth aspirations and dwelling requirements and further note that economic growth aspirations underpin the Council's emerging approach (paras 3.30 - 3.34 of Background Paper 1). Against this background, it is clear that neither of the migration lead Options match housing growth with realistically achievable rates of economic growth and would, therefore, result in a disjointed approach, potentially resulting in the promotion of unsustainable patterns of land use which could increase commuting, constrain the level of growth that could otherwise be achieved, and increase pressure on the housing market. 6531 Guy Evans Cassidy and A As set out above (see answer to Q.6) Noted. Ashton Strategic Growth Option A is the only option that will satisfy the findings of the Planning Inspector and the only option which could with confidence lead to an adopted ‘sound’ Plan. 6533 Charlene Carter Jonas A A strong economy will encourage people Noted. Sussums- to stay and move into the County, this Lewis should include strengthening the rural enterprises and economy.

117 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 6910 Tim Stratton Wrexham Local C This is the most conservative (realistic?) Noted. Access Forum option. 7081 David Metcalfe Plas Kynaston C Of the three options offered in the LDP this Noted. Canal Group would seem the most sensible. However although housing numbers are clearly stated it is not shown how employment opportunities or anything else that is referred to is going to be provided? 7474 Mr Peter Guy Local Resident B If we build too many houses then many of Noted. our green spaces will gradually be eroded away. 7732 Matt Ferguson Brymbo A The Council has committed to the Noted. Developments promotion of its major industrial estate and Ltd to significant employment opportunities on the outskirts of Wrexham. Unless sufficient housing is provided within the Borough to satisfy the employment demand, the economic benefits of employment provision will be exported out of the Borough. 8298 Leslie Smith L S Planning Ltd A Please see previous comment Noted. 8408 Mark Harris Home Builders A Option A is the only option which delivers Noted. Federation (HBF) both the housing requirement and Employment land that was suggested to be appropriate by the Inspector at the previously withdrawn LDP Inquiry. It is the only option which is based on an aspirational plan and one which meets many of the needs identified by the various topic and background papers. It also sets targets which reflect the Councils role in the wider region both in employment terms but also in the closely linked need for more housing.

118 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 8409 Rhian Harris HOW Planning on A Option A is based on an employment led Noted. behalf of projection which will support the Council's Kingmoor Park economic growth aspirations and vision of Properties Ltd a strong, resilient economy, responsive to its strategic location within North East Wales. It also responds to local evidence, the Employment Land Review, which demonstrates the demand and need to allocate further employment land at Wrexham Industrial Estate. Option A is therefore strongly supported. 8411 Kate McClean Taylor Wimpey A We support the employment led projection Noted. that supports housing growth to complement the Council's economic strategy. 8412 Helen Howie Berrys on behalf A Economic growth should be seized with Noted. of Tony Jones both hands for the benefit of all Wrexham's and Richard residents. Tomlinson 8430 Susan Evans WCBC, CYP A The preferred option is option A, however Noted. Service, PSC more information would need to be Department provided on the areas of Greenfield to be developed.

119 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 8449 Michael Gower Homes A Option A for 2 main reasons 1. As a Noted. Forgrave Wrexham resident for the whole of my life I would like to see Wrexham grow as much as possible in order that it can compete better in economic terms, with other major employment centres in North Wales and N.W. England. 2. As an SME local house builder (SME house builder as described by NHBC as one who builds less than 100 units a year), I do believe that the larger the number of sites that are available to build upon gives the smaller and medium local builders more of a chance to access development land. 8451 Penelope S J Overton Local C It is important that people should reside Noted. Although comment is Coles Access Forum not too far away from their place of work. not relevant to this question. 8452 Helen Howie Berrys on behalf A Economic growth should be seized with Noted. of R & C Homes both hands for the benefit of all Wrexham's residents. 8455 Michael Dixon local resident A Option A allows for greater growth and it is Noted. for such growth that we should be planning, lest we risk greater failure in the County Borough. WCBC has the opportunity to strike forward and should do so. 8456 Maureen Local resident Not None of them, for the reasons I have See response to Q.6. Williams answered pointed out. 8467 Gill Wilson Local Resident B Rural enterprises and building Noted. However, the comment Butterworth programmes should also be included. is not relevant to this question. Brown sites should be given special consideration together with change of use from commercial to housing in the town centre. 8468 Vincent Ryan Barton Wilmore A Option A will deliver the greatest social Noted. On Behalf of and economic benefits for Wrexham (also Barratt see response to Q.6). 120 Wrexham LDP – Issues and Options Consultation Responses Q.9. Reasons/Options for Preferred Growth Option and Officer Responses ID Name Organisation Preferred Comments Officer Response Option Developments PLC

8469 Wendy Sime Local Resident C In the present economic climate jobs Noted. growth is very slow. We cannot see the economy picking up dramatically over the next 15 years so we think a projected figure of 6000 new jobs in the county is adequate

8293; Janet Radford AVOW, Public B Following the discussions at the Key Noted. 237; Health Wales, Stakeholder Forum this seems to be the 7075; Wrexham County preferred option. 8309 Borough Council Health Promotion - working together through Public Health Commissioning Group

121 Wrexham LDP – Issues and Options Consultation Responses Q.10. Other Suggested Growth Options and Officer Responses

Q10. Other Suggested Growth Options

ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd But increased to 120 ha (8 ha/yr) of Noted. Before testing employment land and 14,175 (945/yr) different growth scenarios for dwellings and expressed as minimums. the County Borough Please see out comments to Q6 to Q9 consideration was given to the above. Highest past completions factors which influence (945/year) were discounted because “all change, including the levels of growth are significantly above demographic profile of those which would be sustainable within Wrexham, economic growth; the aspiration of the proposed LDP”. the Inspector’s Surely this can only be properly asserted recommendations for the if tested and Objectively Assessed withdrawn 2006-2021 LDP and against need and certainly one would the Council’s aspirations for expect the evidence and steps taken to the new LDP. arrive at this conclusion. We would therefore ask that this is explored further and the aforementioned evidence is provided to demonstrate why this is unsustainable. It is our opinion that this figure is far more typical than recent trends founded between 2007-2014 for which the global economic recession was unprecedented in its length and deep- rooted adverse impact. Through proper comprehensive planning (e.g. master planning), it is possible to deliver well thought-out major housing land allocations that can be sustainable, significantly improving infrastructure (highways, education, health, recreation/leisure), and the overall benefit to the community. Creating such critical mass provides a more realistic opportunity to create sustainable communities, unlikely smaller 122 Wrexham LDP – Issues and Options Consultation Responses Q.10. Other Suggested Growth Options and Officer Responses ID Name Organisation Comments Officer Response incremental development proposals. Larger schemes can finance the required infrastructure needed to support communities and can properly manage into schemes, community facilities and other land uses. We believe that these past trends should be given greater weight, and should at least be explored further. Such potential to meet these past completions is plausible given the economy’s recent pace of recovery; the latent demand for housing created by restrictive Green Barrier Development Plan Policy; new investment in Wrexham; and likely continued in-migration. The Authority has failed to test any ambitious "step-change" employment policy and without testing this it is difficult for them to discredit why 8 ha per annum should not be used. 169 Phillip Mc Cormick RIBA Mc Cormick Should consider all options and reach Altogether, sixteen different Architecture Ltd. the most flexible solution. growth options were considered before selecting the three which are presented for this consultation.

181 Barbara Blanchard ref Robin Morris, Guy Consideration of reusing derelict land for Noted. However, comment is Woodcock Surveyors starter homes where former dwellings not relevant to this question. existed. 265 Michael Dixon Coedpoeth The only other possibility would be to Noted. Community Council consider further development, over and above Option A. I do not have the skills to identify further growth, but anything less risks stultification. 292 Krista Childs WCBC As before See response to Q.9. 438 Cllr Graham Rogers WCBC - Local Cannot think of any at the present time. Noted.

123 Wrexham LDP – Issues and Options Consultation Responses Q.10. Other Suggested Growth Options and Officer Responses ID Name Organisation Comments Officer Response Councillor 483 Cllr Marc Jones Caia Park Community Organic growth model based on past Noted. However, it is not clear Council completion rates (see table 6) 8, 10 and exactly what is meant by the 13 year model = 430 per annum. This comment. would mean rejecting Welsh Govt. Projections. 639 Mr Steve Jones Llangollen Railway Enhanced non-car dependent transport Noted. Assumed that infrastructure to the outlying village comment relates to option B. communities would strengthen the Comment is not relevant to this potential growth for this option. For question. example the reintroduction of a branch railway between Ruabon and Trevor would strengthen the economic growth potential of the peripheral communities of Trevor, Garth, Fron, Acrefair, Cefn, and Plas Madog, open up existing and proposed new affordable housing to commute to work opportunities in the wider Wrexham/Chester/Shrewsbury/Liverpool/ Birmingham corridor and strengthen potential for greater inward tourism to the Pontcysyllte World Heritage Site. In the shorter term the introduction of a parallel footpath/cycle track along the former railway alignment between Ruabon Junction and Llangollen would provide a sustainable green transport link enabling safe routes to schools use as well as enhanced recreation and tourism functionality. 5623 Mr M Gilbert, The on behalf of Redrow Subject to our comments on the way in Noted. Planning Consultancy Homes Ltd which the three identified Options ought to be revised.

124 Wrexham LDP – Issues and Options Consultation Responses Q.10. Other Suggested Growth Options and Officer Responses ID Name Organisation Comments Officer Response 7081 David Metcalfe Plas Kynaston Canal There needs to be more information Noted. However, comments Group provided on how employment proposals not relevant to question. can be improved and transport links to such from residential areas. The employment prospects must also be real jobs and not a raft of meaningless quangos for local authorities. The PKC Group will be making site specific recommendations for Cefn and central section of the Pontcysyllte WHS for inclusion in the LDP which will directly address this, as was the case in the previous LDP. 7628 Steve Jackson Coleg Cambria A possible hybrid option between A and Noted. However, it is not clear C. what figures are being proposed or what justification is being used. 7734 John Small DMR (North Wales) Wrexham's only real problem is Noted. However, comments Ltd. employment - employment has to be the not relevant to question. driver; get people off benefits, off drugs & alcohol and into a job . . . even if it's just a couple of hours a day picking up litter or helping the elderly.

125 Wrexham LDP – Issues and Options Consultation Responses Q.10. Other Suggested Growth Options and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders We consider that the plan should be Noted. However, not clear Federation (HBF) even more aspirational and send out a what is meant in the last two message to the wider region that sentences. In reference to the Wrexham wants to provide both last sentence, this approach employment and housing opportunities. would probably result in lower We consider there are a number of ways numbers. this could be done: We have identified some small increases in the housing figure due to mathematical clarifications. A more aspirational approach could be taken to the provision of employment land particularly around the Wrexham Industrial estate, any increase in employment land would lead to an increase in housing numbers if Growth Option A is chosen. Use a lower household size figure which would be a more positive approach to the future, another option would be to take the average between the 2008 and 2011 figure thus reflecting both trends. 8455 Michael Dixon local resident The only other possibility would be to Noted. consider further development, over and above Option A. I do not have the skills to identify further growth, but anything less risks stultification. 8456 Maureen Williams Local resident At the end of the day the evidence base This paper was produced by as provided by Conwy County Council is the weak and unsubstantiated. More sticking Senior Researcher from the your finger in the air to predict rain than Corporate Research and fact based, HS2 and regional Information Unit, Conway development in North West will increase who has experience of migration out of Wales unless we producing growth options address the issue of rail and road papers for her own transport making it easier for workers to Planning Authority and for access employment in England but Denbighshire Council, as well continue to live in the principality. as providing

126 Wrexham LDP – Issues and Options Consultation Responses Q.10. Other Suggested Growth Options and Officer Responses ID Name Organisation Comments Officer Response Planning related projections support to a number of other Planning Authorities in Wales. She is a founder member of Welsh Government’s Sub-national Projections Working Group (WASP). She was involved in devising the projections methodology used by Welsh Government and has over 20 years of experience of demographic research in North Wales. She is also a member of the Office for National Statistics’ Central and Local Government Information Partnership advisory group on population, and is a long standing member of the POPGROUP1 Steering committee. Altogether, sixteen different growth options were considered before selecting the three which are presented for this consultation.

8468 Vincent Ryan Barton Wilmore On Please see attached letter ref NA Behalf of Barratt 23774/A5/LD/VR for further comments. Developments PLC None stated.

127 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses

Q.11 Comments on Spatial Option 1 - Primary Key Settlement (Wrexham Town) Focussed including Key Strategic Sites?

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County See final comments(Q.14) Noted. See response to Q.14. Borough Council - Strategic Housing Services 145 Dewi Griffiths Dwr Cymru Welsh In terms of the Spatial Options for Noted. The Council will Water Growth, we have initially examined the continue to consult Dwr potential impact on our assets and offer a Cymru Welsh Water high level response. Once detailed throughout the LDP process. information is available as to the specific growth figures and the location of potential development sites we will then be in a position to provide you with additional representation. The town of Wrexham is served by Five Fords Wastewater Treatment Works (WwTW). Capacity exists at the treatment works however depending on the total amount of growth proposed for the catchment area improvements may be required at the WwTW later on in the plan period to provide further capacity. DCWW aim to ensure that sufficient infrastructure exists to accommodate domestic development, however where deficiencies are identified we look to resolve these through capital investment in our Asset Management Plans (AMP). We are currently beginning the AMP6 programme which covers investment for the period 2015-2020, this will be followed by AMP7 for the investment period 2020-25, and AMP8 for 2025- 2030. The Wrexham LDP has a 128 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response timeframe that runs until 2028, therefore any investment required at our WwTWs can be scheduled into future AMPs. Where specific infrastructure improvements are required to allow a development site to proceed, but where there are no current plans for investment through the AMP, there are provisions available for developers to make financial contributions, via planning obligations under the provisions of S106 Town & Country Planning Act 1990, to secure the necessary improvements. DCWW will work with your Authority, through assessing Joint Housing Land Availability Studies, to understand and monitor the rate of growth within the LDP area to assist us in submitting our plans for funding to deliver the required infrastructure necessary to meet future growth. There are incidents of flooding in the public sewerage system in Wrexham that, depending on the location of the proposed growth, may need to be resolved to allow development to proceed. Potential developers can either wait for DCWW to resolve these flooding incidents, subject to funding being approved by our regulator Ofwat, or progress the improvements through the sewerage requisition provisions of the Water Industry Act 1991. Hydraulic modelling assessments may be required to determine an adequate point of connection to the public sewer, particularly for strategic development sites, and potential developers would be expected to fund investigations during 129 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response pre-planning stages. The findings of a hydraulic modelling assessment would identify the extent of any necessary upgrades to the sewerage network which can be acquired through the sewer requisition provisions of the Water Industry Act 1991 (as amended).

155 Justin Paul J10 Planning Ltd Please refer to our response to Q14 and Noted. See response to Q.14 Q15. & Q.15 169 Phillip McCormick Mc Cormick Too much emphasis on Wrexham itself Noted RIBA Architecture Ltd to detriment of other settlements/villages.

181 Barbara Blanchard ref Robin Morris, Guy Where existing utilities already cross land Noted Woodcock Surveyors there is lower disruption to communities and lower cost to the development.

257 Cllr Brian Cameron WCBC Whitegate Each planning application to be Noted. Each planning Ward determined on its own merits. application is treated on its 130 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response own individual merits taking into account all material considerations. 265 Michael Dixon Coedpoeth Too restrictive, risking (further) decay Noted. Community Council outside the town. 304 Dr Denis Edwards Local Resident Option 1 would reduce green areas in Noted. town too much and areas would lose their identity. 305 Mrs V Jones Marchwiel Community Redevelopment of 'old sites' could be Noted. Council included. 347 Steve Nott Abenbury Community The loss of a significant brown field site Noted. Council at the former Firestone site for the prison makes this inevitable 403 Penelope S J Coles Overton Community Wrexham town is already crowded Noted. Council enough. 438 Cllr Graham Rogers WCBC - Local In meeting the demands of the build of Noted. Councillor new homes I am of the opinion both brownfield and greenfield sites will have to be explored to deliver what is being envisaged to growth both in housing and employment requirements. 639 Mr Steve Jones Llangollen Railway The development strategy is too Noted. Wrexham core town focussed and may lead to degradation of the economic potential of the peripheral communities.

131 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 682 Coal Authority The Coal Authority has provided the LPA Noted. Consultation with the with information in respect of the defined Coal Authority will continue development High Risk Areas for coal throughout the LDP process. mining legacy and the Surface Coal resource plans. It is noted that the most up to date information provided by the Coal Authority was downloaded by the LPA on 13 November 2014 for both Development High Risk Areas and Surface Coal Resource. It is noted that the surface coal resource and past coal mining legacy is concentrated in the central part of the County Borough area. The Coal Authority would expect this information to inform the policy framework and the identification of site allocations. 769 Cllr Rodney Skelland WCBC Would impact on the long term Noted. sustainability of the surrounding communities in the county. 1939 Howard Cartwright David Cartwright This is likely to be the least expensive Noted. Solicitor option in terms of both developer and public authorities spending to realise development over the LDP period, but the implied neglect of other key settlement areas may well be unacceptable.

132 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 3095 Carl Richards Local Resident It is important to look further into the Noted. In relation to Planning future and acknowledge that to do so Policy Wales it is considered would only be a temporary solution since that the approach with national in another 20 years we will be back at policy Wales states that square one. Rather than ruin the development in rural areas of character of the key settlement the County Borough is in communities now we should plan more accordance with national carefully and simply create one longer- policy. term solution which I believe includes designing a new key-settlement in an area which can have the necessary infrastructure put in from the start rather than ad-hoc. 5623 Mr M Gilbert, The on behalf of Redrow It is clear to us that Wrexham Town is the Noted. Planning Consultancy Homes Ltd most sustainable location for additional growth and that there are also appropriate locational options for development to accommodate the likely scale of land release required. Development should be delivered through the allocation of large strategic sites in and around the main urban area of Wrexham, delivering new homes each year during the Plan period and beyond. Such sites have the added benefit of providing for the continuous provision of new homes throughout the Plan period which would assist in maintaining a deliverable five year housing land supply.

133 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 6531 Guy Evans Cassidy and Ashton In line with the number of new homes Noted. However it should be required in Strategic Growth Option A, noted that the Council is not Appendix 1 sets out how 6,060 homes considering site specific would be required on ‘Greenfield’ sites. allocations at this stage in the Given that Strategic Growth Option A is LDP process. considered the only viable option in terms of housing land supply it is submitted that a significant amount of greenfield land must be released for development. It was accepted at the Planning Inspectors hearing that there was no reason to believe that the character of the County was such that it could not accommodate the expansion of settlements. The Council accepts that delivering the scale of housing suggested by the Inspector would require allocating sites outside settlement limits. Accordingly the previously pursued strategy of confining development to within existing settlement limits requires reconsideration and the only viable option going forward is allocating sites outside the settlement limits, and on greenfield land. The largest greenfield areas of land capable of accommodating new housing lie immediately adjacent to, and outside the settlement limits of Wrexham, notably to its North West settlement boundary. It is submitted that this area has the greatest potential to accommodate new residential development of the scale required to address the significant shortfall in housing land supply. It is submitted that, in light of the above comments in relation to the broad location of development and the proposed housing 134 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response Guy Evans Continued. numbers, additional housing land allocations are required outside settlement limits for the purpose of the emerging LDP. Such an approach is (in part) consistent with that set out within Spatial Growth Option 1 and accordingly and element of support is put forward for this Option. However it is submitted that development should not in its entirety be limited to the Primary Key settlement of Wrexham Town. It is submitted that the ‘Key Settlements’ identified in Option 2 are well placed to accommodate an element of housing growth and should be considered in conjunction with the Primary Key Settlement (Wrexham Town). Accordingly a balanced approach to Spatial Growth is put forward (i.e. a combination of Options 1 and 2 but with a revised ‘extent’ of growth in respect of Wrexham Town. Such an approach would be consistent with para. 5.9 of the document which considers better related greenfield sites to the existing urban form to be more appropriate to accommodate housing growth than those with poor infrastructure links. Spatial Growth Option 1 is considered to go too far in allocating all housing growth to the surrounding areas of Wrexham. It is submitted (as set out above) that Wrexham should accommodate significant levels of growth but that these (growth areas) should be well related to the existing settlement boundary. The most appropriate area for growth (in the short term) is land to the west of the 135 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response Guy Evans Continued. A483 to the North West of Wrexham. Future growth should then be directed to land immediately to the east to the settlement boundary (to the east of Cefn Road) Whilst support is expressed for Spatial Growth Option 1 in principle, especially with reference to promotion of the Key Strategic Sites and medium term large sites (i.e. up to 500 units), it is submitted that Spatial Growth should not be limited to Wrexham Town alone. Development should be spread between the primary key settlement of Wrexham and the key settlements. Whilst Spatial Growth Option 2 can in part be supported is submitted that the expansion of Wrexham and capacity for growth lies (in the first instance) at land to the North West of the settlement limit to the west of the A483. Spatial Growth Option 2 can therefore in part be supported, however the location of growth areas (shown within Map 4) should be revised with a focus on areas to the North West of the settlement boundary and to the west of the A483. Additional growth areas to the south west and east of Wrexham should be limited to an area of approximately 500m from the existing settlement boundary. In the short term, land off New Road, Rhosrobin in particular presents such an opportunity accommodate growth. The site is well related to a number of local service centres such as Pandy, New Rhosrobin, Little Acton and Croes Eneurys. These centres provide the full range of local services and facilities inclusive of 136 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response Guy Evans Continued. schools, shops, post office, public houses, community hall, churches, recreation facilities etc. All local service centres are easily accessible by means of transport other than the private car, e.g. pedestrian links, cycle links and frequent local bus service. The outer limits of both the conurbation of Wrexham town centre is within 1.5 km of the proposed site. The Rhosddu Industrial Estate lies directly adjacent to the proposed housing site and there are further employment land sources within 0.5 km of the proposed site at Stansty. All associated areas being easily accessible by means of transport other than the private car, e.g. pedestrian links, cycle links and frequent local bus service. As stated above, the site is within proximity to both local service centres and employment sources that are accessible on foot and cycle. The wider environment of the Borough and the adjoining administrative areas are accessible by public transport, via regular bus services, namely the 32 and 33 Arriva service, the 34 GHA Service, and 28A Townlynx Service. There are bus stops in close proximity to the site, and rail links to major destinations from Wrexham train station. There is also a local rail service from Wrexham to Bidston with a station at Gwersyllt, which is approximately 1 km from the proposed site. The site has been promoted through the candidate site submission process and it is submitted that the allocation of the site for residential 137 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response purposes would have the ability to meet a number of the aims and objectives of national policy.

6533 Charlene Sussums - Carter Jonas This approach would artificially restrict Noted. Lewis growth in the rural settlements and would not meet the test of ‘Positive Planning’ due to its inflexibility.

138 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 6910 Tim Stratton Wrexham Local Focuses all funding and effort on the Noted. Access Forum town centre to the detriment of other communities. Overall, the impression of the County Borough is given more by the rural communities than the town as these are what are highly visible to both residents and visitors.

7081 David Metcalfe Plas Kynaston Canal No good for Wrexham County or the Noted. Group Cefn. 7474 Mr Peter Guy Local Resident Good local transport or within walking Noted. distance for people to get to work. 7475 Bryn Richards Local resident There are large areas of brownfield sites Noted. on Wrexham Industrial Estate that are available i.e. empty factories etc.; adjacent land. There is no need to grab further (and already decimated) greenfield sites. Wrexham is a town bordered by villages and the greenfield areas are the division between the town and village. The occupants of villages deserve the option of further development which undermines the established village locations. 7623 David Fitzsimon Fitzsimon Planning This option relies too heavily on Noted. and Development Ltd development around the periphery of Wrexham Town Centre, whose western side has road infrastructure issues and suffers from serious traffic congestion at peak times, as acknowledged in the Option paper.

7628 Steve Jackson Coleg Cambria The plan should maximise the potential Noted. sites within Wrexham Town. This is unlikely to meet all needs.

139 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 7732 Matt Ferguson Brymbo The document has highlighted the Noted. Developments Ltd difficulties with this Option - lack of brownfield capacity, transport infrastructure capacity constraints, accessibility constraints and education capacity constraints. Given the historic shortfall in housing provision in the Borough, an option which clearly has severe constraints is unlikely to be capable of meeting increased demands going forwards.

7734 John Small DMR (North Wales) There is plenty of space for Noted. Ltd. redevelopment in Wrexham, this sounds like a great excuse for large property companies to build another vast estate over fields again . . . maybe look at allowing more new buildings over 3- storey in the town centre?

8298 Leslie Smith L S Planning Ltd Opportunity must be taken to ensure the Noted. growth outlying villages. This is to sustain those villages but also to further support the key settlement.

8315 Mr Shaun Jones Halls Holding Ltd Too much focus on Wrexham will hinder Noted. small villages. Sustainability of villages should be encouraged.

140 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders The HBF do not consider this to be an Noted. Federation (HBF) appropriate option as it places too much emphasis on a small number of strategic sites. This will not provide the mix, in terms of type and location that is required in the housing market. It also adds to the risk of the plan not delivering housing in the early years of the plan due to the time taken to get larger strategic sites delivering housing, which could result in a backlog and increased pressure towards the end of the plan. It also offers less opportunity for smaller house builders who will need to be encouraged as part of achieving the annual supply. 8411 Kate McClean Taylor Wimpey This spatial option does not provide any Noted. diversity in market location and will not fulfil the employment and housing targets set out in Option A.

8412 Helen Howie Berrys on behalf of Focusing on Wrexham is contrary to the Noted. Tony Jones and Vision, which seeks a reduction in Richard Tomlinson inequality. Improvements to the built environment, new infrastructure and investment should be spread across the County Borough, rather than concentrated in a small area.

141 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 8417 Liam Toland Heaton Planning Ltd While Lafarge Tarmac supports the on behalf of Lafarge principle of growth in the County An important role of the LDP is Tarmac Trading Ltd Borough, this should not be to the to facilitate an appropriate detriment of mineral resources. Options level of growth within the 1 and 2 appear to contradict Minerals County Borough, based upon Planning Policy Wales and Objective 11 a sound evidence base. of this document. To avoid sterilisation Wrexham Town has been of mineral resources and to protect new identified as a key settlement built development from harmful amenity of national importance and its issues associated with mineral working, growth is in line with national new development should be channelled policy and guidance. It is to areas that would not result in the loss recognised that due to the of mineral resources or should seek to distribution of mineral within extract minerals prior to development. the County there is likely to be a conflict between such growth and the protection of important mineral resources. This conflict is also considered likely to affect a number of other settlements within the County Borough. This matter has been, and will continue to be considered throughout the production of the LDP in order to minimise any unnecessary sterilisation of mineral and to ensure the use of prior extraction where appropriate 8430 Susan Evans WCBC, CYP Service, Option 1 does not allow for development Noted. PSC Department and growth in more rural areas of Wrexham and was not agreed as preferable by the External Key Stakeholder group.

142 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 8450 Ian Howard BCUHB There is a complete absence of evidence These comments are noted relating to health and well-being of the and the Council will consult local population. The statistical evidence with Public Health Wales as can be provided by Public Health Wales. part of the LDP process. If there is due regard to the local population needs assessment then there will be a much greater priority attached to ensuring that people can take care of their own health, be encouraged to make positive lifestyle choices and have access to the services and facilities they need.

8451 Penelope S J Coles Overton Local Access Wrexham town is already crowded Noted. Forum enough. 8452 Helen Howie Berrys on behalf of R Focusing on Wrexham is contrary to the Noted. & C Homes Vision, which seeks a reduction in inequality. Improvements to the built environment, new infrastructure and investment should be spread across the County Borough, rather than concentrated in a small area.

8454 Daniel Guy Local Resident I do not believe we should be releasing Noted. Each of the spatial Greenfield land for development. options is underpinned by the aim of maximising appropriate and deliverable brownfield land. However, in providing for the development requirements of the County Borough over the plan period will require development on Greenfield sites outside settlement limits. 8455 Michael Dixon local resident Too restrictive, risking (further) decay Noted. outside the town.

143 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 8456 Maureen Williams Local resident Primary key settlements are already Noted. experiencing problems with capacity. Inadequate road links, oversubscribed schools, absence of local employment opportunities, decline in white and blue collar workers more semi-skilled unskilled, subject to vagaries of the employment markets. Increase in low salaried – zero hours contracts etc. 8468 Vincent Ryan Barton Wilmore On Options 1 and 2 recognise and accept Noted. Behalf of Barratt that large scale greenfield release is Developments PLC required and this is supported on the basis that it is essential to meet the future housing needs of Wrexham and achieve the vision and objectives. The options identify a need for 'key strategic sites' capable of delivering in excess of 500 dwellings. Such sites should be located on land adjacent to Wrexham as the 'primary key settlement' and most sustainable. The advantage of such sites is the certainty they bring together with infrastructure and facilities. Our client's site at Holt Road has the potential to be a 'key strategic site'. Whilst option 2 also places an emphasis on key settlements, neither options 1 or 2 would preclude development in smaller rural communities through development management policies. Options 1 and 2 provide the best opportunities for improving existing transport routes and infrastructure. Options 1 and 2 are the most appropriate and capable of delivering sustainable development.

144 Wrexham LDP – Issues and Options Consultation Responses Q.11. Comments on Spatial Option 1 and Officer Responses ID Name Organisation Comments Officer Response 8469 Wendy Sime Local Resident We see no problem with extending the Noted. settlement limit into greenfield land around the edge of Wrexham as long as adequate public open spaces, including children's play areas for both formal and informal play, are set aside to give the feeling of semi-rural space.

8293; Janet Radford AVOW, Public Health Please see comments below (Q.13) See response to Q.13 237; Wales, Wrexham 7075; County Borough 8309 Council Health Promotion - working together through Public Health Commissioning Group

145 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses

Q.12 Comments on Option 2 - Primary Key Settlement (Wrexham Town) and Key Settlement Focussed?

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County See final comments (Q.14 and Q.15) See response to Q.14 and Borough Council - Q.15. Strategic Housing Services 145 Dewi Griffiths Dwr Cymru Welsh Not every settlement in the County is Noted. Consultation with Dwr Water served by its own Wastewater Treatment Cymru/Welsh Water will Works (WwTW), the catchment areas of continue throughout the LDP some WwTW cover numerous process. settlements. In terms of the spatial growth options under consideration the impact on our WwTW will be dependent on the amount of growth and spatial distribution of that proposed growth. The information below shows which settlements are served by which WwTW: Wrexham Five Fords WwTW Acrefair/Cefn Mawr Cefn Mawr WwTW Chirk Five Fords WwTW Coedpoeth Five Fords WwTW Gresford/Marford Gresford WwTW Gwersyllt Gresford WwTW Rhosllannerchrugog Five Fords WwTW Whilst there is capacity available at these treatment works, depending on the total amount of growth proposed for the catchment area, improvements may be required at the WwTWs to accommodate all of the growth. DCWW aim to ensure that sufficient infrastructure exists to accommodate domestic development, however where deficiencies are identified we look to resolve these through capital investment in our Asset Management Plans (AMP). We are currently 146 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response beginning the AMP6 programme which covers investment for the period 2015- 2020, this will be followed by AMP7 for the investment period 2020-25, and AMP8 for 2025-2030. The Wrexham LDP has a timeframe that runs until 2028, therefore any investment required at our WwTWs can be scheduled into future AMPs. Where specific infrastructure improvements are required to allow a development site to proceed, but where there are no current plans for investment through the AMP, there are provisions available for developers to make financial contributions, via planning obligations under the provisions of S106 Town & Country Planning Act 1990, to secure the necessary improvements. DCWW will work with your Authority, through assessing Joint Housing Land Availability Studies, to understand and monitor the rate of growth within the LDP area to assist us in submitting our plans for funding to deliver the required infrastructure necessary to meet future growth. There are incidents of flooding in the public sewerage system in all of the above settlements that, depending on the location of the proposed growth, may need to be resolved to allow development to proceed. Potential developers can either wait for DCWW to resolve these flooding incidents, subject to funding being approved by our regulator Ofwat, or progress the improvements through the sewerage requisition provisions of the Water Industry Act 1991. Hydraulic 147 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response modelling assessments may be required to determine an adequate point of connection to the public sewer, particularly for strategic development sites, and potential developers would be expected to fund investigations during pre-planning stages. The findings of a hydraulic modelling assessment would identify the extent of any necessary upgrades to the sewerage network which can be acquired through the sewer requisition provisions of the Water Industry Act 1991 (as amended). 155 Justin Paul J10 Planning Ltd Please refer to our response to Q14 and See response to Q.14 and Q15. Q.15. 169 Philip McCormick RIBA McCormick More flexibility required for growth in Noted. Architecture Ltd other appropriate settlements/villages.

181 Barbara Blanchard ref Robin Morris, Guy A proportion of new development should Noted. Woodcock Surveyors be spread in the outlying key settlements. 257 Cllr Brian Cameron WCBC Whitegate Development sites were applicable Noted. Ward should be shared between the above areas.

148 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 265 Michael Dixon Coedpoeth Coedpoeth, for example, affords the Noted. Community Council opportunity from growth, enabling support of existing business and employers as well as using the industrial and light industrial sites locally - all of which contribute to maintaining housing and local services. Option 2 avoids unhealthy centralisation and enables support (not subsidy) of the many local amenities and open spaces. It is for these reasons that we should consider growth outside the key settlement area and into the green barrier. Whilst people continue to have and to grow families we need to be able to plan for housing and all associated facilities. Hence Option 2 will enable the growing families and single households to be accommodated - in a planned and effective manner, to the benefit of all, residents, employers and visitors alike. 293 Cllr David Kelly WCBC - local New village Maelor Urban villages Noted. councillor already over developed 304 Dr Denis Edwards Local Resident Spreading new house over primary key Noted. settlements would be advantageous to the primary key settlements and Wrexham town. 305 Mrs V Jones Marchwiel Community The towns and villages should be kept Noted. Council separate to keep their identities. If you fill in the gaps between the villages and the towns they will merge into each other and identities lost. 403 Penelope S J Coles Overton Community I think and hope that these areas could Noted. Council accommodate growth. 438 Cllr Graham Rogers WCBC - Local In essence I agree with the content being Noted. Councillor described in paragraph 1.

149 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 463 Ms Karen Benfield Offa Community Relaxation of planning permission for Noted. Council town centre residential conversions. Most important barrier green belt between villages is retained. 507 Mike Blackshaw Ruabon Community Future developments should be Noted. Council concentrated on the settlement areas mentioned above and away from areas where approval has previously been given to major developments outside the areas mentioned.

150 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 639 Mr Steve Jones Llangollen Railway This option reduced pressure on the Noted. central urban core Wrexham Town area, and gives a more balanced development growth pattern around the supporting outlying centres of the county area, helping to strengthen the peripheral village community economies. Enhanced non-car dependent transport infrastructure to the outlying village communities would strengthen the potential growth for this option. For example the reintroduction of a branch railway between Ruabon and Trevor would strengthen the economic growth potential of the peripheral communities of Trevor, Garth, Fron, Acrefair, Cefn, and Plas Madog, open up existing and proposed new affordable housing to commute to work opportunities in the wider Wrexham/Chester/Shrewsbury/Liverpool/ Birmingham corridor and strengthen potential for greater inward tourism to the Pontcysyllte World Heritage Site. In the shorter term the introduction of a parallel footpath/cycle track along the former railway alignment between Ruabon Junction and Llangollen would provide a sustainable green transport link enabling safe routes to schools use as well as enhanced recreation and tourism functionality.

151 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 682 Coal Authority Coal Authority The Coal Authority has provided the LPA Noted. The Coal Authority will with information in respect of the defined be directly consulted on any development High Risk Areas for coal proposed allocations and this mining legacy and the Surface Coal information will be accounted resource plans. It is Noted that the most for when assessing the up to date information provided by the proposed allocations. Coal Authority was downloaded by the LPA on 13 November 2014 for both Development High Risk Areas and Surface Coal Resource. It is noted that the surface coal resource and past coal mining legacy is concentrated in the central part of the County Borough area. The Coal Authority would expect this information to inform the policy framework and the identification of site allocations. 1939 Howard Cartwright David Cartwright On balance, this option is likely to Noted. Solicitor achieve re-development of more brownfield sites, but popularity in some key settlements will be outweighed by hostility in others, unless consultation with local communities is sensitively handled, in connection with which see also my view at 15 below. 3095 Carl Richards Local Resident I do agree that development should be Noted. concentrated in the primary key settlement and on brownfield sites in the identified key settlement areas but suggest that loss of greenfield should ideally be to create a new key settlement around the A483/A525 Ruthin road and to the south of that area.

152 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 5623 Mr M Gilbert, The on behalf of Redrow As ever, there is a need for a balanced Noted. Planning Consultancy Homes Ltd approach and we would certainly not suggest that there should not be development in Key Settlements. However, we continue to see Wrexham Town as the main focus and would be concerned about a level of reliance on some of the settlements identified that market forces could not realistically achieve. As such, a Key Settlement focussed approach to delivering new housing and employment land is deemed to be inappropriate. 6531 Guy Evans Cassidy and Ashton see answer to question 11 See response to Q.11 6533 Charlene Sussums- Carter Jonas This approach would artificially restrict Noted. Lewis growth in the rural settlements and would not meet the test of ‘Positive Planning’ due to its inflexibility.

153 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 6910 Tim Stratton Wrexham Local Focusing growth in the Primary Key Noted. Access Forum Settlement and Key Settlements will better support the delivery of priority infrastructure (in the more appropriate urbanised locations through mechanisms such as CIL and S106, amongst other national, local and community funding sources) - which should include Green Infrastructure; enabling the promotion and delivery of Green Infrastructure through a strategic borough wide approach and on a site by site basis. It should be noted however, that the PROW and Green Infrastructure network is not contained wholly within sites and/or primary or key settlements and naturally extend beyond their boundaries providing important connections with rural areas (albeit improvements to linkages and disconnected routes is a high priority for the LAF and Welsh Assembly). 7081 David Metcalfe Plas Kynaston Canal Again the LDP should look at the whole Noted. Group county. 7474 Mr Peter Guy Local Resident Building more houses in some areas Noted. could cause congestion on the roads which are already overloaded at peak times. 7475 Bryn Richards Local resident Some of these key settlements areas Noted. mentioned, Gwersyllt in particular, have undergone massive influx of new housing in recent years. Brownfield sites from metal box; D.W.Williams etc and greenfield site adjacent to Mold Road. More than enough development.

154 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 7623 David Fitzsimon Fitzsimon Planning Most sustainable and balanced form of Noted. and Development Ltd development 7628 Steve Jackson Coleg Cambria This would support the development of Noted. key settlement areas. 7732 Matt Ferguson Brymbo The principle here appears more In relation to Planning Policy Developments Ltd practical. However, it is considered that Wales it is considered that the Brymbo should be included as a Key approach taken in assessing Settlement. The redevelopment of the the various settlements which former steelworks has resulted in the make up the rural areas of the construction of a significant number of County Borough is in houses in recent years and a substantial accordance with national amount of readily available and policy. developable brownfield land remains, both within and adjacent to the former steelworks site. The Council has been successful in attracting funding through Welsh Government for regeneration in the Borough but much of the current and potential future development work at Brymbo could be achieved through private investment. 8315 Mr Shaun Jones Halls Holding Ltd Other villages should also receive a Noted. proportionate amount of development to help maintain services.

155 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders The HBF consider this is the most Noted. Federation (HBF) appropriate option as it will tackle the issues identified in the answer to question no.11 in that it will reduce the risk associated with reliance on a small number of strategic sites, allow a large number of smaller sites which will allow delivery in the early years of the plan and provide a better mix in terms of type and location of the proposed new housing. It is also considered to be the most sustainable option as it will help to maintain the role of key settlements as well as reducing the need to travel to or from Wrexham. 8411 Kate McClean Taylor Wimpey Although preferable to the spatial Noted. strategy set out in Option 1, this again limits development to the largest settlements and provides less market diversity. It would also not enable smaller settlements in the Borough to grow at an appropriate scale and could prejudice the vitality and viability of shops, institutions and services in the Local Service Centres. 8412 Helen Howie Berrys on behalf of The primary key settlements represent Noted. Tony Jones and sustainable places that can Richard Tomlinson accommodate their share of the County Borough's growth over the next 15 years. This helps spread growth around, into the most sustainable locations. There is capacity for significant improvements to the built environment (new housing, employment land and infrastructure) in Gwersyllt.

156 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 8417 Liam Toland Heaton Planning Ltd While Lafarge Tarmac supports the Noted. Objective 11 ensures on behalf of Lafarge principle of growth in the County development meets the needs Tarmac Trading Ltd Borough, this should not be to the of society and industry, now detriment of mineral resources. Options and in the future, through the 1 and 2 appear to contradict Minerals provision of an adequate Planning Policy Wales and Objective 11 supply of high quality minerals of this document. To avoid sterilisation in sustainable locations, the of mineral resources and to protect new production of valuable mineral built development from harmful amenity resources from non-mineral issues associated with mineral working, development and the reduction new development should be channelled of conflict between minerals to areas that would not result in the loss workings and sensitive land of mineral resources or should seek to issues. extract minerals prior to development. 8430 Susan Evans WCBC, CYP Service, Option 2 is the preferred option as it Noted. PSC Department appears to provide for the most likely sustainable development both within Wrexham centre and more rural area. 8450 Ian Howard BCUHB There is a complete absence of evidence These comments are noted relating to health and well-being of the and the Council will consult local population. The statistical evidence with Public Health Wales as can be provided by Public Health Wales. part of the LDP process. If there is due regard to the local population needs assessment then there will be a much greater priority attached to ensuring that people can take care of their own health, be encouraged to make positive lifestyle choices and have access to the services and facilities they need. 8451 Penelope S J Coles Overton Local Access I think and hope that these areas could Noted. Forum accommodate growth. 8454 Daniel Guy Local Resident I believe there are plenty of houses in the Noted. Gwersyllt/Bradley area and that attention should be directed towards Acrefair/Cefn Mawr as they would benefit from some redevelopment 157 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 8455 Michael Dixon local resident Coedpoeth, for example, affords the Noted. In relation to Planning opportunity from growth, enabling Policy Wales it is considered support of existing business and that the approach taken in employers as well as using the industrial assessing the various and light industrial sites locally - all of settlements which make up the which contribute to maintaining housing rural areas of the County and local services. Option 2 avoids Borough is in accordance with unhealthy centralisation and enables national policy. support (not subsidy) of the many local amenities and open spaces. It is for these reasons that we should consider growth outside the key settlement area and into the green barrier. Whilst people continue to have and to grow families we need to be able to plan for housing and all associated facilities. Hence Option 2 will enable the growing families and single households to be accommodated - in a planned and effective manner, to the benefit of all, residents, employers and visitors alike. 8456 Maureen Williams Local resident For the reasons previously mentioned Noted and the fact that future developments in Gwersyllt North and West could only take place at the expense of greenfield development. Summerhill could witness the disappearance of remaining permanent pasture land with diverse fauna and flora, a subsequent increase in road congestion and impact on an already overloaded sewage capacity both of which would be nigh impossible to address.

158 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response 8457 Mrs F Massey Local Resident Strongly agree with the proposals that Noted. village areas should be expanded regarding housing. In total agreement with the statements that without growth the villages will continue to leak vitality and become even more dated. 8467 Gill Wilson Butterworth Local Resident Yes, new development should be in Noted. Primary Key Settlement and Key Settlement Focussed, using brown sites and commercial (empty shops) where possible. 8468 Vincent Ryan Barton Wilmore On The title describing option 2 should Noted. Behalf of Barratt include reference to inclusion of key Developments PLC strategic sites to be consistent with supportive text. Options 1 and 2 recognise and accept that large scale greenfield release is required and this is supported on the basis that it is essential to meet the future housing needs of Wrexham and achieve the vision and objectives. The options identify a need for 'key strategic sites' capable of delivering in excess of 500 dwellings. Such sites should be located on land adjacent to Wrexham as the 'primary key settlement' and most sustainable. The advantage of such sites is the certainty they bring together with infrastructure and facilities. Our client's site at Holt Road has the potential to be a 'key strategic site'. Whilst option 2 also places an emphasis on key settlements, neither options 1 or 2 would preclude development in smaller rural communities through development management policies. Options 1 and 2 provide the best opportunities for

159 Wrexham LDP – Issues and Options Consultation Responses Q.12. Comments on Spatial Option 2 and Officer Responses ID Name Organisation Comments Officer Response improving existing transport routes and infrastructure. Options 1 and 2 are the most appropriate and capable of delivering sustainable development. 8469 Wendy Sime Local Resident Development should be focused on a few Noted. key areas and then done well. 8293; Janet Radford AVOW, Public Health Please see comments below (Q.13) See response to Q.13 237; Wales, Wrexham 7075; County Borough 8309 Council Health Promotion - working together through Public Health Commissioning Group

160 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses

Q13. Comments on Option 3 - Primary Key Settlement (Wrexham Town), Key Settlements & Local Service Centre Focussed?

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County See final comments (Q.14 and Q.15) See response to Q.14 and Borough Council – Q.15. Strategic Housing Services. 145 Dewi Griffiths Dwr Cymru Welsh Not every settlement in the County is Noted. Consultation with Dwr Water served by its own Wastewater Treatment Cymru Welsh Water will Works (WwTW), the catchment areas of continue throughout the LDP some WwTW cover numerous process. settlements. In terms of the spatial growth options under consideration the impact on our WwTW will be dependent on the amount of growth and spatial distribution of that proposed growth. The information below shows which settlements are served by which WwTW: Wrexham Five Fords WwTW Acrefair/Cefn Mawr Cefn Mawr WwTW Chirk Five Fords WwTW Coedpoeth Five Fords WwTW Gresford/Marford Gresford WwTW Gwersyllt Gresford WwTW Rhosllannerchrugog Five Fords WwTW Bangor Bangor is y Coed WwTW Broughton Five Fords WwTW Brymbo Five Fords WwTW Glyn Ceiriog Glyn Ceiriog WwTW Holt Holt WwTW Llay Gresford WwTW Overton Overton WwTW Penley Penley WwTW Penycae Five Fords WwTW Rhostyllen Five Fords WwTW Rossett Lavister WwTW Ruabon Five Fords WwTW As the current consultation is at a high level stage we will need to await further information 161 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response regarding the breakdown of growth between settlements to allow us to make an assessment of the potential impact upon our assets. The settlements identified here are served by WwTWs of varying size and where the total growth identified by proposed allocations exceed the theoretical design capacity of these treatment works then improvements to provide further capacity will be required. DCWW aim to ensure that sufficient infrastructure exists to accommodate domestic development, however where deficiencies are identified we look to resolve these through capital investment in our Asset Management Plans (AMP). We are currently beginning the AMP6 programme which covers investment for the period 2015-2020, this will be followed by AMP7 for the investment period 2020-25, and AMP8 for 2025- 2030. The Wrexham LDP has a timeframe that runs until 2028, therefore any investment required at our WwTWs can be scheduled into future AMPs. Where specific infrastructure improvements are required to allow a development site to proceed, but where there are no current plans for investment through the AMP, there are provisions available for developers to make financial contributions, via planning obligations under the provisions of S106 Town & Country Planning Act 1990, to secure the necessary improvements. DCWW will work with your Authority, through assessing Joint Housing Land Availability Studies, to understand and monitor the 162 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response rate of growth within the LDP area to assist us in submitting our plans for funding to deliver the required infrastructure necessary to meet future growth. There are incidents of flooding in the public sewerage system in the settlements listed below that, depending on the location of the proposed growth, may need to be resolved to allow development to proceed. Potential developers can either wait for DCWW to resolve these flooding incidents, subject to funding being approved by our regulator Ofwat, or progress the improvements through the sewerage requisition provisions of the Water Industry Act 1991. Hydraulic modelling assessments may be required to determine an adequate point of connection to the public sewer, particularly for strategic development sites, and potential developers would be expected to fund investigations during pre-planning stages. The findings of a hydraulic modelling assessment would identify the extent of any necessary upgrades to the sewerage network which can be acquired through the sewer requisition provisions of the Water Industry Act 1991 (as amended). Wrexham Acrefair/Cefn Mawr Chirk Coedpoeth Gresford Gwersyllt Rhosllannerchrugog Llay Overton Penycae Rhostyllen Ruabon 155 Justin Paul J10 Planning Ltd Please refer to our response to Q14 and See response to Q.14 and Q15. Q.15.

163 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 169 Phillip McCormick RIBA McCormick Better option to retain more flexibility in Noted. Architecture Ltd the LDP 181 Barbara Blanchard ref Robin Morris, Guy Outlying services vary and a balance Noted. Woodcock Surveyors must be struck to ensure that Wrexham Town Settlement is not too heavily weighted at the expense of smaller developments. Also too huge an expanse of residential development without a transport system in place will mean more vehicles and more car parks for Wrexham. 257 Cllr Brian Cameron WCBC Whitegate Because we need more affordable Noted. Ward housing in the area. 265 Michael Dixon Coedpoeth Too restrictive, with poor consideration of Noted. Community Council the widespread and strong local communities which should not have opportunities for modest and controlled development destroyed. 304 Dr Denis Edwards Local Resident Would require the most in infrastructure Noted. development and increase car usage. 305 Mrs V Jones Marchwiel Community Marchwiel only has one small Noted. Council convenience store. No Doctors Surgery, No Chemist, No Post Office. The school is full to capacity. 403 Penelope S J Coles Overton Community Some of the more rural areas have not Noted. Council got enough facilities to accommodate new growth and I do not believe that Wrexham Council has or will have the money to improve their situation nor do I believe that the developers will adequately assist with this. 438 Cllr Graham Rogers WCBC - Local My comments as requested are along See response to Q.12. Councillor the lines described in option 2 (Q.12).

164 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 463 Ms Karen Benfield Offa Community Acceptable only with strong safeguards. Noted. Council Accept some greenfield outside settlement limits but should be limited as far as possible with brownfield and affordable housing given the highest priority. 639 Mr Steve Jones Llangollen Railway This option gives a too widely dispersed Noted. development pattern, putting pressure on rural communities and areas with poor or non-existent Public Transport links and little potential to enhance non-car dependent travel, as well as giving too diluted economic focus across the County. 682 Coal Authority The Coal Authority has provided the LPA Noted. The Coal Authority will with information in respect of the defined continue to be consulted development High Risk Areas for coal throughout the LDP process. mining legacy and the Surface Coal resource plans. It is noted that the most up to date information provided by the Coal Authority was downloaded by the LPA on 13 November 2014 for both Development High Risk Areas and Surface Coal Resource. It is noted that the surface coal resource and past coal mining legacy is concentrated in the central part of the County Borough area. The Coal Authority would expect this information to inform the policy framework and the identification of site allocations. 769 Cllr Rodney Skelland WCBC Smaller villages struggle retaining Noted. schools, shops, pubs, community centre, transport etc. there is a need for limited expansion in these smaller communities where there is good sound infrastructure to preserve these facilities.

165 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 1939 Howard Cartwright David Cartwright While this could be presented as sharing Noted. In relation to Planning Solicitor development pressures around fairly, it Policy Wales it is considered runs the risk of undue pressure on that the approach taken in infrastructure in some communities by assessing the various reason of the tendency of developers to settlements which make up the concentrate activities where environment rural areas of the County and costs appear to make marketing Borough is in accordance with easiest. Also, the designation of Ruabon national policy and Rossett as only local centres seems suspect. 3095 Carl Richards Local Resident It is important to promote some Noted. development in the outlying areas of the county in order to both spread the load across all communities but also to keep those communities alive. Not to do so risks failing communities as the draw away from the outlying areas removes facilities. 5623 Mr M Gilbert, The on behalf of Redrow See our comments in relation to '12' Noted. Planning Consultancy Homes Ltd above. There clearly is a role for development which can support local communities, but not at a scale which detracts from the focus on Wrexham Town.

166 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 6531 Guy Evans Cassidy and Ashton It is submitted that small scale housing Noted. growth in local service centres would support rural communities and local services. Without some small scale growth there would be a decline in local services and ultimately this would lead to their closure. Such a scenario can be avoided if small scale extensions or pockets of development are permitted in and around the small villages and rural hinterland. We consider that whilst development should be focussed on the primary key service settlement and key settlements an element of housing needs to be developed in and around the key service centres and small villages. Such development can support existing local services and facilities; it can also lead to the opening of new services, as new developments can offer a population source and support that would otherwise make the enterprise financially unviable. 6533 Charlene Sussums- Carter Jonas The Plan has made little or no reference Noted. However, the Taylor Lewis to the lessons outlined in the Taylor Review is applicable to Review (2008). In brief, the salient points England only. In relation to that need to be considered by Wrexham Iscoyd being identified as a tier are as follows: • Outdated inflexible ‘tick 4/5 settlement, no map has box’ methodology for determining the been provided to show the sustainability of a settlement has resulted extent of where a settlement in many rural areas being deprived of boundary should be drawn in growth, which has therefore led to the this area. The economic loss of their local services. • Need to activity in this area is recognise what rural communities can be acknowledged, however, it is like without writing them off as not currently identified as a unsustainable. • Key question is whether settlement in the County development will add to or diminish the Borough and given the economic, social and environmental dispersed nature of

167 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response sustainability of the settlement. • development within the Iscoyd Sustainability trap – permitting area, it is therefore not development only in places considered to considered appropriate be ‘sustainable’ in narrow terms. • Sustainability in planning policy can be too focused on access to services and reducing car use. • Viability of local shops (in surrounding settlements too) and services are put at risk if settlements are excluded from growth. • Only permitting minimal development in smaller rural communities will drive up house prices and cause shortage of homes that locals can afford. • Small rural settlements struggle to provide the range of housing market options that urban areas have and so a different policy approach is required. • Environmental protection can still be achieved when a better balance is found with high quality small scale development meeting local need. • Ruling out whole categories of settlements as unsustainable ignores the potential for enhancing the sustainability of many smaller rural communities. Planning Policy Wales states that Development Plans should secure sustainable rural communities with access to affordable housing and high quality public services; a thriving and diverse local economy where agriculture‐related activities are complemented by sustainable tourism and other forms of employment in a working countryside; and an attractive, ecologically rich and accessible countryside in which the environment

168 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response and biodiversity are conserved and enhanced. National Policy advises that development in rural areas should be directed towards local service centres, or clusters of smaller settlements where sustainable functional linkages can be demonstrated. An example of this would be Iscoyd. The background paper produced by Wrexham sets out a settlement hierarchy based on the function of each settlement. A tiered approach is used to group settlements of similar characteristic in terms of facilities, services, and growth opportunities. The Settlement Hierarchy defines Rural Villages as ‘range of services available in these settlements is generally confined to those meeting purely local needs. The settlements themselves are surrounded by attractive countryside and some are not conveniently accessible by public transport. New development is therefore restricted to small sites.’ The intention of the settlement hierarchy (as set out in section 1.3) is to rank the settlements within the County Borough based on the level of services they provide, their employment/economic function and their accessibility via sustainable transport methods. The document goes onto state that ‘on the whole the lack of services and ability to access sustainable modes of transport in settlements in both tiers (4/5) make them inappropriate locations for development in sustainability terms. However in some circumstances small scale development to meet local need may be deemed appropriate as windfall 169 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response development (e.g., barn conversion, infill and rural exceptions) It is therefore considered that in accordance with the Taylor Review and the above paragraph deeming small scale housing development in rural areas as appropriate, Iscoyd should be a Tier 4/5 settlement due to the level of economic activity. This includes the following: - Iscoyd Park Wedding and Function Business which employs 60-70 staff on a full and part time basis - Park Pre- School at Iscoyd Park which cares for children from infancy to school age - Copper Tree Gallery at Iscoyd which provides for picture framing, works of art and an impressive gallery - Whitewell Parish Rooms at Iscoyd which has recently secured funding for the thriving community centre. - Broad Oak Business Park which provides for a range of business units and small offices. - Iscoyd Park Cricket Club which attracts members of all ages Development of a select infill plot would therefore greatly enhance the viability of the rural settlement and thriving community and boost the numerous economic enterprises and versatility of Iscoyd over the plan period. 6910 Tim Stratton Wrexham Local Probably disperses resources and Noted. Access Forum funding too much.

170 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 7081 David Metcalfe Plas Kynaston Canal This again is the best option, look at the Noted. Group whole county and not just focused on Wrexham Town Centre, Cefn Mawr and the Cefn have a tremendous amount to offer the county if managed properly and has the potential to become a Blists Hill or Hebden Bridge of the Pontcysyllte WHS, Wrexham County and North East Wales. Please watch out for our site specific recommendations for inclusion in the LDP2 on how we can do this together. 7475 Bryn Richards Local resident There is a need to keep village identity - Noted. not a giant sprawl of housing. 7623 David Fitzsimon Fitzsimon Planning Local Service Centres are less Noted. and Development Ltd sustainable locations for new development compared to the edge of Wrexham Town Centre and Key Settlements. 7628 Steve Jackson Coleg Cambria A sensitive dispersed plan would provide Noted. development to sustain more rural areas whilst developing established settlement areas.

171 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 7732 Matt Ferguson Brymbo As previously indicated, it is considered Noted. In relation to Planning Developments Ltd that Brymbo should be included as a Key Policy Wales it is considered Settlement but if this is not to be the case that the approach taken in then it should certainly be seen as a assessing the various Local Service Centre. The settlements which make up the redevelopment of the former steelworks rural areas of the County has resulted in the construction of a Borough is in accordance with significant number of houses in recent national policy. years and a substantial amount of readily available and developable brownfield land remains, both within and adjacent to the former steelworks site. The Council has been successful in attracting funding through Welsh Government for regeneration in the Borough but much of the current and potential future development work at Brymbo could be achieved through private investment. 8298 Leslie Smith L S Planning Ltd Do not restrict the number of local Noted. service centres. As well as including what facilities are there, supply led, also consider what facilities could be encouraged to be there, demand led. 8315 Mr Shaun Jones Halls Holding Ltd Incorporating local service centres will Noted. benefit their sustainability. Bangor has suitable sites for development and a good range of services. 8408 Mark Harris Home Builders The HBF do not support this option as it Noted. Federation (HBF) will reduce the importance of Wrexham as the Primary Settlement and make the plan less sustainable encouraging continued reliance on car travel. It is also considered that not all Local Service Centres will be attractive to volume house builders and therefore put at risk the delivery of the number of houses required by the plan.

172 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 8411 Kate McClean Taylor Wimpey This option supports development Noted. through a wider range of settlements to enable growth more evenly across the Borough. Local Service Centres should be permitted to accommodate housing and employment growth at an appropriate scale in order to retain and grow populations, provide better opportunity for the delivery of affordable and specialist housing and to sustain existing shops, institutions and other services . We would also encourage the authority to consider 2 tiers of local service centres, focusing development in those centres which have the best quality and quantity of services and facilities. 8417 Liam Toland Heaton Planning Ltd Option 3 does not propose development Noted. on behalf of Lafarge that would result in the loss of mineral Tarmac Trading Ltd resources of regional and national significance. Suggests that proposing the safeguarding of mineral resources such as Borras Quarry is a realistic suggestion and can still accommodate significant growth in the County Borough without the threat to mineral resources. 8430 Susan Evans WCBC, CYP Service, The group felt that this option could be Noted. PSC Department considered in the future following the successful implementation of Option 2. The Council must be careful to ensure that all development activities are sustainable. The lack of public transport links may affect the attractiveness from the point of view of investors and the objective to reduce the use of the car may make this option difficult to achieve on a large scale.

173 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 8451 Penelope S J Coles Overton Local Access Some of the more rural areas have not Noted. Forum enough facilities to accommodate new growth and I do not believe that Wrexham Council has or will have the money to improve their situation nor do I believe that the developers will adequately assist with this. 8452 Helen Howie Berrys on behalf of R The local service centres represent Noted. & C Homes sustainable places that can accommodate their share of the County Borough's growth over the next 15 years. Local planning authorities should reflect market demand as to where people want to live. Villages are perennially popular, reflecting peoples' instinctive desire to live in attractive surroundings. Spreading growth around the Borough will enable rural areas to thrive and address rural inequality, and enable more people to live where they can enjoy the Borough's quality "natural, built heritage and culture assets" as set out in the LDP's Vision. 8455 Michael Dixon local resident Too restrictive, with poor consideration of Noted. the widespread and strong local communities which should not have opportunities for modest and controlled development destroyed. 8456 Maureen Williams Local resident There is some capacity to build on one Noted. brownfield site in Gwersyllt North and some development along the A541 between the St Giles development and the A483 but as stated previously any further development in Summerhill on greenfield sites would impact on the lives of a significant majority of the population in the area.

174 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 8468 Vincent Ryan Barton Wilmore On Option 3 is not appropriate as it will Noted. Behalf of Barratt undermine the proposed mission and Developments PLC objectives. It would see significant development on greenfield sites in unsustainable locations, placing a greater demand on services and increasing the need to travel. Development in a dispersed nature will limit the ability of development to improve existing infrastructure.

175 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response 8469 Wendy Sime Local Resident Priority should be given to concentrating Noted. housing and jobs in and close to Wrexham where there is existing infrastructure. The second priority should be the rejuvenation of the urban villages west of the A483 where there is basic infrastructure which could easily be upgraded and expanded for an increased population. There are several old industrial sites in desperate need of redevelopment. Trying to extend development even further into the countryside is likely to result in spreading resources too thin. We can picture developers wanting to build estates of 4- bedroom 'executive' homes in rural areas on greenfield sites to make a good profit with no thought to the strain on facilities and infrastructure, especially limited or the lack of mains sewerage, and the fact that the occupants of these executive houses will be commuting to their jobs many miles away leaving behind large dormitory towns rather than the former villages. There are presently poor transport links between rural areas highlighted in this option and larger centres; one or two buses a day is not adequate to encourage bus use, resulting in even more cars on the roads. 8293; Janet Radford AVOW, Public Health We feel that the creation of vibrant Noted. 237; Wales, Wrexham sustainable communities is important, by 7075; County Borough dispersing development across the 8309 Council Health county there will be an opportunity for all Promotion - working localities to benefit from services and together through facilities being retained. Public Health

176 Wrexham LDP – Issues and Options Consultation Responses Q.13. Comments on Spatial Option 3 and Officer Responses ID Name Organisation Comments Officer Response Commissioning Group

177 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses

Q14. Preferred Spatial Option Comments and Reasons

ID Name Organisation Preferred Comments Officer Response Option 67 Mike Jenkins Wrexham County 1 We have shown option 1 as preferred as we Noted. Borough Council - consider that a policy of developing on larger Strategic Housing strategic greenfield sites that are close to town Services centre amenities and transport links are likely to deliver the most viable developments and, as a consequence also maximise the delivery of affordable housing. Other comments: We agree that brownfield sites are in short supply and where they are developable tend to have higher infrastructure and additional costs (such as contamination) that limit the delivery of affordable housing. We agree that the numbers of new housing required under strategic growth option A will not be delivered without release of significant greenfield land in, and around the town centre. Bringing forward such sites in urban villages and rural communities if options 2 or 3 are adopted is generally more problematic - recent experience ranging from general reluctance to outright opposition to affordable housing in urban villages. Recent opposition to major housing developments in Ruabon and Llay demonstrate the parochial nature of many urban and rural villages even when these developments are accompanied by infrastructure improvements. However, where deliverable we agree that they can support regeneration in these areas. However issues around development and viability are likely to result in little if any, in developer led affordable housing. We do not feel that the potential merging of settlements to the north west of Wrexham will have a detrimental effect on local 178 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option identity. Small scale housing developments in rural communities should be encouraged, particularly affordable housing as a means of reversing the decline in rural populations but the experience of the Rural Housing Enabler in Wrexham (until 2013) demonstrated that these are also difficult to achieve without some kind of supporting subsidy either in the form of gifted land, grant or reduced infrastructure requirements. Where small private schemes do come forward a low affordable threshold or commuted sum may be appropriate.

179 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 155 Justin Paul J10 Planning Ltd 3 The Council struggled to demonstrate that it Noted. The consultation could even accommodate 8.065 units through its document explains at regeneration brownfield only no settlement Paragraph 5.7 providing expansion policy expressed in LDP1. That for all of Wrexham’s strategy was fatally flawed and when faced with development an increase to 11,786 dwellings it was accepted requirements over the by the Council that settlement expansion was Plan period will also going to be required. To suggest now that require new land for Options 1, 2 or 3 can deliver even 10,100 units, development outside of let alone 11,030 or 13,010 (or our preferred existing settlement limits 14.175) is simply unrealistic. Significant to be released. settlement expansion will be needed because there simply are not the brownfield sites available to deliver the level of growth required. If we had to select an Option it would have to be a mix between Option 1 and Option 3, balanced by greater growth to the west of Wrexham town than is shown in Option 2 or 3 and perhaps less reliance upon the sensitive areas to the east and west of Wrexham town; with limited but proportionate growth in the Minor Village, Local Service Centres and Key Settlements.

169 Phillip Mc Mc Cormick 3 See my earlier comments. Noted. Cormick RIBA Architecture LTD 181 Barbara ref Robin Morris, 3 Already outlined in previous question Noted. Blanchard Guy Woodcock Surveyors 247 Arfon Jones WCBC Local Not Unable to support any of the three broad spatial Noted. Councillor answered growth options for new development.

257 Cllr Brian WCBC Whitegate 2 As overleaf - because we need more affordable Noted. Cameron Ward housing in the area. 180 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 265 Michael Dixon Coedpoeth 2 Whilst there are modest amounts of "brownfield" Noted. The consultation Community available I believe that, in an area with so much document explains at Council green, mountainous and free space available, Paragraph 5.7 providing we should make use of land outside the for all of Wrexham’s settlement areas. Coedpoeth, for example, has development an A road running through and is minutes from requirements over the the A483, enabling easy access to all the Plan period will also surrounding areas. Planned development here require new land for would enable support of the local manufacturing development outside of and service businesses as well as contributing existing settlement limits support to the 42 retail shop-front businesses. to be released. This would help to contain the "shopping journeys" as well as supporting the two local However, it should be schools, library, dental surgery, two pharmacies noted that the Council is and three medical practices. These networks do not considering site not happen by accident and are worthy of care specific allocations at and support. Not subsidy, but planned support. this stage in the LDP The local electricity, sewerage and water process supplies have been recently augmented and the local telephone exchange is capable of considerable expansion. We have almost boundless green barrier and modest incursion would enable the village to do its bit in supporting the county, whilst still maintaining a separate life - surely in line with the revised LDP.

304 Dr Denis Local Resident 2 see above Edwards 403 Penelope S J Overton 2 Growth in the already crowded town centre Noted. The consultation Coles Community would not be a good thing and growth in the document explains at Council more rural areas would put too much strain on Paragraph 5.7 providing their facilities. for all of Wrexham’s

181 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option development requirements over the Plan period will also require new land for development outside of existing settlement limits to be released. 436 Peter Mullen Gwersyllt Not The Council feels unable to support any of the Noted. Community answered three broad spatial growth options for new Council development. 438 Cllr Graham WCBC - Local 3 To ensure within reason that efforts are made to Noted. Rogers Councillor fulfil the demands as specified by Welsh Government. 507 Mike Ruabon 2 Priority should always be given to brownfield Noted. Each option is Blackshaw Community sites, the development on new sites should only underpinned by the aim Council be necessary where no other alternatives exist. of maximising appropriate and deliverable brownfield land. However, providing for all of Wrexham’s development requirements over the Plan period will also require new land for development outside of existing settlement limits to be released. 592 Angela Loftus Denbighshire Not Regardless of the chosen spatial option, we The Council will continue County Council answered would like to offer the opportunity to discuss any to consult with potential impact on infrastructure facilities in Denbighshire County Denbighshire, particularly in settlements along Council throughout each the River Dee. stage of the LDP process in line with the Revised Delivery Agreement.

182 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 639 Mr Steve Llangollen 2 Option 2 gives an optimised balance of Noted. Jones Railway spreading economic growth and development across the County, whilst concentrating housing and job creation development around existing local centres helping to reduce pressure on the core Wrexham Town area as well as protecting the green field land and outlying rural green belt localities from excessive urbanisation which will ultimately give a better diversity balance and quality of life for the economy and residents respectively.

682 Coal Authority Not The Coal Authority has provided the LPA with Noted. This information answered information in respect of the defined will be used to help development High Risk Areas for coal mining determine whether or not legacy and the Surface Coal resource plans. It a site is suitable for is noted that the most up to date information allocation in the LDP. provided by the Coal Authority was downloaded by the LPA on 13 November 2014 for both Development High Risk Areas and Surface Coal Resource. It is noted that the surface coal resource and past coal mining legacy is concentrated in the central part of the County Borough area. The Coal Authority would expect this information to inform the policy framework and the identification of site allocations.

769 Cllr Rodney WCBC 3 Comments the same as on 13. Smaller villages Noted. Skelland struggle retaining schools, shops, pubs, community centre, transport etc. there is a need for limited expansion in these smaller communities where there is good sound infrastructure to preserve these facilities

183 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 1930 Carys Wynne- Arts Council of Not No preference - should be based on end users' Noted. Williams Wales answered opinion - such as young people and families and the older generation within communities.

1939 Howard David Cartwright 2 This is the best option to deal with dereliction Noted. Cartwright Solicitor problems in addition to providing adequate capacity to meet both employment and housing needs, but see also 15 below.

3095 Carl Richards Local Resident I believe that to further expand some of the key Noted. settlement areas would be hugely detrimental to them. Option 1 focuses on development in the main town which is desperately needed but also acknowledges the need to build in key strategically located sites. 5623 Mr M Gilbert, on behalf of 1 See our comments in relation to 11, 12 and 13 See Officer response to The Planning Redrow Homes above. Questions11, 12 & 13. Consultancy Ltd 6531 Guy Evans Cassidy and 1 It is submitted that a combination of Spatial Noted. Ashton Growth Option 1 and 2 should be pursued with an understanding that some small scale development in and around the local services centres and villages be acceptable.

6533 Charlene Carter Jonas 3 The Plan has made little or no reference to the Noted. However, the Sussums- lessons outlined in the Taylor Review (2008). In Taylor Review is Lewis brief, the salient points that need to be applicable to England considered by Wrexham are as follows: • only. In relation to Iscoyd Outdated inflexible ‘tick box’ methodology for being identified as a tier determining the sustainability of a settlement 4/5 settlement, no map has resulted in many rural areas being deprived has been provided to of growth, which has therefore led to the loss of show the extent of where their local services. • Need to recognise what a settlement boundary rural communities can be like without writing should be drawn in this them off as unsustainable. • Key question is area. The economic whether development will add to or diminish the activity in this area is 184 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option economic, social and environmental acknowledged, however, sustainability of the settlement. • Sustainability it is not currently trap – permitting development only in places identified as a settlement considered to be ‘sustainable’ in narrow terms. • in the County Borough Sustainability in planning policy can be too and given the dispersed focused on access to services and reducing car nature of development use. • Viability of local shops (in surrounding within the Iscoyd area, it settlements too) and services are put at risk if is therefore not settlements are excluded from growth. • Only considered appropriate. permitting minimal development in smaller rural communities will drive up house prices and cause shortage of homes that locals can afford. • Small rural settlements struggle to provide the range of housing market options that urban areas have and so a different policy approach is required. • Environmental protection can still be achieved when a better balance is found with high quality small scale development meeting local need. • Ruling out whole categories of settlements as unsustainable ignores the potential for enhancing the sustainability of many smaller rural communities. Planning Policy Wales states that Development Plans should secure sustainable rural communities with access to affordable housing and high quality public services; a thriving and diverse local economy where agriculture‐related activities are complemented by sustainable tourism and other forms of employment in a working countryside; and an attractive, ecologically rich and accessible countryside in which the environment and biodiversity are conserved and enhanced. National Policy advises that development in rural areas should be directed towards local service centres, or clusters of smaller settlements where sustainable functional linkages can be 185 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option demonstrated. An example of this would be Iscoyd. The background paper produced by Wrexham sets out a settlement hierarchy based on the function of each settlement. A tiered approach is used to group settlements of similar characteristic in terms of facilities, services, and growth opportunities. The Settlement Hierarchy defines Rural Villages as ‘range of services available in these settlements is generally confined to those meeting purely local needs. The settlements themselves are surrounded by attractive countryside and some are not conveniently accessible by public transport. New development is therefore restricted to small sites.’ The intention of the settlement hierarchy (as set out in section 1.3) is to rank the settlements within the County Borough based on the level of services they provide, their employment/economic function and their accessibility via sustainable transport methods. The document goes onto state that ‘on the whole the lack of services and ability to access sustainable modes of transport in settlements in both tiers (4/5) make them inappropriate locations for development in sustainability terms. However in some circumstances small scale development to meet local need may be deemed appropriate as windfall development (e.g., barn conversion, infill and rural exceptions) It is therefore considered that in accordance with the Taylor Review and the above paragraph deeming small scale housing development in rural areas as appropriate, Iscoyd should be a Tier 4/5 settlement due to the level of economic activity. This includes the following: - Iscoyd Park Wedding and Function Business which employs 186 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 60-70 staff on a full and part time basis - Park Pre-School at Iscoyd Park which cares for children from infancy to school age - Copper Tree Gallery at Iscoyd which provides for picture framing, works of art and an impressive gallery - Whitewell Parish Rooms at Iscoyd which has recently secured funding for the thriving community centre. - Broad Oak Business Park which provides for a range of business units and small offices. - Iscoyd Park Cricket Club which attracts members of all ages Development of a select infill plot would therefore greatly enhance the viability of the rural settlement and thriving community and boost the numerous economic enterprises and versatility of Iscoyd over the plan period. 6910 Tim Stratton Wrexham Local 2 Reasonably balanced use of resources across Noted. Access Forum the County Borough. 7081 David Metcalfe Plas Kynaston 3 Questions 6 to 13 are just repeats of the same Noted. Option 3 is not Canal Group question, and the options are nonspecific apart the same as Option C. from housing numbers. Option 3 and C are Option C refers to the exactly the same things. amount of growth within the County Borough (in this case, 10,100 homes and 42ha of employment land), whilst Option 3 relates to where development should be located (in this case Wrexham Town, Key Settlements and Local Service Centres). 7475 Bryn Richards Local resident Not The use of brownfield sites must be the Noted. National answered preferred option for growth and greenfield sites Planning Policy indicates must be discussed and agreed locally. that brownfield sites should be considered first. This has been 187 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option done, and it was found that there is insufficient capacity to meet any of the growth options. This lack of capacity and inability to meet previous Welsh Government projections was one of the main reasons that LDP1 was withdrawn. 7623 David Fitzsimon 2 Most balanced and sustainable approach Noted. Fitzsimon Planning and Development Ltd 7732 Matt Ferguson Brymbo 2 Option 2 if Brymbo is regarded as a Key Noted. Developments Settlement - otherwise Option 3 Ltd 8298 Leslie Smith L S Planning Ltd 3 People do not come to Wales to live in towns. Noted. Villages must have critical mass to be viable but this could be achieved through the growth process. 8315 Mr Shaun Halls Holding Ltd 3 Option 3 will allow an appropriate scale of Noted. Jones development to maintain sustainability of numerous settlements. If it is too restricted rural service provision will suffer putting greater strain on public finances. This option will reduce reliance on private car usage.

8408 Mark Harris Home Builders 2 The HBF believe that option 2 is most likely to Noted. Federation (HBF) deliver the mix and type and location of new development while being sustainable and considering market conditions. This growth option will help support builders of all sizes and reduce the risk of the plan not delivering houses on time.

188 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 8409 Rhian Harris HOW Planning on 1 The inclusion of Wrexham as a primary key Noted. behalf of settlement in all of the spatial options is strongly Kingmoor Park supported. Properties Ltd 8411 Kate McClean Taylor Wimpey 3 This option supports development through a Noted. wider range of settlements to enable growth more evenly across the Borough. Local Service Centres should be permitted to accommodate housing and employment growth at an appropriate scale in order to retain and grow populations, provide better opportunity for the delivery of affordable and specialist housing and to sustain existing shops, institutions and other services . We would also encourage the authority to consider 2 tiers of local service centres, focusing development in those centres which have the best quality and quantity of services and facilities.

8412 Helen Howie Berrys on behalf 2 Option 2 most closely matches the Vision, by Noted. of Tony Jones sharing growth around (reducing inequalities) and Richard whilst providing a highly sustainable form of Tomlinson development. Not everyone needing new housing wants to live in Wrexham Town. Investment in the County Borough will be greater if it utilises the strengths of all parts of the County Borough.

189 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 8417 Liam Toland Heaton Planning 3 Option 3 does not propose development that Noted. Ltd on behalf of would result in the loss of mineral resources of Lafarge Tarmac regional and national significance. Suggests Trading Ltd that proposing the safeguarding of mineral resources such as Borras Quarry is a realistic suggestion and can still accommodate significant growth in the County Borough without the threat to mineral resources.

8430 Susan Evans WCBC, CYP 2 Option 2 is the preferred option as it appears to Noted. Service, PSC provide for the most likely sustainable Department development both within Wrexham centre and more rural areas. 8449 Michael Gower Homes 3 Option 3: 1. Development of the smaller villages Noted. Forgrave will support the rural communities and allow the children who have grown up in these communities to remain in their home villages also others should not be deprived of the opportunity to move into these villages. Not everyone in the borough wants to live in Wrexham town. 2. More varied provision of houses is a good thing, and more interesting and higher quality housing schemes will result. 3. Option 3 will create many more housing sites of all sizes which gives the small and medium sized local house builder more and varied housing opportunities – more varied housing scheme has to be a good thing. It would greatly assist the local house builders if the site allocations could be smaller; the more sites there are and the more they are spread throughout the Wrexham villages the easier it becomes for the local house builder to thrive; the local house builder (unlike the volume house builders) purchases virtually all the materials locally, the workforce is local to the borough too

190 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option and they are more receptive to the Planning Officers encouragement to deliver higher quality schemes. 4. The housing allocation in the rural hamlets and smaller villages will invariably be smaller sites and as a consequence the more interesting and higher quality housing schemes will be built. Option 1 is my least preferred option – this will encourage the mega sites of 400+ which only the volume house builders can access. 8451 Penelope S J Overton Local 2 Growth in the already crowded town centre Noted. Coles Access Forum would not be a good thing and growth in the more rural areas would put too much strain on their facilities.

8452 Helen Howie Berrys on behalf 3 Option 3 matches the Vision by sharing growth Noted. of R & C Homes around (reducing inequalities) and enabling more people to live where they can more fully enjoy the Borough's attractive landscape in traditional village settings. Not everyone needing new housing wants to live in the more urban parts of the Borough. Investment in the County Borough will be greater if it utilises the strengths of all parts of the County Borough.

191 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 8455 Michael Dixon local resident 2 Whilst there are modest amounts of "brownfield" Noted. available I believe that, in an area with so much green, mountainous and free space available, we should make use of land outside the settlement areas. Coedpoeth, for example, has an A road running through and is minutes from the A483, enabling easy access to all the surrounding areas. Planned development here would enable support of the local manufacturing and service businesses as well as contributing support to the 42 retail shop-front businesses. This would help to contain the "shopping journeys" as well as supporting the two local schools, library, dental surgery, two pharmacies and three medical practices. These networks do not happen by accident and are worthy of care and support. Not subsidy, but planned support. The local electricity, sewerage and water supplies have been recently augmented and the local telephone exchange is capable of considerable expansion. We have almost boundless green barrier and modest incursion would enable the village to do its bit in supporting the county, whilst still maintaining a separate life - surely in line with the revised LDP.

8456 Maureen Local resident 3 It would result in a better spread of future Noted. Williams development but concentrating any development in some already congested areas of our urban village settings will impact negatively on the population both now and in the future.

192 Wrexham LDP – Issues and Options Consultation Responses Q.14. Preferred Spatial Option Comments/Reasons and Officer Responses ID Name Organisation Preferred Comments Officer Response Option 8457 Mrs F Massey Local Resident 2 Increased housing in the area could offer the Noted. opportunity to revitalise and update the whole shopping area to include more shops and increase the variety of shops. Particularly given the predicted increase in the number of older people over the next 20 years, who would prefer to shop locally, and given that Marford residents have no separate shopping area. Rossett, Gresford and Marford have few shops, the whole area could be designated a 'small town area' with an appropriate central shopping area.

8467 Gill Wilson Local Resident 3 More rural employment is important, especially Noted. Butterworth non-farming employment. 8468 Vincent Ryan Barton Wilmore 1 The title describing option 2 should include Noted. On Behalf of reference to inclusion of key strategic sites to be Barratt consistent with supportive text. Please see Developments above. PLC 8469 Wendy Sime Local Resident 2 See comments above Noted. 8293; Janet Radford AVOW, Public 3 We feel that the creation of vibrant sustainable Noted. 237; Health Wales, communities is important, by dispersing 075; Wrexham County development across the county there will be an 8309 Borough Council opportunity for all localities to benefit from Health Promotion services and facilities being retained. We feel - working together that the Wrexham Town Centre and local through Public centres could be enhanced by more mixed use Health development, in particular provision of Commissioning accommodation in those localities. Group

193 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses

Q15. Other suggested Spatial Options and Comments

ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd The key priorities for the Authority in this Noted. However no detailed Plan are to address the inherent and supporting evidence was contextual failings of LDP1 and therefore submitted to justify why these ensure the problems expressed by the alternative options should be Inspector are resolved. This will provide given consideration or be the Council with the best opportunity in favoured at the stage. securing a "sound" Plan. This means having a strategy that can deliver infrastructure, reverse out-migration, arrest market failure, provide meaningful levels of affordable housing, economic growth and standard market housing is provided in the most sustainable manner possible and Wrexham's wellbeing is enhanced; all without undermining the future sustainability of any key settlements in the Authority area which can be identified in an ordered settlement hierarchy. Whilst we support the principles of Option 1, benefiting from existing infrastructure and substantially promoting sustainability aims, we are mindful that the Council will have to provide a significant number of new housing and thus this will have to be spread across the County Borough using a balanced, proportionate and sustainable approach. Accordingly, we consider most growth should be around Wrexham town, specifically to the West, with limited growth opportunities across other settlements where sustainability can be properly demonstrated and other capacity and site constraints overcome. 194 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response Otherwise similar errors to LDP1 will be repeated. There is a need to have a settlement hierarchy to secure sustainable communities in terms of employment, housing and infrastructure. Whilst Option 3 provides a balance across the Country Borough, there needs to be clear warnings over providing growth options in unsustainable locations which would burden small local communities. . As such we promote an Option 4 that is primarily focussed on development around Wrexham town to its west, with some limited and measured growth across a settlement hierarchy. This Option 4 is sustainable and consistent with PPW. Note that there are some settlements which won't be able to accommodate any significant growth due to having poor accessibility to jobs and services as well as public transport provision. We also consider that there should be less reliance upon growth to the sensitive eastern and southern fringes of Wrexham town. There is no evidence to suggest that this will result in the "Cons" expressed in Tables 2 and 4 - all those concerns are based upon speculation and conjecture and not upon any evidence base. Our Preferred Option 4 will see Wrexham as the main hub and growth point, with modest settlement expansion across the Key Service Centres and filtering down to Local Centres/smaller rural settlements; thus we are advocating a balanced and proportionate level of growth based upon a defined settlement hierarchy. The 195 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response problem of a "a limited supply of brownfield land for retail, employment and housing development within the existing settlement boundary” is an issue faced by all three spatial options, and is in no way specific to any one option. One of the "cons" set out against Option 1 states that “intensifying land use in Wrexham Town would mean that the existing infrastructure and road network would be significantly stretched. This could result in further traffic congestion and limit private sector investment, for example if improvements are not made”. This is not specific to just Option 1, but also applies to Option 2. The premise of locating close to Wrexham Town’s edge is that it promotes walking, cycling and use of public transport as services here are excellent. Any applications that come forward for development can provide Green Travel Plans to promote this further. By definition, this should reduce the reliance on the private car and provides the opportunity for a shift change in sustainable travel, which is advocated by Welsh Government policy, and should be supported by the Local Authority. Accordingly, this will relieve pressure on the highway, and act to improve the current situation along the A483. The Council states that intensifying land use in Wrexham (at all costs to everywhere else) “could result in further traffic congestion…if improvements are not made”. This is a pertinent point. Strategic sites on the edge of Wrexham Town will be of a scale 196 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response that creates the critical mass required to realistically contribute to the significant funding of highway infrastructure improvements and therefore there is no doubt that current (perceived/real) congestion issues can be improved and new pressures rebalanced. This would not be possible without such large scale development. Other infrastructure requirements, including health and education facilities, recreation and leisure, employment and retail, and affordable housing can all be properly planned for in large schemes, either providing significant financial contributions that actually make a real difference to provision or they can be accommodated within the scheme itself. Again such developments can come forward to the west of Wrexham town. Merging of settlements (as suggested as one of the "cons" of Option 1) can be avoided through landscape treatment and ensuring there are logical settlement edges. Moreover, sites to the west of Wrexham can be developed whilst still providing a sense of openness, and avoiding complete coalescence. It is also possible though proper place making and master planning to create new green infrastructure throughout the proposed schemes. This would open up accessibility of the countryside, which is currently closed off to the public, being mostly on private land; and would ensure new development is set within a green and pleasant setting. Indeed, questions need to be asked about the quality of the 197 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response Green Barrier between Wrexham Town and Rhosrobin/Gwersyllt, and weighed against the potential loss of more important sites to the south and east of Wrexham Town’s Green Barrier, which are included in Options 2 and 3 and where there are landscape and topographical challenges to overcome. Other infrastructure requirements, including health and education facilities, recreation and leisure, employment and retail, and affordable housing can all be properly planned for in large schemes, i.e. to the west of Wrexham town, either providing significant financial contributions that actually make a real difference to provision or they can be accommodated within the scheme itself. By allowing key service settlements to grow this will ensure all communities benefit from development, remain and have enhanced levels of sustainability. Indeed providing a degree of growth in this manner (for housing, retail and employment) will reduce the need to travel and evidence exists to demonstrate that many communities are really well connected and served by public transport, with few real concerns. This favours a balanced approach with a focus on growth to the west of Wrexham town. Option 3 States that “new infrastructure requirements spread over more locations could lead to extra pressure on public and private finance”. This might be the case, but it is the amount of growth that should be permitted within the hierarchy which is 198 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response the key issue and any uncontrolled / unplanned growth across the smaller settlements should be resisted. This way all settlements can grow in a sustainable manner according to their capacity. The Issues and Options Paper states that Option 1 “will require development on land outside of the settlement limit in the Green Barrier and Special Landscape Areas and will result in the loss of high quality agricultural land and mineral resources of regional and national significance around Wrexham”. The fact is to the east, south and south west of Wrexham there are areas of land that are topographically challenged; are in highly productive Agricultural Land (Grade I, II and III) locations; are within more sensitive Special Landscape Areas and are also Green Barrier and could very easily result in settlement coalescence, whilst areas to the west do not fall within these and are unencumbered by such constraints. Map 2 of the Council's Consultation document illustrates this context and shows that land to the west of Wrexham is unconstrained. The issues and Options Paper states that for Option 1 “Development would not benefit some of the County Boroughs more deprived areas outside of Wrexham Town”. This is not necessarily true. As already noted, to deliver affordable housing for example, as part of a development in a deprived area would seriously undermine viability and thus deliverability. It is likely that deliverability will already be questionable 199 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response in deprived areas. The Planning Authority can adopt an approach which secures a mix of on-site affordable at the large strategic sites, and in part secure financial contributions for off-site affordable housing. This affordable housing could then be delivered at cost within these areas by the developers of larger strategic sites abutting Wrexham Town and in other sustainable settlements within a defined hierarchy. We consider that promoting Option 4 and specifically allowing land to the west of Wrexham to come forward that there are a range of benefits associated with this, namely: • Less contentious land used designations – just green barrier and limited minerals. Green Barrier is common across the County Borough and minerals would not be extracted upon sites that, due to otherwise substantial harm to the amenity of surrounding housing and town, would never realistically be exploited. • Does not have the best grading of agricultural land and in current agricultural production, nor do sites offer any known Special Landscape value. • Coalescence can be reduced (as noted above) without impacting on the openness of the green barrier which cannot be said of some sites to the south and east of Wrexham town; • Proximity to town/ public transport – sustainable travel to school, community facilities, town centre and work etc.; • Opportunity to facilitate improvements to A483 should it be found congestion is an issue; • Opportunity to 200 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response consider social infrastructure due to critical mass of sites, which would just not be possible for smaller schemes and those in areas of the County Borough where the market is weak. • Opportunity to create high quality gateway site at the arrival to the town centre off the A483 and off the A541 raising the profile of Wrexham • Opportunity to ensure lower order settlements (key service and local centres) are able to secure a balanced and proportionate level of sustainable growth 169 Phillip McCormick McCormick Need to allow for settlement Noted RIBA Architecture Ltd development to meet specific residential user needs if the “Vision for the LDP” is to be achieved.

181 Barbara Blanchard ref Robin Morris, Guy Larger car parks which may be This would be a consideration Woodcock Surveyors necessary for Primary Key areas as well at a detailed Planning as further car parks for Local Service Application stage. Centres and will take up a great deal of land which then will affect natural environment and drainage issues. This may only be achieved by covering in more green land.

201 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 247 Arfon Jones WCBC Local The following alternative option should Noted, however no detailed Councillor be explored on the basis that it would further supporting evidence offer the best way forward for the County was submitted to justify why Borough and relieve the pressure on these alternative options already sizeable communities with should be given consideration infrastructure capacity constraints: or be favoured at this stage. Proposed New Option - Option 4 - To focus new development on the primary key settlement of Wrexham Town coupled with new development in the Pentre Maelor and Cross Lanes areas where: • there is a more than adequate land supply • there are now much improved road communications • any new development would be close to the Wrexham Industrial estate and the available employment opportunities 265 Michael Dixon Coedpoeth I believe that this controlled development Noted. Community Council of Option 2 affords the best opportunity to support employment led growth, creating further support for a village (aka a small town) with a population exceeding 5,000 - to the benefit of all. The surrounding green space affords considerable opportunity to absorb growth, whilst still keeping access on the doorstep. Not everyone wants to go hiking and walking, but the boundless opportunity is still there. 293 Cllr David Kelly WCBC - local Maelor underdeveloped Noted. councillor

202 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 436 Peter Mullen Gwersyllt Community The following alternative option should Noted, however no detailed Council be explored on the basis that it would further supporting evidence offer the best way forward for the County was submitted to justify why Borough and relieve the pressure on these alternative options already sizeable communities with should be given consideration infrastructure capacity constraints: or be favoured at this stage Proposed New Option - Option 4 - To focus new development on the primary key settlement of Wrexham Town coupled with new development in the Pentre Maelor and Cross Lanes areas where: • there is a more than adequate land supply • there are now much improved road communications • any new development would be close to the Wrexham Industrial estate and the available employment opportunities The Council commends this alternative option to the County Borough Council.

203 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 639 Mr Steve Jones Llangollen Railway Enhanced non-car dependent transport Noted. infrastructure to the outlying village communities would strengthen the potential growth for this option. For example the reintroduction of a branch railway between Ruabon and Trevor would strengthen the economic growth potential of the peripheral communities of Trevor, Garth, Fron, Acrefair, Cefn, and Plas Madog, open up existing and proposed new affordable housing to commute to work opportunities in the wider Wrexham/Chester/Shrewsbury/Liverpool/ Birmingham corridor and strengthen potential for greater inward tourism to the Pontcysyllte World Heritage Site. In the shorter term the introduction of a parallel footpath/cycle track along the former railway alignment between Ruabon Junction and Llangollen would provide a sustainable green transport link enabling safe routes to schools use as well as enhanced recreation and tourism functionality.

204 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 682 Coal Authority The Coal Authority has provided the LPA These comments are noted with information in respect of the defined and the Council will consult development High Risk Areas for coal with Coal Authority as part of mining legacy and the Surface Coal the LDP process. resource plans. It is noted that the most up to date information provided by the Coal Authority was downloaded by the LPA on 13 November 2014 for both Development High Risk Areas and Surface Coal Resource. It is noted that the surface coal resource and past coal mining legacy is concentrated in the central part of the County Borough area. The Coal Authority would expect this information to inform the policy framework and the identification of site allocations. 769 Cllr Rodney Skelland WCBC Option 1 Wrexham Town Focused Noted. including Key Strategic Sites with a percentage increase (8% -12%) in all other towns and villages where there is a good sound infrastructure, for reason of balance and sustainability without overly burdening the existing infrastructure whilst maintaining the identity of the more rural communities and village. An example to be avoided is the Brymbo scenario where development is completely out of balance with the village by way of size, infrastructure and location (in my opinion). 1939 Howard Cartwright David Cartwright Reclassification of Rossett and Ruabon Noted Solicitor as key settlements, so as to provide an enhanced option 2 should be considered.

205 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 6531 Guy Evans Cassidy and Ashton Development should in the first instance Noted be focused on the primary key settlement of Wrexham with a priority being land to the North West of the settlement boundary to the West of the A483. Further expansion of the development boundary of Wrexham to the south west and east should be more clearly defined to ensure that a natural green barrier in maintained between settlements in these areas. Outside of Wrexham growth should be directed towards the key settlements with some small scale development in and around the local services centres and villages. 6533 Charlene Sussums- Carter Jonas The Plan has made little or no reference Noted. However, the Taylor Lewis to the lessons outlined in the Taylor Review is applicable to Review (2008). In brief, the salient points England only. In relation to that need to be considered by Wrexham Iscoyd being identified as a tier are as follows: • Outdated inflexible ‘tick 4/5 settlement, no map has box’ methodology for determining the been provided to show the sustainability of a settlement has resulted extent of where a settlement in many rural areas being deprived of boundary should be drawn in growth, which has therefore led to the this area. The economic loss of their local services. • Need to activity in this area is recognise what rural communities can be acknowledged, however, it is like without writing them off as not currently identified as a unsustainable. • Key question is whether settlement in the County development will add to or diminish the Borough and given the economic, social and environmental dispersed nature of sustainability of the settlement. • development within the Iscoyd Sustainability trap – permitting area, it therefore not development only in places considered to considered appropriate be ‘sustainable’ in narrow terms. • Sustainability in planning policy can be too focused on access to services and reducing car use. • Viability of local

206 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response shops (in surrounding settlements too) and services are put at risk if settlements are excluded from growth. • Only permitting minimal development in smaller rural communities will drive up house prices and cause shortage of homes that locals can afford. • Small rural settlements struggle to provide the range of housing market options that urban areas have and so a different policy approach is required. • Environmental protection can still be achieved when a better balance is found with high quality small scale development meeting local need. • Ruling out whole categories of settlements as unsustainable ignores the potential for enhancing the sustainability of many smaller rural communities. Planning Policy Wales states that Development Plans should secure sustainable rural communities with access to affordable housing and high quality public services; a thriving and diverse local economy where agriculture‐related activities are complemented by sustainable tourism and other forms of employment in a working countryside; and an attractive, ecologically rich and accessible countryside in which the environment and biodiversity are conserved and enhanced. National Policy advises that development in rural areas should be directed towards local service centres, or clusters of smaller settlements where sustainable functional linkages can be demonstrated. An example of this would

207 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response be Iscoyd. The background paper produced by Wrexham sets out a settlement hierarchy based on the function of each settlement. A tiered approach is used to group settlements of similar characteristic in terms of facilities, services, and growth opportunities. The Settlement Hierarchy defines Rural Villages as ‘range of services available in these settlements is generally confined to those meeting purely local needs. The settlements themselves are surrounded by attractive countryside and some are not conveniently accessible by public transport. New development is therefore restricted to small sites.’ The intention of the settlement hierarchy (as set out in section 1.3) is to rank the settlements within the County Borough based on the level of services they provide, their employment/economic function and their accessibility via sustainable transport methods. The document goes onto state that ‘on the whole the lack of services and ability to access sustainable modes of transport in settlements in both tiers (4/5) make them inappropriate locations for development in sustainability terms. However in some circumstances small scale development to meet local need may be deemed appropriate as windfall development (e.g., barn conversion, infill and rural exceptions) It is therefore considered that in accordance with the Taylor Review and the above paragraph deeming small scale housing development in rural areas as appropriate, Iscoyd should be a Tier 4/5 208 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response settlement due to the level of economic activity. This includes the following: - Iscoyd Park Wedding and Function Business which employs 60-70 staff on a full and part time basis - Park Pre- School at Iscoyd Park which cares for children from infancy to school age - Copper Tree Gallery at Iscoyd which provides for picture framing, works of art and an impressive gallery - Whitewell Parish Rooms at Iscoyd which has recently secured funding for the thriving community centre. - Broad Oak Business Park which provides for a range of business units and small offices. - Iscoyd Park Cricket Club which attract members of all ages. Development of a select infill plot would therefore greatly enhance the viability of the rural settlement and thriving community and boost the numerous economic enterprises and versatility of Iscoyd over the plan period. 7081 David Metcalfe Plas Kynaston Canal There needs to be more clarity about Noted. Group how employment prospects can be improved and transport to and from. 7475 Bryn Richards Local resident Preserve as much greenfield areas as It is important to note that the possible. Do not lose village identity. Spatial Growth Options put Once development encroaches onto forward are not intended to greenfield sites, this identity is lost define precise boundaries at forever. this stage. 7734 John Small DMR (North Wales) Work with builders (local preferably) to Noted. Ltd. make existing brownfield sites easier to develop i.e. helping out with contaminated land disposal which can cost a fortune and is currently making a number of brownfield sites unviable.

209 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders In addition to Option B we consider there Noted. Federation (HBF) could still be room to consider small alteration’s to settlement boundaries in some of the local service centres and smaller settlements (but not as many as option C) to give opportunities for the small house builder and self-builders. 8412 Helen Howie Berrys on behalf of Strategic allocations don't need to be Noted. Tony Jones and confined to Wrexham Town. Land to the Richard Tomlinson north of Gwersyllt would lend itself to a strategic allocation, with potential to be accompanied by improvements to the local highway network. 8455 Michael Dixon Local resident I believe that this controlled development Noted. of Option 2 affords the best opportunity to support employment led growth, creating further support for a village (aka a small town) with a population exceeding 5,000 - to the benefit of all. The surrounding green space affords considerable opportunity to absorb growth, whilst still keeping access on the doorstep. Not everyone wants to go hiking and walking, but the boundless opportunity is still there. 8456 Maureen Williams Local resident A new village/town in South Maelor Noted. including a mix of housing to provide 5000 to 8000 new homes, associated infrastructure, high technology businesses, leisure opportunities, new schools etc., along the lines of the Western Gateway development. 8467 Gill Wilson Butterworth Local Resident More development of existing dwelling Noted. groups, perhaps on the sites of unused farm buildings where they could be removed and 2 or 3 or 4 linked affordable housing units built. 210 Wrexham LDP – Issues and Options Consultation Responses Q.15. Other Suggested Spatial Options/Comments and Officer Responses ID Name Organisation Comments Officer Response 8468 Vincent Ryan Barton Wilmore On Mixture of options 1 and 2. Noted. Behalf of Barratt Developments PLC

211 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses

Q16. What do you think the Council should prioritise in terms of developer contributions?

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County Affordable housing - shortfall Noted. Borough Council - demonstrated in recently completed Strategic Housing HMA. JAH and CIL viability study Services supports a policy of varying requirements dependent on HM areas. Support considerable lowering of existing threshold in areas where development values, returns and viability are healthily accompanied by a robust approach to using 'three dragons' to interrogate developer viability claims whilst acknowledging that in some areas AH will not be deliverable except in limited cases.

212 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 145 Dewi Griffiths Dwr Cymru Welsh As a provider of sewerage infrastructure Noted. Water in the County we are primarily governed by the Water Industry Act 1991 (as amended) whereby we have a duty to extend and improve our assets to accommodate future growth. We aim to ensure that sufficient infrastructure exists for domestic development, and we seek to address deficiencies through capital investment in our 5 year Asset Management Plans (AMP). DCWW have to put forward a business plan for investment for each AMP cycle, and as part of this work we require some certainty in terms of growth areas and site development proposals. An adopted Local Development Plan with identified growth options helps strengthen the case Welsh Water can put forward in relation to projects requiring AMP funding. Our industry regulator, Ofwat, do not usually provide investment for infrastructure to serve unconfirmed growth. Due to the regulatory, financial and legislative framework that DCWW has to work within, there is potential disparity in the timeframes of our AMP and the Local Plans. There may be instances where ‘lead-in’ times are required to bring an infrastructure project and associated funding to fruition. As such, where specific infrastructure improvements are required to bring a development site forward in advance of any investment through AMP, we support the provision within the policy of seeking financial contributions from developers to secure the necessary improvements. 213 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd We recognise the need for developments Noted. of scale to deliver, make contributions and address deficiencies to infrastructure; be this affordable housing, education, POS, primary healthcare, utility services and transportation. However, this must be done in partnership with others and must also be based upon viability. Thus, blanket rates should not be applied arbitrarily as impacts will vary from one site to another; this is where CIL can either fail or succeed. Additionally, thresholds should be appropriate and there must be an acknowledgment that significant developments might have greater impacts than others. 169 Philip Mc Cormick RIBA McCormick The Council should only require Noted. Architecture Ltd developer contributions where relevant and required to facilitate the particular development and should be encouraging development.

181 Barbara Blanchard ref Robin Morris, Guy Proportions of contributions will vary from Noted. Woodcock Surveyors case to case according to the size and position of the development. The number and size of places and facilities would have to be worked out before a commitment of contribution could be decided. All of the above need to be in place and considered according to the predominant age range of new residents.

214 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 247 Arfon Jones WCBC Local The following should be prioritised in Noted. Councillor terms of developer contributions: • School places/new schools • Community facilities, including health provision • Open space provision • Tree planting • Renewable energy • Road structures/local highway works 257 Cllr Brian Cameron WCBC Whitegate Health and education. Noted. Ward 265 Michael Dixon Coedpoeth Community facilities are addressed by Noted. Community Council the many Parish, Village and Community Halls as well as parks and playgrounds. The LDP has the opportunity to enable expansion of schools and modest improvement to the road infrastructure. Whilst householders can be encouraged to make the most of renewable energy I do not believe that WCBC funds, albeit from developers, would be best used in this manner, particularly with the continuing central government support still available, if reduced. So: schools and transport infrastructure. 293 Cllr David Kelly WCBC - local Highways infrastructure Open space Noted. councillor Affordable homes 304 Dr Denis Edwards Local Resident All of above and providing buildings for Noted health care to attract GPs is very important for future healthcare. If developers are asked to build new surgeries or buy and upgrade existing health centres they will get income from the health board. New GPs are not keen to buy into premises any more or make long term commitments to an area which is necessary if you own the surgery. This would attract more GPs to the area.

215 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 305 Mrs V Jones Marchwiel Community All of the above including funding of Noted. Council community facilities perhaps to improve the cohesion of the communities by hosting days to meet their neighbours. Perhaps during gardening or decorating talks, events. 347 Steve Nott Abenbury Community The Council feel strongly that any of the Noted. Council growth options must have a guaranteed commitment to improving the infrastructure. We opposed the Prison on a number of grounds including the impact on the infrastructure of the Borough. Of prime concern is the capacity of Five Fords and the Maelor hospital which will both, in our opinion struggle to meet the existing and extra demands of the Prison. 403 Penelope S J Coles Overton Community The development of the Welsh culture. Noted. Council Suitable places for outdoor recreation. Cycle routes because the ability to cycle to work is useful and important. Improvements to public transport, community facilities. Building communities is important. Bridle ways because there are not enough. 436 Peter Mullen Gwersyllt Community The Council considers that the following Noted. Council should be prioritised in terms of developer contributions: • School places/new schools • Community facilities, including health provision • Open space provision • Tree planting • Renewable energy • Road structures/local highway works 438 Cllr Graham Rogers WCBC - Local The policies to be applied should be in Noted. Councillor line as stated in paragraph 2 (Making it Happen)

216 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 463 Ms Karen Benfield Offa Community Affordable housing - priority. Local Noted. Council schools, health provision, transport infrastructure and open space provision. 483 Cllr Marc Jones Caia Park Community Education/schools Noted. Council 507 Mike Blackshaw Ruabon Community The LDP should ensure all developers Noted. Council should make contributions to enhance all facilities within the development area. 639 Mr Steve Jones Llangollen Railway Enhanced non-car dependent transport Noted. infrastructure to the outlying village communities would strengthen the potential growth for this option. For example the reintroduction of a branch railway between Ruabon and Trevor would strengthen the economic growth potential of the peripheral communities of Trevor, Garth, Fron, Acrefair, Cefn, and Plas Madog, open up existing and proposed new affordable housing to commute to work opportunities in the wider Wrexham/Chester/Shrewsbury/Liverpool/ Birmingham corridor and strengthen potential for greater inward tourism to the Pontcysyllte World Heritage Site. In the shorter term the introduction of a parallel footpath/cycle track along the former railway alignment between Ruabon Junction and Llangollen would provide a sustainable green transport link enabling safe routes to schools use as well as enhanced recreation and tourism functionality. 769 Cllr Rodney Skelland WCBC School places. Design and landscaping Noted. a development

217 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 1918 Mike Barclay WCBC Play The provision and maintenance of public Noted. Development Team open space and the development of a transport infrastructure which helps to reduce people's reliance on cars and increases walking and cycling. 1930 Carys Wynne-Williams Arts Council of Wales n/a NA 1939 Howard Cartwright David Cartwright School places, transport infrastructure, Noted. Solicitor landscaping/tree planting and renewable energy where that is feasible. 3095 Carl Richards Local Resident Transport and community facilities Noted. 5623 Mr M Gilbert, The on behalf of Redrow Any such policy should be strictly related Noted. Planning Consultancy Homes Ltd to the National policy guidance as Section 3.7 of Planning Policy Wales (including passing the CIL test of a planning obligation); in all cases the LPA must be able to demonstrate in a transparent fashion that a contribution is justified by the development. 6533 Charlene Sussums- Carter Jonas Contributions should be site specific and Noted. Lewis led by local community plan of needs 6541 Mrs Carole Roberts - Acton Community Contributions for all of the following: • Noted. Clerk to the Council Council Local Highways Works • Transport infrastructure • Open Space provision • Tree Planting, biodiversity & Landscaping • Health Provision • School Places / new Schools • Renewable energy

218 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 6910 Tim Stratton Wrexham Local As stated previously, accessibility, Green Noted. Access Forum Infrastructure and access to the countryside should continue as a running theme throughout the plan in order that the Vision and Objectives are achieved. Section 6.9 Developer Contributions should include ‘Green Infrastructure - including bridleways and other leisure and recreation activities’ or similar wording as the proposed list would not specifically cover these matters. The Plan sets out to a Vision and Objectives but then does not include Green Infrastructure in one of the mechanisms for delivery. Contributions via S106 and CIL should include Green Infrastructure priorities, which are partly covered within the ROWIP 2007 and UDP Policy T9. The ROWIP is also due to be reviewed before 2017 (for the next 10 years) and is therefore flexible enough to deal with changing circumstances over the Plan period. The ROWIP can form part of the Plan most up to date evidence base. 7081 David Metcalfe Plas Kynaston Canal What is needed for the Cefn area, (and Noted. Group perhaps the whole of Wrexham) is a coordinated approach (which we know is the intention of the LDP) that has to make sense and will promote private investment and productive economic activity. For the Cefn and central Pontcysyllte WHS area this will include improvement to the canals, roads and rail which will develop the right environment for economic growth on a sustainable basis.

219 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 7474 Mr Peter Guy Local Resident I agree that they should contribute to Noted. extra school places and community facilities that would be required in some areas depending on the size of the development. 7475 Bryn Richards Local resident To develop available brownfield sites as Noted. new 'small villages' to incorporate schools i.e. medical centres. Good public transport into Wrexham to benefit town retailers. 7623 David Fitzsimon Fitzsimon Planning Affordable housing Noted. and Development Ltd 7628 Steve Jackson Coleg Cambria Infrastructure development including; Noted. schools, multi-use open spaces to support active lifestyles and community activities, renewable energy. 7732 Matt Ferguson Brymbo Care is needed to ensure that whichever Noted. Developments Ltd elements are prioritised this does not simply add costs to the sites and render them uneconomic. All sites have different characteristics (particularly in terms of land stability, past mining and industrial contamination). Consequently any attempt to obtain developer contributions for wider use must take account of differing site costs and be flexible in its application. If not, development will gravitate to greenfield, higher quality agricultural sites where development costs are low and certain.

220 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 7734 John Small DMR (North Wales) I think the council should prioritise asking Noted. Ltd. large developers such as Redrow to make large contributions, proportional to the size and value of the final site rather than stifling local development by making unreasonable demands of smaller constructors. I feel that the planning process currently works in favour of larger developers. 8298 Leslie Smith L S Planning Ltd Transport infrastructure, schools, Noted. ecological mitigation matters and POS. 8315 Mr Shaun Jones Halls Holding Ltd Schools Noted.

221 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders The HBF do not consider it appropriate to Noted. Federation (HBF) try and prioritize developer’s contributions at this point in the LDP process. It would however make the following comments with regard to any Policy relating to S106 contributions or CIL. Any such Policy should not start from the position that private developers will be able to contribute on every application, or that they are 'expected' to contribute. Reference should be made back to Circular 13/97 which explains in which cases contributions from developers can be asked for/justified. Any Policy should be flexible enough to take account of the viability issues associated with each site. It should allow each site to be considered on its own merits taking into account the local circumstances. The request for contributions can put the viability of the scheme at risk and therefore have the impact of reducing the level of housing development and the provision of affordable housing. Any Policy should also be supported by an SPG which makes it clear and easy for developers to calculate the likely level of contribution required for each scheme as this needs to be factored in at the time the land is acquired. Particularly if the list of potential contributions is long then there will often be the need to decide which is more important rather than trying to secure them all.

222 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 8411 Kate McClean Taylor Wimpey The Council should set their own Noted. priorities based on local needs, however the viability of any developer contributions should be at the forefront of any policy relating to developer contributions. 8430 Susan Evans WCBC, CYP Service, • Affordable housing • School places/new Noted. PSC Department schools • Health provision • Community facilities • Transport Infrastructure • Tree planting biodiversity and landscaping.

8449 Michael Forgrave Gower Homes My concern is that too much Noted. CIL/developer contributions in conjunction with too much affordable housing will render sites unviable. I believe that the council’s prioritise affordable housing far too much. The average affordable house “costs” in the region of £30,000.00 per affordable (2 bed semi houses), which is generally more than the land value of this type of property. I think more use should be made of this cost by CIL/schools contribution/transport infrastructure. There is no grant monies available for private housing schemes – the RSLs keep all grant monies for their own projects nowadays and have since 2012. I would prefer to see CIL in conjunction with a lower affordable housing provision (of say 10%). The council’s open space and affordable housing policies discriminate against the development of starter homes (compared to family homes) because both policies are a percentage of the number of houses that are built. The larger the type of house

223 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response built on any given site the less affordable houses and open space is required. Approximately 20% more open space and affordable houses are required to deliver a site of starter homes than medium sized family homes – as a result very few starter homes are being built. I propose a more equitable solution of say 15% open space on each site and say 3 affordable houses per developable acres (i.e. excluding open space). So every 5 acre site would provide 0.75 acre of open space and 13 affordable houses (.3no x 4.25 developable acres). 8451 Penelope S J Coles Overton Local Access The development of the Welsh culture. Noted. Forum Suitable places for outdoor recreation cycle routes because the ability to cycle to work is useful and important. Improvements to public transport, community facilities, building communities is important. Bridle ways because there are not enough. 8454 Daniel Guy Local Resident I believe Renewable energy and Noted. community facilities should be prioritised.

224 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 8455 Michael Dixon Local resident Community facilities are addressed by Noted. the many Parish, Village and Community Halls as well as parks and playgrounds. The LDP has the opportunity to enable expansion of schools and modest improvement to the road infrastructure. Whilst householders can be encouraged to make the most of renewable energy I do not believe that WCBC funds, albeit from developers, would be best used in this manner, particularly with the continuing central government support still available, if reduced. So: schools and transport infrastructure. 8456 Maureen Williams Local resident School places, transport infrastructure Noted. It is acknowledged in where possible and cost effective, the consultation documents landscaping. that infrastructure improvements need to be aligned with new development, including improvements to the transport networks, utilities, green infrastructure , health, education and social facilities 8467 Gill Wilson Butterworth Local Resident Renewable energy. Noted. 8469 Wendy Sime Local Resident All these are important and the order of Noted. importance should be determined individually for each development by consulting with the community affected. A one-size-fits-all list of priorities is not necessarily the best approach. But for this particular area, south Maelor, it was felt that improvement of local roads, new schools/school places, affordable housing and health provision should be prioritised in that order.

225 Wrexham LDP – Issues and Options Consultation Responses Q.16. Priorities for Developer Contributions and Officer Responses ID Name Organisation Comments Officer Response 8293; Janet Radford AVOW, Public Health It is of vital importance that there is an Noted. 237; Wales, Wrexham asset based approach, what we mean by 7075; County Borough this is that communities and individuals 8309 Council Health should have access to a range of Promotion - working facilities and services which they can use together through to increase resilience, connect with each Public Health other and maintain health and well-being. Commissioning Group We would prefer to see developer contributions used to sustain vital community assets, such as parks, community gardens, and community centres and to sustain community activities. Across Wrexham County Borough there are cutbacks, these impact most on preventative services. A developer contribution could be used to support the maintenance and development of facilities, if a creative, collaborative approach is taken this could be through provision of materials and services as well as financial contributions. We would like to see a third sector grant scheme developed to promote activities that support health and well-being.

226 Wrexham LDP – Issues and Options Consultation Responses Q.17. Comments on Proposed Methods of Monitoring and Officer Responses

Q17. Comments on Proposed Methods of Monitoring?

ID Name Organisation Comments Officer Response 155 Justin Paul J10 Planning Ltd The Council's track record in the timely Noted. delivery of an LDP is poor; slippage has already occurred as part of LDP2 and there is little confidence that the target of adoption during 2018 will be met. Whilst LDP1 failed to make provision for a "Plan B" the Authority is strongly recommended to ensure this LDP2 benefits from an alternative method of delivery should its plan fail to deliver, as can be audited through Annual Monitoring Reports (combined with a Stakeholder Panel meeting every year) and a Plan Review after/every 5 years. Additionally detailed phasing / housing trajectory and certainty about the deliverability of key housing and employment sites will be required. 265 Michael Dixon Coedpoeth This gives the opportunity to review and Noted. Community Council adjust - and to police. Well done. 592 Angela Loftus Denbighshire County Please ensure that LDP monitoring is Noted. Council considered from the outset and that there is a planning related link between objectives and indicators. 1918 Mike Barclay WCBC Play Individuals responsible for leading on the Noted. Development Team play sufficiency duty should be involved in this monitoring process. 1930 Carys Wynne-Williams Arts Council of Wales Please monitor progress with end user Noted. involvement to ensure local buy in into plans.

227 Wrexham LDP – Issues and Options Consultation Responses Q.17. Comments on Proposed Methods of Monitoring and Officer Responses ID Name Organisation Comments Officer Response 5623 Mr M Gilbert, The on behalf of Redrow The broad approach outlined accords Noted. Planning Consultancy Homes Ltd with National guidance, detailed comments will need to await the publication of the Preferred Strategy. 6910 Tim Stratton Wrexham Local The timescale for the replacement of Noted. Access Forum Wrexham's Rights of Way Improvement Plan (see CROW Act 2000) by 2017 is parallel that of the LDP. This is subject to pending legislation which may expand its terms. The LAF and ROWIP are clearly an established and ready-made means of monitoring Green Infrastructure development. The LAF, who work closely with the Cyfoeth Naturiol Cymru/Natural Resources Wales and local communities, could be included on the Council's planning consultation list as a key stakeholder and consultee in related matters. The ROWIP is a statutory requirement and provides the most up to date evidence base for the LDP (as it has with the UDP). There is an obvious and positive relationship to be more clearly established between the ROWIP and LDP. For example, specifically including the ROWIP in the wording of the LDP would help to achieve the LDP Vision and Objectives in relation to Green Infrastructure and the public’s access to the countryside whilst being flexible enough to respond to changing circumstances (as it is a statutory duty to monitor and review the ROWIP). The ROWIP provides more detailed proposals pertaining to access in the Borough. The LAF is a positive and proactive group that aims to promote

228 Wrexham LDP – Issues and Options Consultation Responses Q.17. Comments on Proposed Methods of Monitoring and Officer Responses ID Name Organisation Comments Officer Response access and is supportive of appropriate development across the Borough through the LDP. The LAF welcomes positive and sustainable growth in urban and rural areas particularly where there are community benefits where local rights of way meet the present and likely future needs of the public in accordance with Section 60 of the Countryside and Rights of Way Act 2000. A more detailed statement is to follow. 7081 David Metcalfe Plas Kynaston Canal Yes, the monitoring should be linked to Noted. Group economic viability and include meaningful employment statistics. 7475 Bryn Richards Local resident Make sure consultation is achieved - The consultation arrangements inform residents close to proposed are set out in the Revised development sites of planning proposals Local Delivery Agreement and applications - organise public 2014, available to view on the consultation with Council officials. Council’s LDP web pages. 7628 Steve Jackson Coleg Cambria Monitoring arrangements proposed seem Noted. appropriate. 7734 John Small DMR (North Wales) Follow-up on developers commitments Noted. Ltd. and force them to complete the 'contributions' that they have committed to - I have come across a number of examples where some developers seem to be able to complete only the parts that interest them before selling the properties on. 8315 Mr Shaun Jones Halls Holding Ltd No more than 5% of total income.

229 Wrexham LDP – Issues and Options Consultation Responses Q.17. Comments on Proposed Methods of Monitoring and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders The AMR should include reference to the Noted. Regard will be had to Federation (HBF) new requirement of TAN1 JHLAS to link Welsh Government Guidance the 5 year land supply to the AMR when preparing the framework process. This will allow a much closer for annual monitoring of the eye to be kept on the housing delivery LDP. levels. An additional bullet point is suggested which would relate to the aim of the Council to keep supporting data/ evidence base up to date thus allowing quicker plan reviews if and when required. 8449 Michael Forgrave Gower Homes In fairness the council do not have a The programme for delivery of good track record regarding timely the LDP is set out in the delivery of LDPs. I’m not sure that the Revised Local Delivery department is large enough to deliver the Agreement 2014, available on LDP on time so my suggestion would be the Council’s LDP web pages. to employ more strategic planners for the remainder of the LDP process. 8455 Michael Dixon local resident This gives the opportunity to review and Noted. adjust - and to police. Well done. 8456 Maureen Williams Local resident These are adequate. Noted. 8467 Gill Wilson Butterworth Local Resident The action plan should be easily Noted. understood by all parties, adaptable, flexible and swiftly accomplished.

230 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses

Q18. Comments on Evidence Base

ID Name Organisation Comments Officer Response 67 Mike Jenkins Wrexham County Comprehensive and Strategic Housing Noted. Borough Council - Services have been closely involved Strategic Housing where appropriate. Services 155 Justin Paul J10 Planning Ltd We have real concern over the lack of The LDP needs to be founded any Green Barrier Review, Capacity on sound evidence base. A list Study, Transportation Strategy and other of key evidence base key items that have not been advanced documents is provided in the and/or have not been made available consultation document. The since LDP1 was withdrawn in February Green Barrier review and the 2012. Moreover, little to no emphasis Strategy Network Capacity and has been placed upon the housing crash Improvement Report are both of 2007 and financial crash of 2008 ongoing. (See Appendix 3). which conspired to create the deepest This not meant to be an housing recession since the 1930’s, we exhaustive list and the Council are just starting to come out of what will take account of other economic forecasters describe now as published documents or “the great recession” and the concern commission further research here is that ambitions for growth are during the preparation of the being predicated upon low rates of LDP as necessary. growth and still there appears to be a reluctance to acknowledge that a sustainable spatial strategy needs to be employed. Please refer to our comments made in the separate statement accompanying this submission, which also highlights our concern over the transparency of other evidence base which should have informed this consultation and have been available.

231 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 265 Michael Dixon Coedpoeth This further work has provided a broader This support is welcomed. Community Council and deeper picture, enabling greater understanding of the solutions available to meet the challenges. I welcome the increased work - and Option 2. 347 Steve Nott Abenbury Community May have missed it but could not find This comment is noted. Council clear evidence of the impact of the Prison. 403 Penelope S J Coles Overton Community Some of the documents are difficult to This comment is noted. Council locate. 483 Cllr Marc Jones Caia Park Community Entire plan is skewed by W.G. top down The Local Development Plan Council projections, disregarding historic needs to be founded on a specifics and community need. Large sound evidence base. The scale housing will not deliver affordable 2011 based household housing and address infrastructure projections were produced by problems. There is a very real danger of Welsh Government in urban sprawl linking up villages and February 2014 and form the damaging green barriers. basis of the Strategic Growth options presented. 639 Mr Steve Jones Llangollen Railway Reference and study into potential Objective 9 acknowledges the enhancements in Public Transport as need to reduce the need to opposed to road improvements to cater travel by car. for car based travel growth should be more strongly considered. 1918 Mike Barclay WCBC Play The LDP should also be based on Noted. Development Team Wrexham's Play Sufficiency Assessment 2013. We will also be carrying out a new assessment to be completed by March 2016 which may provide further evidence that could be of use to the LDP. 1939 Howard Cartwright David Cartwright The Housing and Employment figures for These are set out in Appendix Solicitor even the first three quarters of 2014- 1 and 2 of the consultation 2015 would have been helpful, given that document. the 2013-2014 figures appear unusually low.

232 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 6533 Charlene Sussums- Carter Jonas Background Paper – Settlement Noted. Noted. In relation to Lewis Hierarchy. This document should include Iscoyd being identified as a tier Iscoyd as a Tier 4/5 settlement due to the 4/5 settlement, no map has employment generation in the settlement been provided to show the which includes the Iscoyd Park Wedding extent of where a settlement and Function Business, Park Pre-School, boundary should be drawn in Copper Tree Gallery, Whitewell Parish this area. The economic Rooms and Broad Oak Business Park. activity in this area is Note see provided location plan in hard acknowledged, however, it is copy format. not currently identified as a settlement in the County Borough and given the dispersed nature of development within the Iscoyd area, it therefore not considered appropriate 6910 Tim Stratton Wrexham Local A more detailed statement is to follow. Noted. Access Forum 7081 David Metcalfe Plas Kynaston Canal Firstly the Wrexham Retail Assessment These comments are noted. Group only covers Wrexham town centre and In February 2014 Wrexham no other areas in the county like the Cefn The Retail Study provides a full & Cefn Mawr, which is not good. assessment of retail needs Secondly the Settlement Hierarchy gives a false picture of Cefn Mawr and misses within Wrexham, including a out areas and villages of the Cefn. new household survey, to Thirdly the Economic, Employment and inform the preparation of the Retail document is incorrect for Cefn Local Development Plan. Mawr.

233 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 8408 Mark Harris Home Builders It is noted that a range of documents The LDP needs to be founded Federation (HBF) have been provided and many of these on sound evidence base. The have been updated although some of list of key evidence provided in these may require further updating Appendix 3 is not meant to be depending on the timescales associated an exhaustive list and the with the future stages of the plan. It is Council will take account of noted that no reference is made to the other published documents or LDP’s of adjoining authorities and it is commission further research suggested that progress on these needs during the preparation of the to be monitored to ensure the need for LDP as necessary. any cross boundary policy development/ adjustment. Appendix 1 of the Revised Delivery Agreement 2014 sets out the consultation Groups, Organisations, and Forums. B2 includes adjoining Local Planning Authorities.

8409 Rhian Harris HOW Planning on Support the ELR recommendations that Noted. In relation to the behalf of Kingmoor the UDP single user site be allocated for comment on Appendix4, the Park Properties Ltd employment purposes and the size of this site is referred to in development limits of the industrial estate para 7.9 of the UDP. This will expanded to include the site. The details be checked and can be for this site in Appendix 4 are incorrect. rectified if incorrect. The site size should be 39ha. In terms of Furthermore, it does not market availability, this should be indicate that the site should be corrected to state that the land is restricted to a particular available for development. Although employment use class, it earmarked for specific users, there is no merely states what the site had personal permission and we suggest the planning permission for at the development potential be expanded to time of the site survey. If there include general industrial and storage is a need for any reason to and distribution (B2 and B8). restrict the employment use on this site, then this will be

234 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response included as part of a relevant policy in the Deposit LDP, which will be subject to full public consultation.

8412 Helen Howie Berrys on behalf of Page 17 of the Population and Housing Noted. Tony Jones and Topic Paper records that Wrexham CB Richard Tomlinson has failed to deliver sufficient housing for the past 5 years. It is apparent that a step-change is needed to deliver enough housing. It is essential that a good range of size and locations of housing allocations are included in the Plan, to ensure there is ample choice to ensure delivery in the years ahead.

235 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 8430 Susan Evans WCBC, CYP Service, More questions than comments: • Has Noted. The consultation PSC Department there been any research into numbers of document acknowledges that disabled people in Wrexham, and/or Infrastructure Improvements numbers of people with protected need to be aligned with new characteristics which this strategy may development, including affect? • Has there been any research improvements to transport of information gathered about the networks, utilities, green financial impact on Council departments infrastructure , health of developments within Wrexham. For education, and social facilities. example private children’s care homes in Wrexham have had a significant resource impact on the CYP Department including Corporate Parenting, Education, YJS, also Health and North Wales Police. The impact of any development on the Council’s resources should be an area for assessment and this could be included within the objectives of the strategy.

236 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 8449 Michael Forgrave Gower Homes Little to no emphasis should be placed Noted. on the smaller number of housing completions in recent times; the housing crash of 2007 and financial crash of 2008 have conspired to create the deepest housing recession since the 1930’s, we are just starting to come out of what economic forecasters describe now as “the great recession”. I think your inclusion of years 2008 – 2014 within every example of past housing completion rates in your list is extremely misleading. Historically low numbers of houses were built in these years because of the housing crash and the unprecedented banking crisis, indeed in 2012 the number of houses built in England and Wales was the lowest for 90 years. If in your list you excluded the years 2008 – 2014 and showed the period 2001 – 2007 and say 1997 – 2007 I think the average per year would jump to around 550 – 650 houses per year – this is probably a more accurate way of showing more typical numbers of houses being built in the borough. Also the point should be noted that the borough’s population is probably 10% higher now than it was around 2005.

237 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 8450 Ian Howard BCUHB There is a complete absence of evidence These comments are noted relating to health and well-being of the and the Council will consult local population. The statistical evidence with Public Health Wales as can be provided by Public Health Wales. part of the LDP process. If there is due regard to the local population needs assessment then there will be a much greater priority attached to ensuring that people can take care of their own health, be encouraged to make positive lifestyle choices and have access to the services and facilities they need. 8451 Penelope S J Coles Overton Local Access Some of the documents are difficult to Noted. Forum locate. 8452 Helen Howie Berrys on behalf of R Page 17 of the Population and Housing Noted. & C Homes Topic Paper records that Wrexham CB has failed to deliver sufficient housing for the past 5 years. It is apparent that a step-change is needed to deliver enough housing. It is essential that a good range of size and locations of housing allocations are included in the Plan, to ensure there is ample choice to ensure delivery in the years ahead. 8453 Malcolm Ratcliff Mineral Products The Minerals Background Paper will These comments are noted. Association need to be updated with the outcome of The minerals topic paper will the RTS 1st Review and consideration be updated as part of the LDP will need to be given to the safeguarding evidence base. of mineral related infrastructure as well as mineral deposits themselves. A set of development management criteria will also need to be developed to support MSAs, the safeguarding of mineral related infrastructure and mineral proposals. A full justification for ensuring a steady and adequate supply of mineral will be required. 238 Wrexham LDP – Issues and Options Consultation Responses Q.18. Comments on Evidence Base and Officer Responses ID Name Organisation Comments Officer Response 8455 Michael Dixon local resident This further work has provided a broader Noted. and deeper picture, enabling greater understanding of the solutions available to meet the challenges. I welcome the increased work - and Option 2. 8456 Maureen Williams Local resident The evidence is not conclusive since it is The examination of the LDP is based around assumptions that are an independent process for subject to challenge. If correct or even determining whether the plan partly so, many communities will be is fundamentally sound. damaged because of incorrect Having regard to the evidence projections for land use in the future. A submitted with the plan and more considered evidence base is the representations received at needed. deposit , the inspector must determine whether the plan meets the ten tests of soundness set out in the guidance issued by WG and Planning Inspectorate. 8293; Janet Radford AVOW, Public Health There is a complete absence of evidence These comments are noted 237; Wales, Wrexham relating to health and well-being of the and the Council will consult 7075; County Borough local population. The statistical evidence with Public Health Wales as 8309 Council Health can be provided by Public Health Wales. part of the LDP process. Promotion - working If there is due regard to the local together through population needs assessment then there Public Health will be a much greater priority attached to Commissioning Group ensuring that people can take care of their own health, be encouraged to make positive lifestyle choices and have access to the services and facilities they need.

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General Comments

ID Name Organisation Comments Officer Response 682 & Melanie Lindsley Coal Authority WCBC area contains coal resources All of the above should be 1932 capable of extraction by surface mining noted. This helps illustrate the operation covering approximately 25% of issues facing the County with the CB. respect to coal, particularly the Coal resources should not be extent to which the County unnecessarily sterilised by new Borough is constrained by the development, prior extraction would be distribution of coal. Whilst coal sought where this is the case. This can need not be an absolute also remove any potential land instability constraint it is certainly an problems. important consideration due to The Coal Authority owns the coal on the distribution of the coal and behalf of the state and where its associated mining legacy development is to intersect the ground and the distribution of a then written permission may be required number of important from the CA. settlements, including There is a coal mining legacy in Wrexham Town. Wrexham, whilst most is benign, there are potential public safety and stability problems that can occur with development. These can include collapse of mine entries, emission of gases, spontaneous combustion, and the discharge of water. Approximately 1,630 recorded mine entries within WCB with around 90 reported incidents. Mine entries and mining legacy matters should be considered to ensure that site allocations and policies will not lead to public safety hazards. Mining legacy is not a complete constraint as it can be argued that where mining legacy matters have been

240 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses addressed, new development is safe, stable and sustainable. 302 Councillor Alan Local Member Strongly objects to any more land being At this stage in the LDP Edwards WCBC put forward for a large amount of process site specific dwellings before any infrastructure is put allocations are not being in place such as a new school and considered. drainage system. There are still over 100 dwellings at the Gatewen Village site with S106 money for school enhancements, but nowhere for the school to be enlarged. Any further development on Gatewen Road will create enormous traffic problems. Development should be spread out more to the boundaries of the County Borough and not Broughton, Gwersyllt and Tanyfron, which always seem to have the most building. Will not support new LDP until these matters are addressed. 291 Emma Louise Topham Clerk to Minera There is an anomaly in the maps of A settlement in Development Community Council Minera and Coedpoeth. The area of Plan terms relates to the built Nant Llais and Gwernygaseg Road are extent of a village or town. It detailed as Coedpoeth Settlement, but does not relate to the they are looked after by Minera Ward. administration of the Please rectify this. Community. (email sent 26th March 2015) 357 Maurice Paddock Clerk to Gresford Would not wish to see an extension of Noted. Community Council the settlement Areas around our villages (Gresford Marford). Would support infilling provided regard is had to the effects on Doctor’s surgeries, schools, drainage, water services, road and other public utilities all of which are severely stretched and in need of further investment. 8379 Alison Truman Glandwr Cymru, Particularly supports Objective 5 in Noted. At this stage in the LDP Canal and River relation to protecting and enhancing the process site specific 241 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses Trust Pontcysyllte Aqueduct and Canal World allocations are not being Heritage Site. Any site allocations in this considered. location should avoid any detrimental impact on the Outstanding Universal Value of the site and the setting of the historic canal infrastructure. Any development sites identified within or adjacent to the key settlement of Cefn Mawr/Trevor may have the potential to directly impact on the heritage value of the WHS and setting of Pontcysyllte Aqueduct itself. 8442 Heledd Cressey Welsh Government With regard to the scale of change Noted. (Plans Branch) identified, it is for the LPA to evidence and justify the level of housing provision having regard to PPW (9.2.1 & 9.2.2). Also applies to whether they align or deviate from the latest WG projections. The provision should link to any issues the authority is seeking to address, such as affordable housing. It is understood the Plan is seeking to Noted. It is acknowledged that create a strong economy and be the LDP needs to be founded responsive to its location in North on sound evidence base. A list East Wales, recognising close of key evidence base proximity to North West England. documents is provided in the consultation document. The The plan will need to explain and Green Barrier review and the evidence how these issues have Strategy Network Capacity and been embedded in the preferred Improvement Report are both growth option alongside addressing ongoing. (See Appendix 3). other key issues the authority wish to This not meant to be an redress. exhaustive list and the Council will take account of other published documents or commission further research during the preparation of the 242 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses LDP as necessary.

A coherent plan, identifying outcomes Noted. that align and address key issues will stand the authority in good stead. It should be noted that the latest Noted. population and household projections are trend based and characterised by a period of economic decline with an increase in the number of people remaining within existing homes which has resulted in lower levels of household growth and net migration for the majority of LAs compared to the 2008 projections. However, Wrexham has bucked this trend and has continued to grow. You will also need to explain how the Ministers position (CL-01-14) in using the 2011 based projections has been taken into account in the preferred option. LPAs should take a positive approach Noted. and maximise economic opportunities and the implications for housing provision but in the context of deliverability and realism alongside economic potential (should be evidenced by viability testing). Technical work should have tested a Noted. range of scenarios that include housing, economic and demographic led forecasts and made recommendations on housing requirements and job targets over the plan period. Further modelling can

243 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses be undertaken if appropriate (various migration etc. to produce alternative outputs based on evidence). The options paper appears to Noted. encourage economic growth. How this relates to housing will need to be made clear. Two of the options are based on the 2011 projections – consider and explain the implications for this approach and the relationship to the evidence. Need to justify how the level of housing proposed relates to the authority’s own evidence base and aspirations. The implications arising from the economic growth strategy and the relationship to the level of housing will require full explanation. 307 Stuart Whiles RECAP (Rossett As an environmental group we are Noted. It is acknowledged in Environmental mostly concerned about the loss of the consultation documents Community Action open space, particularly as the that infrastructure Programme) extremes of the village of Rossett improvements need to be (Golf Course & Rossett Mill). aligned with new development, including improvements to the transport networks, utilities, green infrastructure , health, education and social facilities.

Concerned about the loss of the Golf Noted. Course to housing – the woods adjoining are rich in wildlife. Any loss of land would endanger one of the largest birds of prey. We believe the woods and lake are a SSSI. There should be no development in Noted. Rossett, and the open space between

244 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses Wales and Cheshire, England and between Marford and Rossett should be maintained. 703 John Moran HSE As there is insufficient information at Noted. this stage in the consultation document on the location and use class of sites that could be developed. We have no representations to make at this stage of the local planning process. HSE acknowledges that early Noted. Consultation with the consultation can be an effective way HSE will continue throughout of alleviating problems due to the LDP process. incompatible development at later stages of the planning process and can provide advice on compatibility as the plan progresses. To assist in meeting the requirements Noted. of PPW and the LDP Regs, information on the location of consultation zones for major hazard installations and MAHPs can be found on the HSE extranet system. All planning authorities have an administrator that can access the HSE Planning Advice for Developments near Hazardous Installations Information Package (PADHI+). Further information is available on http://www.hse.gov.uk/landuseplannin g/padhi.htm Identifying Consultation Zones In Noted. Local Plans – Where there are major hazard installations and MAHPs

245 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses within the Plan area, the associated consultation zones should be marked on a map. The proposals maps may be suitable for presenting this information. Marking the zones associated with any MAHPs is particularly recommended. The pipeline operator should be contacted for up-to-date information on pipeline location. Identifying Compatible Noted. Development in Local Plans - Guidance in PADHI –available at http://www.hse.gov.uk/landuseplannin g/padhi.pdf will allow compatible development within any consultation zone to be identified. The plan should include an analysis of compatible development types within the consultation zones of major hazard installations and MAHPs based on the general advice contained in the PADHI guidance. The sections on Development Type Tables (P.9) and Decision Matrix (P.17) provide information to allow for a general assessment. 219 Jacquelyn Fee Mono Consultants It is important that a Noted. Consultation with the (8448 on behalf of Mobile telecommunications policy remains in Mono Consultants will continue ) Operators place in the emerging LDP. throughout the LDP process Association(8448) Telecommunications plays a vital role in the social and economic fabric of communities. This is recognised through chapter 12 of PPW and TAN19.

246 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses It is suggested that within the LDP there should be a concise and flexible telecommunications policy. Policy suggestion has been given (see consultation response). 639 Steve Jones Llangollen Railway The Wrexham LDP shall safeguard These comments have been Trust Ltd the former railway track bed between noted and will be taken into Ruabon, Acrefair and Trevor and consideration , where relevant onwards towards Llangollen in in the more detailed stages of Denbighshire County as a the LDP preparation Sustainable Green Transport Corridor, to ensure provision for the potential long-term future reinstatement of a Standard Gauge Single Track Railway and parallel Cycle Track/Footway. This would offer social, economic, sustainability and accessibility benefits to the western villages within the County Borough and help connect the World Heritage Site with Wrexham and other existing tourism and leisure facilities within the Dee Valley. Potential housing developments within Acrefair and Cefn Mawr could compromise this provision. Constructing and Implementing Noted. the new railway line – The Ruabon Link group has the priority of campaigning to protect the former track bed from development to ensure the railway line and cycle track can be re-instated.

Delivery is reliant on the Co-operation of Prospect Estates who owns the 247 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses critical portion of the track bed, through the former Air Products site. 436 Peter Mullen Clerk to Gwersyllt Strongly opposed to any option that Noted. It is acknowledged in Community Council would result in large scale residential the consultation documents development in Gwersyllt. Gwersyllt that infrastructure has absorbed more residential improvements need to be development than many other areas aligned with new development, including improvements to the in recent years and is at saturation transport networks, utilities, point. The community of Gwersyllt green infrastructure , health, covers a wide area including: education and social facilities

• the densely populated village of Gwersyllt • Bradley • Pandy • Summerhill • Rhosrobin • Sydallt Increasingly concerned about the genuine infrastructure capacity constraints that are being encountered here. The allocation of additional sites for development will exacerbate the situation. The following are already major sources of concern:

 the inadequacy of the road network  the adverse impact on local schools and, in particular, the older school buildings which are in desperate need of refurbishment  the pressures on vital services

248 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses such as health centres

the transport difficulties facing those who need to travel to their place of work on the Wrexham Industrial estate Concerned that the community of Gwersyllt is becoming a 'soft' target for developers at a time when the preparation process for the new LDP has yet to be completed. This is putting the community under great pressure and is, in the Council's opinion, contrary to the spirit of the Wales Spatial Plan which promotes the building of sustainable communities whilst retaining their character and distinctiveness. The Council urges the County Borough Council to take account of its concerns and fears. 247 Councillor Arfon Jones Local Member The Welsh Government has based Noted. The 2011 based housing numbers on a population household projections were projection that would increase the CB produced by Welsh population by 22% by 2035. This is Government in February 2014 unprecedented and, mirrored in any and form the basis of the Strategic Growth Options. In other Council area in North Wales addition to these projections and has no scientific basis. Even if Carl Sargent (Minister for there was logic to it, it is not desirable Natural Resources) has stated to see such a rapid growth in the that LPAs must provide for the town’s population when existing level of housing based on all infrastructure – health, education, sources of evidence. transport and public services are already creaking.

249 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses This is not a grassroots consultation Noted. It is acknowledged in to assess how many homes are the consultation documents needed in say Coedpoeth or that infrastructure Marchwiel over the next 15 years. improvements need to be The numbers projected (13,010, aligned with new development, including improvements to the 10,030 or 10,100 homes) mean large- transport networks, utilities, scale new villages or commuter green infrastructure, health, estates along the A483 corridor – education and social facilities. creating urban sprawl from Gresford to Ruabon. Developers have already applied for a number of houses at Llay and Rhosrobin, with Ruabon recently being granted permission for 319 homes. These large scale sites are designed for commuters to gain access to the A483. The A483 has already reached capacity at the Posthouse roundabout. There is no joined up thinking as these developments are not connected with industry or jobs. Any Plan needs to be looking at Noted. Please refer to reducing carbon footprints, reducing Objectives. travel by car and creating employment opportunities within communities. The number of homes proposed per Noted. year is unbalanced, with the lowest 710 homes a year. Only 215 homes were built last year and only 426 homes on average were built in the last 10 years, which includes the boom of 2006-7, which saw 945 homes built. Planners are trying to railroad a plan that won’t work. It will speculative housing and put more 250 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses pressure on schools, health services and roads. 477 Nigel Hodges Clerk to Rhosddu There are a number of offices above Noted. Community Council shops that have been vacant for years (BHS, Roxburgh House, King Street, Lord Street, Trinity Street, Regent House). The LA should encourage the conversion of these to residential units. Derelict sites in Penybryn and opposite the Albion Car Park could provide multi storey residential accommodation. The larger villages can accommodate Noted. small growth that would help the local shops, with the older villages having small infill sites that have been vacant for years – these could be redeveloped. The smaller villages need Noted. accommodation for those adult children wishing to stay in the village. Where there is demonstrable need for local people, permission could be allowed subject to S106 agreement restricting occupation to people living or working in the village. This would depress the market value making houses more affordable for local people. 7306 Adrian Walters Flintshire County The growth scenarios are all in line or Noted. Consultation with Council above Welsh Government household Flintshire County Council will projections. Option A (13,010 new continue throughout the LDP homes) is a considerable step process. change above the other two options and needs to be based on firm

251 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses evidence that the level of employment land is realistic and deliverable, otherwise it is an aspirational figure which could bring about higher levels of housing growth without the accompanying employment development. There is a flexible approach the options that have been presented and it recognises that greenfield sites are likely to be allocated. This will enable the spatial strategy to withstand changes to the level of growth required and or the need to add or delete sites later in the process. It is recognised that Wrexham (Town) is the most sustainable settlement in the County Borough, it is not considered appropriate for all growth to take place here (Option 1). Options 2 and 3 are seen as a more appropriate and sustainable approach as they allow some growth to take place in the lower tier settlements. Whatever spatial strategy is chosen, it must be capable of being translated into clear policies which identify and justify the amount and type of housing development that will be allowed in different tiers of settlements. No significant concerns at this stage.

Members are pleased with the realistic options and that the

252 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses relationship between jobs growth and housing provision is being looked at. Members concerned whether Option A is realistic in terms of robust evidence. Members feel that placing all growth in Wrexham Town is not sustainable. Generally supportive of Spatial Option 3 which distributes growth between Wrexham Town, the urban villages and the rural settlements as this provides a sustainable level of development in rural settlements which could help sustain services and facilities. However, the distribution of growth between all settlements should be carefully considered. There needs to be a balance in the rural settlements in terms of meeting local need but not harming the character of these areas. Members concerned about growth that could occur in settlements near the boundary with Flintshire, particularly in relation to coalescence with Flintshire along Mold Road and the pressure placed on services in Flintshire, such as Castell Alun High School in Hope. Members highlight the importance of the Wrexham to Bidston railway line an important transport facility serving both Wrexham and Flintshire and providing an economic role. Flintshire and Wrexham should work

253 Wrexham LDP – Issues and Options Consultation Responses General Comments and Officer Responses together to put pressure on Welsh Government to bring about improvements (electrification) to the line and services (frequency). 6540 Cheshire West and No comments at this stage of the Noted. Consultation with Chester Council process. A couple of queries were Cheshire West and Chester (CWAC) however raised by CWAC in relation will continue throughout the to the evidence base on population LDP process. and housing growth and the Employment Land Review based upon a misunderstanding of the findings. These issues have been resolved and CWAC had no further comments to make. 8295 Peter Scott WCBC Economic Section 1.7 - In the description of the Noted. However this detail will Development county and its spatial characteristics be best included within the – it is right to stress the importance of supporting evidence base links to Chester and Deeside documents. However, considering the map/plan of

north Wales – the plan and the document should more fully recognise the economic geography of North East Wales. The plan should show the wider Mersey Dee Alliance area – access to airports at Liverpool and Manchester.

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