M3.01R: Wrexham County Borough Council's Response to Action Points

Home , Bersham, Brymbo Steelworks, Caego, Gresford, Pentre Bychan, Rhosnesni

M3.01R: Wrexham County Borough Council’s response to Action points 1 and 2 from Matter 3: Housing Provision

1. Introduction and Background

1.1 This note has been prepared by Wrexham County Borough Council (WCBC) in response to the Inspectors’ action points raised during the Matter 3: Housing Provision hearing on the 4th September 2019. The main focus of the report is action points 1 and 2 as these have the most significant implications for the Plan in terms of changes. The Council has provided a revised housing trajectory in responding to these two action, and will, as part of the Matters Arising Changes address the presentational issues around conformity with DPM3 in relation to the trajectory, tables and diagrams (action point 3) as well as action point 4.

1.2 This response will inform the additional Matter 3 hearing on 10th October 2019.

1.3 In reporting to the Inspectors on these action points, the Council has consulted the appropriate Councillors in accordance with the scheme of delegation agreed by the Council.

1.4 The Councils key points are provided in Paragraphs 3.10, 5.11 and 8.1 below.

2. Action Points

2.1 The action points which this report relates to are:

1. Committed sites - make available (by 19th September) a report on individual sites that are committed, taking account of Welsh Government (WG) advice on categorising sites being brought forward in Development Plan Manual 3 (DPM3). Those who had objected to committed sites would have an opportunity to respond to the Council’s additional work.

2. Table 4 of BP08b (Windfall sites) (double counting) - explain by 19th September why the Council has applied 9 years (surely the first 3 years or so will be sites already committed (Table 4 of BP08b) and address subsequent triple counting issue.

3. Housing Trajectory - consider how the housing trajectory and other tables/diagrams in DPM3 could be included in the Plan along with any monitoring indicators

4. Policy SP1 - consider adapting the wording of criterion d) so that it is meaningful without being too restrictive. Remove criterion f) and consider whether it is better placed in other housing policies. Consider whether viability should relate to criteria other than criterion b).

3. Action Point 1 - Committed Sites

3.1 There are two elements in relation to this action point: the presentation of information in line with DPM3 as per Welsh Governments (WG) hearing statement (M3.02) and clarification of the committed sites (sites with Planning permission) paragraphs 3.7 -3.10 and Appendix 1.

Presentation of information

3.2 DPM3 updates the 2015 Manual. It was released for consultation following the publication of the Plan and provides guidance (for the first time) for Local Planning Authorities in relation to the presentation of components of housing supply, in order to ensure consistency across Wales on how the calculations are presented.

3.3 Following comments made by WG on the Plan in 2018 and the publication of DPM3 in May 2019, the Council has been in discussions with WG officers about the components of the housing land supply, the housing trajectory (the rate at which houses are developed over the Plan period) and the 5 year land supply calculations.

3.4 The housing commitments identified in the Plan are based on the position as of the 1st April 2017 which is now over 2 years out of date. In responding to the Inspectors’ request for information, the figures have been updated to the 1st August 2019 which provides an up to date position on committed sites and the resulting required allocations.

3.5 The information has already been provided in Background Paper 08 and updated in subsequent revisions (BP08a and BP08b in August 2019) as a result of discussions with WG. Paragraphs 5.58 to 5.69 of DPM3 set out how the housing land supply should be addressed and presented in LDPs.

3.6 In accordance with the comments made by WG in their hearing statement for Matter 3 (M3.02) the following changes are proposed to the Plan which will be advertised as Matters Arising Changes (MACs) at the end of the hearing sessions:

a) Table 4a (BP08 and as amended by BP08a) and b) - components of the housing supply by settlement tier, and any necessary updates to it, will be added to Policy SP1 in the Plan under Table 1. b) Table 19 (BP08 and as amended by BP08a) and b) - Housing Trajectory and 5 year land supply calculation (Appendix C of BP08) along with the detailed housing trajectory (Appendix B and Chart 2 of BP08) and any necessary updates to them will be added as an Appendix to the Plan. c) Monitoring Framework - the Plan will include robust and comprehensive indicators to monitor the delivery of housing based on the indicators listed in Chapter 8, Table 29, of DPM3. This will be dealt at the Matter 16 Hearing.

Delivery of Committed Sites

3.7 At the Matter 3 hearing on the 4th September, the Council provided a copy of BP08b (August 2019) which had been made available prior to the hearing session on the 2nd September on the Council’s webpages. Table 6 of BP08b shows the committed large sites within the housing supply as of 1st April 2019 as taken from the Housing Monitoring Report (MRH06). Table 4 of the BP08b provides an overview of the housing provision as of 1st August 2019 (see paragraphs 5.5 to 5.11 below for further information on this, along with Appendix 1).

3.8 A number of objections were raised in the hearing statements for Matter 3 and reiterated during the hearing in relation to concerns over the delivery of 4 of the committed housing sites and 1 site referred to in Appendix A of BP08 (January 2018) as a potential source of windfall development (Llay003NUCS).

3.9 A summary of the committed sites (as of 1st April 2019) objected to along with the Council’s response is summarised in Table 1 below. Full details of the committed sites are provided in Appendix 1.

Table 1 Site No. Council Response Implications Units for the Plan Hafod Tileries 300 The Council has already addressed this None issue in the Housing Monitoring Report 2019 (MRH06) following feedback from Hourigan Connolly, the agents acting on behalf of Gladman, the site owner. These figures are neither included in the committed supply nor the trajectory. Llay003NUCS 7 This site was included as a potential None future windfall site in Appendix A of BP08. Although not directly forming part of the components of the housing supply in the Plan, it was part of the evidence in support of the windfall allowance. This site has since been identified as public open space and therefore removed from Appendix A. These comments were made at LDP Deposit Stage and the Council supported its removal. Former Air 232 This site is included in the 2019 Housing Should the Products Site, Monitoring Report MRH06 on the basis of Inspectors Acrefair information received from Rob Cooke in agree with the October 2018. It was confirmed that 100 objections to dwellings would be completed in 5 years, the delivery of with 132 beyond 5 years. The HBF was the site, it consulted and raised no objections. could result in This site is also included in the housing the loss of 232 trajectory as follows: 21/22 - 30, 22/33 - units from the 30, 23/24 - 40, 24/25 - 33, 25/26 - 33, overall supply 26/27 - 33 and 27/28 - 33. of housing

No evidence has been presented to over the Plan indicate that this site is unlikely to come period which forward and the Council has relied on the would result in information provided by the applicant, the need for which has been accepted by the HBF as the Plan to part of the consultation on the 2019 address the housing monitoring report. shortfall.

This site has outline Planning permission and the Council are aware that discussions have been had with a national housebuilder to deliver the site. No objections to its inclusion in the 2019 monitoring framework (MRH06) have been raised by the HBF. There is no evidence submitted by objectors to suggest that it won’t come forward over the Plan period which extends to 2028 and the Council maintain that it should remain within the committed supply. Westminster 30 The Council has accounted for the None Industrial reduced number of dwellings (30) on this Estate, site as set out in MRH06 and in the Gwersyllt detailed housing trajectory. The trajectory sets out 10 completions per year from 21/22. Ruabon 319 Pure Commercial advised on 8th August None Business Park, 2019 that it is likely that 175 dwellings will Ruabon be completed in the next 5 years with 144 in the years that follow. These figures were included in the Housing Monitoring Report 2019 (MRH06) which was consulted on with HBF who raised no objections. A detailed trajectory was also provided: 21/22 - 65, 22/23 - 55, 23/24 - 55, 24/25 - 50, 25/26 - 50, 26/27 - 44.

3.10 The Council is satisfied that the Former Air Products site, Acrefair will be delivered over the Plan period for the reasons set out in Table1. It is the Council’s view that there is no need to remove this site from the committed supply.

4 Action Point 2 - Windfall Sites

4.1 The potential for double counting between the delivery of the sites forming part of the committed supply and the allowance made for the delivery of large windfall sites was raised during the hearing session. WG, in their Matter 3 response (M3.02) suggest that in the housing trajectory there should be no duplication between windfall sites and the supply in the short term.

4.2 The Plan sets out an allowance for windfall sites of 195 units per annum which comprises 120 units on large sites and 75 units on small sites. The allowance for small sites does not need to be adjusted as these are not accounted for anywhere else in the housing trajectory or overall supply, in line with WG guidance.

4.3 Prior to addressing the issue of double counting on large sites, it is useful to provide some background context to the windfall sites allowance in the Plan. Based on the historical average contribution of small and large windfall sites to housing development over the past 17 years (285 units per annum, table 10, BP08b), the Council believe that the windfall allowance (195 units per annum) in the Plan is a reasonable and conservative assumption about the future delivery of windfall sites for the remaining Plan period. The Council have already reduced the total windfall (small and large sites) allowance by 32% compared to past trend data.

4.4 Past trend data for large windfall sites over the same period shows an average of 160 units per annum, which also suggests that the large sites contribution could justifiably be much higher. The Council have reasonably reduced the large sites windfall contribution by 25% and do not believe that the allowance for large sites is too high. In addition, the fact that 788 windfall units have been approved by the Local Planning Authority since the 1st April 2019 and the 1st August 2019 (now in the committed supply – see table 3 and 4 in section 5 below) further justifies that the large sites windfall allowance could be much higher than is identified in the Plan.

4.5 It is expected that the Plan makes provision for windfall development to come forward over the plan period and it is also reasonable to discount the past average windfall completions given that by their very nature windfall sites are to a large degree unknown. Additionally, evidence1 also demonstrates a diminishing source of windfall site supply within existing settlement limits, which has resulted in the conservative estimate identified in the plan for large sites (120 per annum).

4.6 Turning to the issue of double counting, upon further investigation, it would appear that there is a degree of double counting between the allowance made for large windfall sites (120 per annum) and the delivery of the committed sites (i.e. sites with planning permission, see table 4 BP08b and the housing

1 EBH01, WCBC Urban Capacity Study, 2007 https://wrexham-consult.objective.co.uk/portal/ldp_ebsd trajectory and 5 year land supply calculations shown in Appendix C of BP08b) (August 2019), rows G and H demonstrate this point), particularly over the next few years (2019/2020 and 2020/2021).

4.7 It has already been established that there should be an allowance for windfall development over the Plan period and that there is no degree of double counting in relation to the small sites allowance (75 units per annum over the Plan period). The issue relates to the double counting of large windfall sites and their categorisation within the committed supply over the next few year (2019/2020 and 2020/2021).

4.8 The committed supply (see table 3 and 4 and Appendix 2) consists of land with planning permission and is made up of UDP allocations (of which there are 249 deliverable units with planning permission) and large windfall sites. Since the expiry of the UDP in 2011, the majority of sites in the committed supply (i.e. land with planning permission) are windfall sites, reflective of the fact that there has been no up to date replacement plan in place. This is why it is imperative that a replacement plan is adopted as soon as possible to ensure a plan led system.

4.9 This element of double counting is only the case for the next few years (2019/2020 and 2020/2021), not for the entire Plan period as once the Plan is adopted (anticipated 2020), the majority of development will be on allocated sites (with some windfall development from small and large sites, of the order of 195 units per annum).

4.10 In order to address this issue, it is proposed that the large sites windfall allowance is applied to the remaining 7 years of the Plan period (i.e. from 2021/2022 onwards).

4.11 The Council is aware of local examples of large sites which have been or are in the process of being developed in the County Borough which justify the large windfall allowance being applied to the remaining 7 years of the Plan period Local evidence suggests that from the submission of planning applications to the recording of units completed takes on average 22 months (Appendix 3). The resulting implication of applying the large windfall site allowance to the remaining 7 years of the plan period is shown in table 3 and 4 of section 5 below in relation to action point 3.

5. Housing Trajectory (Action Point 3)

Delivery of Allocated Housing Sites

5.1 A number of objections were raised in the hearing statements for Matter 3 and reiterated during the hearing in relation to the delivery of 8 of the allocated housing sites.

5.2 A summary of the sites objected to along with the Council’s response and implications for the Plan is summarised in Table 2 below. Full details of the site allocations are contained in Appendix 4.

Table 2 Site No. Council Response Implications for the Plan Units Lower 200 Extensive engagement has taken There is the potential that Berse Farm plan place with the landowner, agent and further units could be (KSS1) period developer about the future delivery of delivered in advance of the housing on this site. Redrow/SCP those identified in the believe that there is highway capacity current trajectory (2026) to deliver development before junction due to the evidence 4 improvements are implemented, provided in the Statement of potentially including some interim Common Ground (SoCG, mitigation. It is maintained, that at SoCG004) by WG transport least 500 can be delivered over the which states that J4 works plan period. are likely to commence in spring 2022 resulting in a potential further 200 units being delivered on this site which could offset the need to release as many other housing sites for allocation. This is covered further in section 6 below. Land East 1580 Extensive engagement has taken None of Cefn plan place with the landowner, agent and Road period developer about the future delivery of (KSS2) housing on this site. A Planning application for 600 dwellings is currently being considered by the Council on the northern part of the site.

Barton Willmore on behalf of Barratt Homes and Bloor Homes in their Statement for Matter 3 (M3.11) confirm their position in relation to the proposed trajectory for this site.

J10 Planning on behalf of CPPL in their statement for Matter 3 (M3.14) confirms that CPPLC can bring forward 500 units without the spine road, which enables quick delivery. Planned contribution of 120 units over 2020/21 period, which is high due to PRS and timber frame construction. They further confirm that 460 units can be delivered by 2023, with 1000 by 2028. They refer to Norris Green where delivery rates were rapid (850 units). Land 375 Response by J10 Planning dated 8 None adjoining plan March 2019 indicates that Planning Mold period application is likely to be submitted Road/A483 during 2019 with commencement of (H1.1) development taking place in early 2021. It indicates that the site may be developed by two developers in tandem. Completions of 45 per year in 21/22, with 60 per year over the following 5 years and 30 in 27/28. Land off 180 Response received from Kronospan None B5070, plan 05/03/19 confirming expected Chirk (H1.6) period completions of 20 per year in 23/24 and 40 per year in the following 4 years Stansty 96 plan Response from Fishergerman None Fields, period 26/02/19 confirming expectation of 20 Stansty, completions in 21/22, 40 in 22/23 and Gwersyllt 36 in 23/24. (H1.7) Home Farm 362 Development commenced in early None Llay (H1.10) plan 2019. Developers anticipate site period being built out by 23/24. Land adj. 35 plan Email 06/03/19 from the agent (Peak None Sycamore period Architectural) anticipates 10 House, completions per year 25/26 and 26/27 Wrexham with 15 in 27/28. There have been Road, Holt two companies interested in (H1.13) developing the site. Rossett 137 Outline Planning application refused 7 None (H1.16) plan January 2019. Applicant intends to period appeal. Interest received from 15 housebuilders. Completions of 42 expected in 21/22 and 45 per year in the following two years.

5.3 The Council maintains that the sites objected to, as contained in Table 2, can be delivered over the Plan period. A trajectory for each site has been agreed with the agent, land owner or developer as a result of extensive engagement. In determining these delivery forecasts, consideration has been given to ‘time lags’ such as the time between pre-application discussions, the determination of an application and the discharge of conditions.

Delivery of Sites Granted since 1st April 2019 to 1st August 2019

5.4 In BP08b reference is made to sites that have been granted Planning permission since 1st April 2019 as contributing to the overall housing supply. However, concerns were raised in relation to the lack of information about the future delivery of these sites.

5.5 Since the hearing session, the Council has collected delivery information on sites between 1st April and 1st August 2019, which is included in Appendix 2.

5.6 The additional sites granted permission since 1st April 2019 (i.e. commitments) have also been added to the detailed housing trajectory (taking the trajectory up to the 1st August 2019) and have been used to calculate the overall housing provision and 5 year land supply (see Tables 3 and 4, below). The trajectories are included in Appendix 5.

Impact on Overall Housing Provision, Components of the Housing Supply and the 5 year land supply.

5.7 Adjusting the windfall allowance on large sites for the remaining 7 years of the Plan period (to avoid possible errors in double counting units on large windfall sites in the first 2 years of the Plan) and adding in the sites granted permission up to 1st August 2019 produces the outcome set out in Tables 3 and 4) below. The trajectory is shown in Appendix 5.

Table 3 Updated LDP Housing Components (2013 - 2028) if 2 years of the large windfall allowance is removed (i.e. applying the windfall allowance for 7 years of the Plan period) Components Sub-components No. of dwellings Sites Completed Sites (2013-2019) 1561 Committed Deliverable Large Sites over 1973 remaining plan period (1st September 2019) S106 Sites (Pending at 1st April 2019) 16 LDP Allocations deliverable within the plan period 3366 Sub-total 6916 Allowances Large Windfall Sites (120 x 7) 840 Small Windfall Sites (75 x 9) 675 Sub-total 1515 Total provision 8431

Table 4 LDP Housing Components by Settlement Tier (2013 - 2028) if 2 years of the large windfall is removed (i.e. applying the windfall allowance for 7 years of the Plan period) Components of Housing Tier Tier Tier Tier Tier Other Total Supply 1 2 3 4 5 A Total Completions (Small 694 338 407 96 20 6 1561 and Large) 1st April 2013 to 31st March 2019 B Commitments 794 827 352 0 0 0 1973 1st September 2019 (Deliverable over remaining plan period) C S106 at April 2019 11 5 0 0 0 0 16 D Housing Allocations 2180 748 359 79 0 0 3366 E* Large Windfall (120 pa X 318 314 183 15 10 0 840 7)* F* Small Windfall (75 pa X 9)* 152 236 164 93 20 10 675 G TOTAL Housing Provision 4149 2468 1465 283 50 16 H Overall Total 8431 *The windfalls have been apportioned in line with past windfall completion rates by Settlement Tier for the period 2009-2019 rounded to Zero DP.

5.8 The housing requirement in the Plan, under Policy SP1, is 7750 and provision has been made for 8525 which allows for 10% flexibility should any of the allocated sites not be delivered.

5.9 Taking account of the revised housing provision as shown in Tables 3 and 4, above (8431 dwellings) leaves a shortfall of 94 dwellings over the Plan period.

5.10 In terms of the resulting 5 year land supply, this is set out in Appendix 5 and is summarised in Table 5, below. It shows that there is currently a 6 year land supply, which reduces to 5 in 2023, 4 in 2026 and 3 in 2028. It is accepted that the 5 year supply will trail off when there are less than 5 years of the Plan remaining (Paragraphs 5.68 and 5.69 of the DPM3). DMP3 also indicated that the focus for examination should be ensuring that the Plan can broadly deliver a 5 year supply over the Plan period, with a focus on the short/medium term supply. Plan review is a statutory requirement after 4 years where this issue would be re-examined.

Table 5: 5 year land supply (with 2 year large windfall removed) Year A B C D 5 Year Housing Annual Requirement Total no. Land Supply in Requirement* (A/5) dwellings to be Years built within 5 (C/B) years* 2019 3471 694 4185 6 2020 3708 742 4381 6 2021 3804 761 4433 6 2022 3747 749 4274 6 2023 3591 718 3918 5 2024 3213 643 3320 5 2025 3022 604 2829 5 2026 2884 577 2398 4 2027 2713 543 1930 4 2028 2644 529 1575 3

5.11 In summary, the Council believe that provision is required for an additional 94 dwellings (based on applying the windfall allowance for the last 7 years of the Plan period). Section 6 of this report below looks at addressing this shortfall.

6. Addressing the shortfall

6.1 The Council believe that there is a shortfall of 94 dwellings over the Plan period for the reasons set out above. Addressing this shortfall could be achieved by i) allocating additional sites or, ii) bringing forward the delivery of additional units on sites that are already allocated in advance of when they are currently anticipated within the trajectory.

6.2 Looking at the two options in further detail:

i) Additional allocations

6.3 Appendix 7 (Reserve Sites) provides the background to the ‘B list’ sites and other reserve sites. In total, of those with potential to be developed (i.e. they are located in tiers 1-4, the constraints on the site are likely to be able to be mitigated and are viable to deliver) these sites have the ability to provide 828 units (Table 6 below). Sites in Tier 1 of the settlement hierarchy in the Plan should be considered for allocation if required in advance of those in Tier 2, those in Tier 2 in advance of Tier 3 and so on, in accordance with the spatial strategy set out in the Plan.

6.4 Should the Inspectors feel that there is a need to allocate additional sites, the green and amber sites from the reserve list in Appendix 6 is set out in Table 6, below and could be could be considered for allocation. Maps of all the sites (red, amber and green) are available to view in documents KPD07a (Site Register), KPD19 and KPD19a (Sites submitted at deposit and addendum) and KPD20 (amendments to proposals maps) which are available on the consultation portal.

6.5 By way of an explanation of the red, amber and green categorisation, the green and amber sites were submitted during the pre-deposit stage of plan preparation and have been assessed in accordance with the Candidate Site Assessment Methodology (BP4a) incorporating the SA. They have the ability to become potential allocations if required with the green sites being the preferred allocations (due to there being more certainty that the constraints can be mitigated and they are deemed to be more deliverable compared to the amber sites). The red sites are sites that have been rejected for various reasons as set out in Appendix 7 and 8.

6.6 Should the inspectors feel that there is a need to allocate further sites, it should be noted that all changes to the plan (Matters Arising Changes), will be subject to further SA/HRA assessment with the results made available for consultation with the Matters Arising Changes Report.

6.7 In addition, during Matter 3, a number of sites which are being promoted by site proponents were identified and the Council were asked to clarify its position in relation to these. This is detailed in Appendix 8, but in summary the sites were either submitted too late in the LDP process and did not include the required assessments in relation to SA/ SEA and HRA, there was a lack of information in relation to the submissions to demonstrate that adequate mitigation could be provided to overcome site constraints or the sites did not accord with the Plans spatial strategy. For the avoidance of doubt these sites are included in the list of sites identified as red, amber or green in Appendix 7.

Table 6: Reserve sites Tier 1 Settlements Source Site Units Comments Plan Period B List WRO5CS 15 No developer, possible highways 15 Llwyn Onn constraint, possible windfall WR20CS Delivery of 200 Sustainable, not delivery within the first 200 KSS1 sooner 5 years of the Plan period, but can than planned deliver over the Plan period Total 215

Tier 2 Settlements Source Site Units Comments Plan Period B List CH01OS 40 Extension to the Chirk allocation which 0 delivers only within the last five years of (40 outside the plan period, an extension will deliver Plan period) outside of the plan period B List CH03OS Dependent on the Chirk allocation which 0 delivers only within the last five years of the plan period, an extension will deliver outside of the plan period B List GRE09CS 132 Questionable density, designated green ? wedge, landscape values. B List GRE15CS 110 Density, smaller site subject to an ? application which has been refused for 40 units NSP NSP009 10- Highways constraint, limited potential for 15 GRE004AS 15 small scale development c. 10-15 units Vicarage Lane/ Hillock Lane NSP NSP011 82 Current application, deliverable 82 Summerhill NSP NSP022 Duplicate - See GRE15CS above ? Vicarage Lane NSP NSP033 60 Council owned, affordable, has been 60 CH04CS Chirk through SA, constraints can be Green overcome with a smaller scale proposal, deliverable by Council/RSL but funding and phasing to be agreed Total 157 Tier 3 Settlements Source Site Units Comments Plan Period B List O05OS 25 Deliverable 25 NSP NSP012 – 25 Been through the SA, deliverable 25 O04OS Bangor in first five years Road NSP NSP013 – Duplicate see above 0 O05OS NSP NSP014 – 25 Deliverable in first 5 years, been 25 O06OS adj St through SA Marys school NSP NSP056 Brymbo 350 The part of this proposal within the 350 Steelworks settlement boundary has potential as a windfall, but not in the first 5 years of the Plan (highways and deliverability concerns). The rest is outside settlement boundary. APM APM08 Extension 15 Deliverable 15 to allocated site Caego Total 440

Tier 4 Settlements Source Site Units Comments Plan Period B List BRN06CS 15 Deliverable 16 Bronington School Total 16

Tier Units

1 215 2 157 3 440

4 16 828

ii) Bringing forward units on allocated sites in advance of that identified in the trajectory

6.8 A more sustainable approach than allocating additional land is to bring forward units sooner than currently anticipated within the trajectory on already allocated sites. This relates to KSS1 for which the Statement of Common Ground with WG2 states that works to J4 on the A483 are likely to commence in spring 2022. Based on the delivery rates in the trajectory, it is possible that this site could bring forward a further 200 units in the Plan period to meet the shortfall earlier than currently anticipated.

6.9 This is the most sustainable, logical and sound option, supporting the Plans identified spatial strategy which would mean that should the Inspectors agree with the Council in relation to the windfall position as set out in section 5 above, that there would be no need to allocate further sites from the reserve sites identified in Table 6 as this option covers the identified shortfall and provides further flexibility to the Plan.

6.10 It should be noted that in consultation with the Members that they wished to reiterate to the Inspectors that no dwellings should be occupied on KSS1 unless and until the works to Junction 4 have been completed, as per the wording of the existing SP4 policy. This is crucial for the site and for the Plan as a whole. Because of this, they have strong misgivings about the likelihood of these dwellings coming forward. Of course, ultimately, it is a matter for the Inspectors to decide on the evidence.

7. Action point 4 - Policy SP1

7.1 The Inspectors have asked the Council to consider adapting the wording of criterion d) so that it is meaningful without being too restrictive, to remove

2 SoCG004 Statement of Common Ground between WCBC and Welsh Government for A483 Junctions 3 -6 https://wrexham-consult.objective.co.uk/portal/examination_library_page criterion f) and consider whether it is better placed in other housing policies and consider whether viability should relate to criteria other than criterion b).

7.2 These issues are considered to be minor amendments in the context of the scheme of delegation and are matters which will be responded to by the Chief Officer and consulted upon in the Matters Arising Changes (MACs) schedule in due course.

8. Conclusions and Suggested Changes

8.1 The Council believe that provision is required for an additional 94 dwellings over the Plan period as a result of removing the large windfall sites allowance (120 per annum) from the first two years of the Plan and applying this to the remaining 7 years. The most sustainable and sound option to meet this need is via the delivery of additional units from Key Strategic Site 1 in advance of that identified in the housing trajectory, subject to the proviso that Junction 4 is improved first - as this has implication for the whole Plan and not just KSS1. The senior Members remain concerned about this course of action, but it is a matter for the Inspectors to determine on the evidence.

8.2 The Council is mindful that the Inspectors are yet to examine the evidence in relation to the Key Strategic Sites (KSS). Should this approach be acceptable to the Inspectors, there would be a requirement for the wording of Policy SP4, to be amended, with the proviso that none of the units on KSS1 can be delivered until works to Junction 4 have been completed (as is in the currently worded policy).

8.3 It is suggested that this could be dealt with as a Matters Arising Change (MAC) in due course.

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Appendix 1: Committed sites: Objections and Council Response

Site No. Ref Name Objection Response Resulting units no. units Hafod Tileries 300 M3.03 Hourigan Despite extensive marketing a The Council have already 0 Connolly on buyer has not yet been secured addressed this issue in the behalf of for this land and there is no Housing Monitoring Report 2019 Gladman prospect that the site will start to (MRH06) following feedback deliver. Para 3.16. Delivery of from Hourigan Connolly the the site during the plan period is agents acting on behalf of uncertain and not realistic to Gladman, the site owner. These include in the housing trajectory. figures are neither included in M3.14 J10 Questions the delivery of this site. the committed supply nor the Planning on Outline permission granted 2 trajectory. behalf of October 2015 but no progress. Countryside Properties Plc M3.15 J10 Planning on behalf of Bellis Bros M3.16 J10 Planning on behalf of Gower Homes M3.05 Lichfields on Has outline permission and is behalf of expected to deliver sites in 19/20. Taylor There is no evidence that this site Wimpey has progressed through the necessary planning application

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Site No. Ref Name Objection Response Resulting units no. units processes.

Refers to Lichfields’ ‘Start to finish’ research document on delivery rates and that for developments of 100-499 it takes a little over 4 years to go through the planning approval and delivery process. More appropriate for delivery to commence in 22/23. M3.09 Fischer The trajectory indicates that the German on site will begin delivering 30 per behalf of a year from 2019 rising to 35 from consultee 2022. However, there is no RM application and as such there could be 2 or more years before any delivery. LLAY003NUCS 7 M3.04 Consultee This site should be removed as a This site was included as a 0 M3.06 Consultee potential windfall site as it is potential future windfall site in M3.07 Consultee public open space. Appendix A of BP08. Although not directly forming part of the components of the housing supply in the LDP, it was part of the evidence in support of the windfall allowance. This site has since been identified as public open space and has therefore been removed from Appendix A. These comments

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Site No. Ref Name Objection Response Resulting units no. units were made at LDP Deposit Stage and the Council supported its removal. Former Air 232 M3.14 J10 Questions the delivery of this site This site is included in the 2019 232 Products Site Planning on over the plan period. Housing Monitoring Report Acrefair behalf of MRH06 on the basis of Countryside information received from Rob Properties Cooke in October 2018. It was Plc confirmed that 100 dwellings M3.15 J10 would be completed in 5 years, Planning on with 132 beyond 5 years. The behalf of HBF were consulted in relation Bellis Bros to MRH06 but raised no M3.16 J10 objection to this. Planning on This site is also included in the behalf of housing trajectory as follows: Gower 21/22 – 30, 22/33 – 30, 23/24 – Homes 40, 24/25 – 33, 25/26 – 33, M3.05 Lichfields on Concern expressed about the 26/27 – 33 and 27/28 – 33. behalf of delivery of this site and delivering Taylor dwellings from 19/20. No No evidence has been Wimpey reserved matters submitted or presented to indicate why the approved and not clear whether site is unlikely to come forward there is a developer or and we have therefore trusted housebuilder on board. the information provided by the applicant. Refers to Lichfields’ ‘Start to finish’ research document on delivery rates and that for developments of 100-499 it takes

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Site No. Ref Name Objection Response Resulting units no. units a little over 4 years to go through the planning approval and delivery process. More appropriate for delivery to commence in 22/23. Westminster 30 M3.14 J10 Questions the delivery of this site We have accounted for the 30 Industrial Estate, Planning on (65 units: new scheme for secure reduced number of dwellings Gwersyllt behalf of care unit + 24 residential (30) allowed on this site as set Countryside apartments refused and out in MRH06 and in the Properties appealed) over the plan period. detailed housing trajectory. The Plc Appeal has since been granted Housing Trajectory sets out 10 M3.15 J10 with a lower number of units. completions per year from Planning on 21/22. behalf of Bellis Bros M3.16 J10 Planning on behalf of Gower Homes Ruabon Business 319 M3.09 Fischer The trajectory for this site is likely David Wilkinson of Pure 319 Park German on to be lower, reducing the number Commercial advised via email behalf of a of dwellings deliverable in the first on 8th August 2019 that it is consultee 5 years. likely 175 dwellings will be M3.14 J10 Questions the delivery of this site. completed in the next 5 years Planning on Outline permission was granted with 144 in the years that follow. behalf of in 2015 but no progress. These figures were included in Countryside the Housing Monitoring Report Properties 2019 (MRH06) which was Plc consulted on with HBF who

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Site No. Ref Name Objection Response Resulting units no. units M3.15 J10 raised no objections. A detailed Planning on trajectory was also provided: behalf of 21/22 – 65, 22/23 – 55, 23/24 – Bellis Bros 55, 24/25 – 50, 25/26 – 50, M3.16 J10 26/27 – 44. Planning on behalf of Gower Homes

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Appendix 2: Delivery Evidence for Committed Sites up to 1st August 2019

Note: This table includes sites in the committed supply as of 1st April 2019, it also includes (in amber) new sites granted permission from 1st April 2019 to 1st August 2019.

TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 1 P/2016/0337 Former Acton 23 Reply received via email 8th July 2019. Ebenezer Site is cleared, although construction works not Chapel, 2 yet started - likely to start in next 12 months and Chester St, take 2 years to complete. Wrexham 1 UDP Allocation Former Depot, Caia Park 13 0 Email received from WCBC Housing Dept 2nd Oct 18 Crescent Rd 2018 - not on Housing radar so believes that Wrexham situation remains unchanged. Council car park that is generating an income - unlikely to be built on in near future. 1 P/2006/0131 Rivulet Rd. Caia Park 24 0 Work started only appears to be some minor (adj. to N ground work. Possible land slip issues. Appears to Wales be abandoned and repeated attempts to contact Motorcycles) land owner/developer have been unsuccessful. 1 UDP Allocation Bridge St. Offa 25 0 Email received from WCBC Housing Dept 2nd Oct 16 /Cambrian 2018. Still wish to see housing come forward as Yard, part of a mixed development and efforts are Wrexham ongoing with WG and through marketing to potentially interested partners. Unlikely in next 5 years.

Position remains the same as at 2019. Email received from WCBC Assets Dept.

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 1 P/2017/0212 Western Offa 40 0 Email received from WCBC Housing Dept 2nd Oct P/2016/0401 Gateway, 2018. We do have plans for this site; looking in Ruthin Rd, the region of 40-60 units once A483 junction Wrexham capacity is resolved. This has gone through Corporate Land and Buildings Strategy Group in principle.

Further email from WCBC Housing Dept 19th June 2019. Croesnewydd (as we refer to it) is very much progressing. As this is Council land we are looking at whether any prep work can be brought forward to assist the subsequent development. We are also in the process of early market engagement over the procurement of a development partner.

It is a long-shot to commit to any phasing not least because it all hinges on the A483 but I would be comfortable with the split you have illustrated 20 per year from 28/29. 1 P/2014/0116 CK1, 32-36 Offa 10 0 No Reply. Unable to contact via telephone. Bridge St., Assume figures are correct. Information from Wrexham WCBC Housing Officer who has been in contact with the land owner. Landowner is seeking to sell the site and has moved away. Therefore unlikely that any development will be completed in the next 5 years. Given that no further applications have been submitted and the current application expires towards the end of this year, the figures have been put in category 3. Not considered deliverable over plan period.

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 1 P/2015/0272 Trinity House, Rhosddu 21 0 Email received from Wingetts 24th June 2019. Trinity St, Site has been sold and Wingetts have no further Wrexham information about the future delivery of the site. Letter sent to new owners on 18th July 2019. No response and unable to contact. Considered unlikely that this will be developed in next 5 years. 1 P/2016/1099 Regent House, Rhosddu 27 Discussed with WCBC Housing Partnership Regent Street, Officer. Some completions likely to come forward Wrexham, 3 years from now - Regeneration loan funding LL11 1PR available. 1 P/2016/0189 (O) Tan y Bont, Rhosrobin 189 Agent has indicated that start date is expected to Main Road, be 2021, with 40 dwellings complete per year. Rhosrobin, LL11 4RL 1 P/2018/0588 (O) 120 Rhosnesni Gwersyllt 13 Agent no longer acting on behalf of client. No Lane, feedback as yet from applicant. In absence of Rhosnesni any confirmation, best estimate of 7 in 23/24 and LL12 7NE 6 in 24/25, to allow for RM to be submitted and approved. 1 P/2019/0263 (F) Nant Silyn, Caia Park 14 This is a Council owned site that is also being Pont Wen, developed by the Council. WCBC Housing Dept Caia Park, has advised that work will begin in October 2019 LL13 8SQ with all units being completed by April 2020. 1 P/2018/0267 (F) 16-30 King Rhosddu 52 Agent emailed on 9th September 2019 confirming Street, that the S106 Agreement had been signed off with Wrexham, building regs being submitted mid October. They LL11 1HH anticipate all units will be completed by January 2021. Taylor Reed Homes Ltd is the developer.

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 1 P/2018/0671 (O) Glyndwr Rhosddu 410 Trajectory provided via Email from Narvo on 26th University, July 2019 Plas Coch Road, Wrexham, LL11 2AW 1 P/2018/0684 (F) Henblas Rhosddu 53 The applicant has indicated that all 53 will be Square, delivered by 19/20. Site is practically complete. Henblas Street, LL13 8AE 1 P/2018/0874 (F) Former Rhosddu 13 Have contacted agents - no response to date. In Hippodrome, absence of any confirmation, best estimate of 7 in Henblas 22/23 and 6 in 23/24. Street, Wrexham, LL13 8AD TIER 1 TOTAL 86 47 794 2 P/2007/0634 Land at Cae Cefn 19 0 Site looks abandoned. The site is known to Ann Dolydd, WCBC Housing Officers as Heol Berwyn and was Cefn Mawr on the main programme for the PDP (for Social Housing Grant). However, there is currently insufficient funding available – as such it has been moved to the reserve list. It remains in WWHA ownership. WG is applying internally for more SHG so once this is confirmed, we would look to bring the site back onto our main programme.

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 2 P/2012/0045 Former Air Cefn 232 Planning Business Support spoke to applicant on P/2016/0505 Products Site, 11th October 2018. Currently discussing the sale Llangollen of the site to Barratt. Indicated that all units could Road, Acrefair be completed in next 5 years. NOTE: No RM as yet so keeping it as 100 in first 5 years with remainder outside 5 years.

Planning Control Manager spoke to applicant on 9th September 2019. Still hoping to dispose of the site and see it completed over the plan period. 2 P/2015/0949 Land off & Cefn 30 All units under construction and likely to be West of Park completed in next 5 years. Rd., Rhosymedre 2 1462 Land off Chirk 0 85 0 Unlikely to be built - extant planning permission no Sycamore longer feasible and subsequent applications have Drive, Chirk been unsuccessful. Taken out of settlement limit in LDP. 2 P/2016/1165 North of Chirk 24 Reply received 19th June 2019. Client is Station Ave, intending to commence this summer as soon as Chirk, LL14 the full application is approved and all relevant 5NA planning conditions are satisfied. Development will be completed in the next 2 years and the assessment of the situation is correct. 2 P/2013/0545 Land at former Esclusham 300 0 Gladman emailed 23rd August, unlikely at this Hafod Tileries, stage that anything will be delivered in next 5 Johnstown years or even 5 years beyond plan period.

2 P/2014/0671 Bryn Y Groes, Gresford 26 Email sent to sgestates 18th June 2019. UDP Allocation Chester Rd., Deadline 8th July 2019. Follow up phone call on Gresford 6th August 2019. No feedback. Assume

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period remaining units all to be complete in next 5 years. 22 under construction and 4 not yet started as at April 2019. 2 P/2018/0166 Old caravan Gresford 11 Letter sent 19th June 2019. Deadline 9th July Site, Old 2019. No reply - assume figures are correct. Site Wrexham has been cleared. Road, Gresford, Wrexham, LL12 8AU 2 P/2017/0927 Westminster Gwersyllt 30 Letter sent 18th June 2019. Deadline 8th July Ind. Est., Mold 2019. Further email sent to J10 and Shokat on Rd., Gwersyllt 2nd August 2019. No reply - assume figures are correct. 2 P/2017/0134 Land at Gwersyllt 36 Reply received 19th June 2019 from Mike Boozey Fields, Forgrave of Gower Homes. Gwersyllt We completed 18 units by 30/04/2019. We will complete a further 26 units by 30/04/2020. We will complete the balance, 10 units by 31/07/2020. Total of 54 all complete by 31/07/2020. 2 P/2018/0231 Land South of Llay 18 Email received 19th June 2019. Miners Welfare We are on site in Llay (P/2018//0231), all 18 units Institute, Llay will be complete by 31/04/2020. 2 P/2007/1069 Moreton Rhos 6 Email received from Blueprint on 24th June 2019. Depot, Commencement of the remaining 6 units is Moreton Ave, imminent and likely to be complete in the next 5 Johnstown years. 2 P/2015/0382 Land off North Rhos 23 Email received from Blueprint on 24th June 2019. Rd, Ponciau Site actively being marketed at the moment. Anticipate completion of site in next 5 years. 25

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 2 P/2012/0010 Former Ysgol Rhos 3 8 Email received from Blueprint on 24th June 2019. Y Wern, Hill Site being developed in phases and will continue Street, Rhos when sold. 8 units to be built in next 5 years. 3 units unlikely to be built due to coal mine shaft. 2 P/2015/0915 & WCBC Car Rhos 11 Email received 20th June 2019. Intend to appoint (P/2016/0604) Park & adj. a design consultant soon. Will keep you informed. land, Bonc Further email received 1st August 2019 - Wen, Rhos discussion with Scapeprocure are in hand. Provisional target to commence on site by March 2020 and complete the 12 no 1b2p flats by Aug 2021. 2 1641 Wynnstay Hall, Ruabon 7 Email Received from developer 2nd August 2019. &P/2014/0628 Ruabon Dwellings will be completed in next 5 years. Although only for 7 - forms part of a larger application where this is the remaining area to be developed. 2 P/2014/0021 Ruabon Ruabon 319 Pure Commercial advised via email on 8th August Business Park, 2019 that it is likely 175 dwellings will be adj. to A483, completed in the next 5 years with 144 in the Ruabon years that follow. A detailed trajectory was also provided: 21/22 – 65, 22/23 – 55, 23/24 – 55, 24/25 – 50, 25/26 – 50, 26/27 – 44. 2 P/2017/0342 Land at Pont Ruabon 1 18 Complete and 1 under construction. Site nearly Adam complete. Crescent, Ruabon

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 2 P/2016/0735 Wynnstay Ruabon 35 Email sent 19th June 2019 - deadline Tuesday Technology 9th July 2019. Further email sent 2nd August Park 2019. No feedback - assume figures agreed last year are still correct (Email received from Cadnant Planning 28th August 2018 - agree to the figures presented - 35 units to be completed in the next 5 years.) 2 P/2019/0141 (F) Station Ave, Chirk 24 Agent on behalf of Edwards Homes Ltd confirmed Chirk, LL14 via email that 18 units would be completed by 5NA April 2020 and 6 units by 2021. 2 P/2018/0277 (O) Willow Ruabon 10 Email received from applicant on 10th September Cottage, Park 2019. The reserved matters application will be Street, submitted early 2020, with all 10 units complete Ruabon, LL14 by 2021. 6LE TIER 2 TOTAL 322 85 851 3 P/2013/0697 Land at School Broughton 11 Reply received 18th June 2019. Site sold on to Lane, Butler Builders. 4 units under construction, 4 not Southsea started and 3 complete. Work is likely to be completed in 5 years. 3 P/2016/0871 Land off Blast Brymbo 17 P/2016/0871 still pending. However a further Rd., Brymbo application has been submitted by Brenig Construction for 18 dwellings. Email sent to base architecture on 2nd August 2019. Unlikely to be built in next 5 years.

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TIER SITE REF SITE Community 2028+ Not Total Delivery Evidence ADDRESS Deliverable Remaining Plan Period 3 P/2008/1063 Wrexham Rd., Esclusham 223 Phone call with applicant 23rd Aug - would like to Rhostyllen set up a meeting to discuss the future delivery of the site - possibly October/Nov 2018. Not got a developer on board as yet, but looking to relax standards a little to get some interest. Could start by 2020 with 30-35 dwellings per annum. Email also received 23rd August 2018. WCBC Development Management in discussions with applicant (Summer 2019) about the future delivery of the site. Detailed trajectory reflects latest position. 3 P/2013/0823 Land at Holt 24 Email received from PL Planning 23rd August Wrexham Rd, 2018. Once the RM is approved, the client Holt anticipates that all units will be complete and sold by late 2020. RM P/2018/0009 Pending. Email sent to agent for pending RM application. Email sent 18th June 2019. Deadline 8th July 2019. No feedback assumes situation remains the same. 3 P/2016/0626 Vacant plot Brymbo 70 Email received from Barton Willmore on 21st opposite Bryn August 2019 confirming that 70 likely to be Gwenfro, completed in 5 years. Tanyfron 3 P/2018/0888(F) Broad Oak Rossett 10 Have contacted agents - no response to date. In Farm, Llyndir absence of any confirmation, best estimate of 5 in Lane, Rossett, 23/24 and 6 in 24/25. LL12 0UA TIER 3 TOTAL 0 0 352 Total Commitments 408 132 1997

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Appendix 3: Windfall completion timescales data (in months)

Monitoring Site Windfall/ App No. Granted Total First Time in Months from Period Allocation Units Completions Date Granted to First Recorded dwellings completed

2009-2010 former Milestone W P/2007/0010 5th October 10 10 29 PH, Ruthin Rd, 2007 Bwlchgwyn, LL11 5UT 2009-2010 Land adj. W P/2008/0843 20th January 11 2 14 Beverley, Chirk 2009 Green, Lloyds Lane 2010-2011 Brake Road Moss W P/2008/1219 03/09/2009 14 14 18 2011-2012 Plas y Waun Inn, W P/2007/1423 26th 17 12 17 Chirk October 2010 2011-2012 land off Mold Rd, W P/2009/0444 10th Nov 27 4 28 Gwersyllt, Original 2009 (Redrow - P/2010/0544 11th Jan northern section) 2012 2012-2013 Former Water W P/2008/0090 12th Sept 24 4 18 Works & Social 2011 Club, Maesgwyn Road, Wrexham (Offa)

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2013-2014 Land at Queens W P/2010/0871 3rd May 13 6 22 Head, Glanllyn 2012 Road, Bradley, Wrexham 2014-2015 FORMER W P/2013/0519 4th April 47 28 11 REMPLOY SITE 2014 2014-2015 Site of Former W P/2011/0719 24th 15 6 30 Foundry, Mount - Outline September Street, P/2014/0097 2012 Rhostyllen, 9th October Wrexham 2014 2015-2016 Maelor Place, W P/2013/0797 3rd Feb 19 19 25 Ruabon 2014 2015-2016 SITE OF W P/2014/0292 19th 15 9 15 FORMER December ROSEMARY 2014 NURSERIES, BURTON HALL ROAD, BURTON, ROSSETT, LL12 0AR 2016-2017 Land south of W P/2014/0262 6th Feb 20 3 25 Chestnut Court, Outline 2015 Summerhill Road, P/2015/0607 14th Summerhill, January Wrexham, LL11 2016 4SP 2017-2018 Packsaddle Bank, W P/2014/0800 12th 11 7 26 Wrexham, Road, Outline January Pentre Bychan, P/2016/0198 2016 Wrexham, LL14 30th 4DS September

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2016

2018-2019 Boozey Field, off W P/2015/0790 12th 54 18 26 Griffiths Road, Outline January Old Mold Road, P/2017/0134 2017 Gwersyllt, 3rd July Wrexham, LL11 2017 4YF TOTAL 304 Average months (304/14) 22

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Appendix 4 Allocated Sites: Objections and Council Response

Site No. Ref Name Objection Response Resulting units no. units Lower Berse 200 M3.03 Hourigan Refer to 3 national studies about Extensive engagement has 200 Farm (KSS1, plan Connolly on lead-in times as the basis for taken place with the landowner, SP4) period behalf of objecting to the delivery agent and developer about the Gladman timeframe for this site. Delivery future delivery of housing on this of any housing on this site relies site. A Meeting took place 1 on improvement works to junction March 2019 between The 4 with the A483. Planning Consultancy, Redrow SCP Transport and Wrexham Concerned that 100 dwellings per Council Officers to discuss year for the last 2 years of the potential for delivering more plan will be built by a single than 200 units over the plan developer. period. Redrow/SCP believe M3.05 Lichfields on Any completions are dependent that there is Highway capacity to behalf of upon significant highway deliver development before Taylor improvements. It’s likely that this junction 4 improvements are Wimpey may slip and will be unable to implemented, potentially delivery any housing over the including some interim plan period. mitigation. WCBC Officers M3.12 WSP UK In light of the significant highway expressed concerns about the Ltd on constraints, there is a strong information presented. No behalf of possibility that the site will not agreement reached on Bersham deliver during the plan period. exceeding the projected 200 Quarries Ltd completions over the plan 100 dwellings per year is period. It is maintained, unrealistic and not justified by however that at least 200 will be robust evidence. delivered over the plan period. Land East of 1580 M3.03 Hourigan Refer to 3 national studies about Extensive engagement has 1580 Cefn Road plan Connolly on lead-in times as the basis for taken place with the landowner,

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Site No. Ref Name Objection Response Resulting units no. units (KSS2, SP5) period behalf of objecting to the delivery agent and developer about the Gladman timeframe for this site. future delivery of housing on this site. A planning application is The trajectory for this site is not currently being considered by realistic. The following is the Council on the norther part proposed as a more realistic of the site for 600 dwellings. position for the northern part of the site: Barton Willmore on behalf of Barratt Homes and Bloor 21/22-24, 22/23–50, 23/24-75, Homes in their Statement for 24/25-75, 25/26-80, 26/27-90, Matter 3 (M3.11) confirm their 27/28-90 & 2028+-116. position in relation to the proposed trajectory for this site. At least 116 less dwellings will be built during the plan period on J10 Planning on behalf of CPPL this part of the site. in their statement for Matter 3 (M3.14) confirms that CPPLC And the following is proposed for can bring forward 500 units the southern part of the site: without the spine road, which enables quick delivery. Planned 22/23-25, 23/24-50, 24/25-50, contribution of 120 units over 25/26-50, 26/27-50, 27/28-50, 2020-21 period, which is high 2028+-705 due to PRS and timber frame construction. Further confirm At least 705 less dwellings will be that 460 units can be delivered built during the plan period on by 2023, with 1000 deliverable this part of the site. by 2028. Refers to Norris Green, where delivery rates M3.05 Lichfields on The evidence for the delivery of have been rapid (850 units). behalf of this site is not fully justified and is

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Site No. Ref Name Objection Response Resulting units no. units Taylor undeliverable. Refers to Wimpey Lichfields’ ‘Start to finish’ research document on delivery rates and that for developments of 1,500-1,999 it takes around 6.5 years to deliver any units from validation of the first planning application.

Starting to deliver units in 20/21 is unrealistic and the completion estimates discussed with relevant parties is not fully evidenced. M3.09 Fischer Build rates of 140 dwellings per German on annum are anticipated. This behalf of a would require 4 or 5 consultee housebuilders delivering together over a number of years. Such rates are difficult to achieve and could lead to losses if there is any slippage. M3.12 WSP UK The lead-in times and build rates Ltd on set out in the trajectory are wholly behalf of unrealistic and not justified. Bersham Given the plan period is only until Quarries Ltd 2028, this site will deliver less than 1,580 and given it represents 18% of the housing provision, this is a significant risk to the plan.

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Site No. Ref Name Objection Response Resulting units no. units Land adjoining 375 M3.12 WSP UK The proposed build rates and Response by J10 Planning 375 Mold Road/A483 plan Ltd on lead-in times put forward by the dated 8 March 2019 indicates (H1.1) period behalf of developer are unrealistic. planning application likely to be Bersham Insufficient evidence that 2 submitted during 2019 with Quarries Ltd developers will be involved. commencement of development taking place in early 2021. Email indicates that the site may be developed by two developers in tandem. Completions of 45 per year In 2021-2022, with 60 per year over the following 5 years and 30 in 2027-2028. Land off B5070, 180 M3.12 WSP UK Given the limited amount of plan Response received from 180 Chirk (H1.6) plan Ltd on period remaining, there is Kronospan 05.03.2019 period behalf of insufficient evidence that the site confirming expected Bersham will come forward prior to 2028. completions of 20 per year in Quarries Ltd the 2023-2024 period with 40 per year in the following 4 years. Stansty Fields, 96 M3.12 WSP UK Given the limited amount of plan Response by Fishergerman 96 Stansty, plan Ltd on period remaining, there is 26.02.2019 confirming Gwersyllt (H1.7) period behalf of insufficient evidence that the site expectation of 20 completions in Bersham will come forward prior to 2028. 2021-2022, 40 in 2022-2023 Quarries Ltd and 36 in 2023-2024. Home Farm Llay 362 M3.09 Fischer The trajectory shows 80 per Development commenced in 362 (H1.10) plan German on annum which is ambitious and early 2019. Developers period behalf of more than double the yearly anticipate site being built out by consultee delivery rate of all but 1 of the 2023-2024. Tier 2 sites (Ruabon Business Park). It is likely to be lower, reducing the number of dwellings

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Site No. Ref Name Objection Response Resulting units no. units deliverable in the first 5 years. M3.12 WSP UK Insufficient evidence that 2 Ltd on developers would be involved. behalf of The proposed build rates are Bersham unrealistic and the site is highly Quarries Ltd unlikely to be built out in full by 2028. Land adj. 35 M3.12 WSP UK The landowner proposes Email 06/03/2019 from Peak 35 Sycamore plan Ltd on development in 6-10 years – this Architectural anticipates dev 10 House, Wrexham period behalf of appears to indicate that the site completions per year 2025-2026 Road, Holt Bersham would not come forward during and 2026-2027 with 15 in 2027- (H1.13) Quarries Ltd the plan period. 2028. There have been two complies interested in developing the site.

Rossett (H1.16) 137 M3.15 J10 Supports delivery of this site and Outline planning application 137 plan Planning on confirms that it is deliverable over refused 7 January 2019. period behalf of the plan period. Applicant intends to appeal. Bellis Bros Interest received from 15 housebuilders.

Completions of 42 expected 2021-2022 and 45 per year in the following two years.

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Appendix 5: Housing Trajectory

Calculating a 5 Year Housing Land Supply over the plan period (2013-2028 - 15 Years)

LDP Year 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16+ A Year 2013-14 2014-15 2015-16 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 2026-27 2027-2028 2028+ B Remaining years 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 0

C Total LDP housing requirement (not provision) 7750 7750 7750 7750 7750 7750 7750 7750 7750 7750 7750 7750 7750 7750 7750 Annual Plan Requirement 517 517 517 517 517 517 517 517 517 517 516 516 516 516 516 Actual recorded completions on large sites during D year 151 160 132 232 119 291 Actual recorded completions on small sites during E year 64 75 67 96 103 71 Anticipated completions on allocated sites during F year 75 291 486 575 522 330 315 420 352 1400 Anticipated land bank completions during G year"+S106" 16 at April 2019 200 308 241 236 276 261 216 148 103 108

H Anticipated completions large windfall during year 120 120 120 120 120 120 120 120 Anticipated completions small windfall sites during I year 75 75 75 75 75 75 75 75 75 75 TOTAL COMPS 215 235 199 328 222 362 350 674 922 1006 993 786 726 763 650 1703 Total anticipated annual completions (D+E+F+G+H+I) minus 10% flexibility on future annual completions. Not done for first 6 years as shortfall is already accounted for. Rounded to J zero DP. 215 235 199 328 199.80 325.80 315.00 606.60 829.80 905.40 893.70 707.40 653.40 686.70 585.00

Total cumulative completions (Rounded to K zero decimal places) 215 450 649 977 1177 1503 1818 2424 3254 4159 5053 5761 6414 7101 7686

L Residual housing requirement (C-K) 7535 7300 7101 6773 6573 6247 5932 5326 4496 3591 2697 1990 1336 649 64

5 Year requirement (L/B*5) See Notes for Row N N 2691 2808 2959 3079 3287 3471 3708 3804 3747 3591 3213 3022 2884 2713 2644 O Total Annual Building Requirement (N/5) 538 562 592 616 657 694 742 761 749 718 643 604 577 543 529

P Land available large sites (allocations) 1949 2204 2228 2162 1939 1617 1387 1172 852 600 16110 Q Land available large sites (land bank) 1261 1322 1230 1137 1004 728 467 251 103 0 R Land available - large windfall 600 480 600 600 600 600 600 600 600 600 S Land available - small windfall 375 375 375 375 375 375 375 375 375 375

Total land available for the 5 year period T derived from (P+Q+R+S) 4185 4381 4433 4274 3918 3320 2829 2398 1930 1575

Housing land supply in years (T/O) U Rounded to zero DP 66665554 4 3

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NB: The table below identifies anticipated completions on those allocated and committed sites which are expected to be developed beyond the Plan period. Where less than 5 years of the Plan remain, the data below have been factored into the housing land supply calculations for years 11 to 15 (Rows P and Q as highlighted in yellow in the table above). This allows for a more realistic land supply to be calculated.

Site Remaining No. No. units to be delivered per year units at 2028 2028-2029 2029-2030 2030-2031 2031-2032 2032-2033 2033+ KSS1 1300 100 100 100 100 100 800 KSS2 100 100

The table below shows the detailed trajectory demonstrating the annual anticipated completions on allocated housing sites and sites in the committed supply as of 1st August 2019. Amber sites are those granted since 1st April 2019 to 1st August 2019.

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Appendix 6:B list and other sites (i.e. reserve sites)

1. This section summarises the ‘B list’ sites and other sites that have come forward since the B list was considered by the Planning Policy Panel, including where the other sites have originated from.

‘B list’ sites

2. At its meeting on 14 December 20173 the Planning Policy Panel endorsed a list of 9 ‘B’ sites as a contingency should some of the allocated sites not come forward. The ‘B List’ sites had been submitted during the pre-deposit stage of plan preparation, included in the Site Register (KPD07) and consulted on with the Preferred Strategy (KSD03). All of the sites were subject to assessment using the Candidate Site Assessment Methodology contained in Background Paper 04a, including engagement with internal and external stakeholders to identify any site constraints.

3. Sites included on this list have been reassessed for any changes in circumstances that may prevent them being allocated (e.g. granting of Planning permission, changes in national policy and updated site constraints). From the original list of 9 sites one site is not available (CHIR002UCS - Station Avenue/Station Road, Chirk) because during officer discussions with the site owner it was confirmed that the owner does not intend to promote this site).

4. There has been limited contact with land owners and site proponents of the other B List sites to determine whether the sites are likely to come forward for housing over the Plan period and to establish further evidence about ‘how’ and ‘when’ the sites will be delivered (i.e. phasing and timing) to inform a housing trajectory for the Plan.

Other sites submitted before the Plan went on Deposit

5. During public consultation on the Deposit plan, representations were received proposing sites for allocation. Representations proposing sites were recorded either as:  New Sites Proposed (NSP) in KPD19 and KPD19a  Amendments to the Proposals Maps (APM), recorded in KPD20

3 https://wrexham‐consult.objective.co.uk/portal/planning_policy_panel_reports 46

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6. The majority of the above submissions are sites previously proposed during pre-Deposit Plan preparation (38 from the NSP list and 1 from the APM list). A small number have been proposed for the first time during consultation on the Deposit Plan (14).

7. Sites previously submitted to the Council were assessed in the pre-Deposit stage of plan preparation in accordance with the Site assessment methodology and the results recorded in the Site Register and consulted upon together with the Deposit plan.

8. Representations on previously submitted sites have provided a range of supporting information. The sites and submissions have been reviewed to see if circumstances have changed or more recent evidence overcomes the reasons why the sites were originally rejected. Sites which have constraints that cannot be overcome (e.g. sites smaller than 10 units, sites in open countryside, no evidence the site constraints have been addressed) have not been re-considered.

Other sites received at Deposit Plan Stage

9. Representations at Deposit stage proposed 14 completely new sites. These have not previously been reported to the Members and have not been subject to consultation with key stakeholders or the public. This is in accordance with LDP guidance, but these sites were put on the Consultation Portal for information for people to see.

10. LDPM 3 states “…it is unlikely sites submitted at Deposit will be allocated. Therefore it is proposed that these sites are not considered further”

Potential sites for Allocation

11. While the B list considered by Planning Policy Panel in December 2017 is the preferred list for Members because it has been considered by them, reliance on this list alone would make the Plan unsound.

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12. For the following reasons the reserve list of sites should be expanded to include a select number of candidate sites proposed at Deposit:  Earlier Candidate Sites proposed at Deposit are more sustainable than sites on the B list and it can be demonstrated that the reasons for rejection can be overcome (e.g. more detailed information has been made available in support of a Planning application)  Some of the sites proposed at Deposit are in more sustainable settlements within the settlement hierarchy and it would be perverse to allocate a site from the B list in Tiers 3 or 4 when there is a more sustainable site in Tier 1 or 2  There are known constraints with some of the B list sites that would prevent them from delivering housing

13. There would be a risk of legal challenge if the Council does not give due consideration to reasonable alternatives. There are case law examples of successful legal challenges against local authorities who have not treated ‘alternatives’ appropriately in the Sustainability Appraisal.

14. In view of this, the reserve list of sites has been updated to include sites that were proposed at Deposit (appendix 7 of this report).

15. While there are legitimate concerns that allocations are being made at a late stage in the Plan making process and about the public’s right to comment, these fears can be allayed. Only sites previously in the public domain are proposed for inclusion in the reserve list and there are consultation processes that give the public a right to comment. During the Examination hearings, the Council compiles a schedule of proposed Matters Arising Changes or MACs which are amendments to the Plan to make it sound and any additional allocations will be included within this schedule. The schedule, accompanied by a revised Sustainability Appraisal and Habitat Regulations Assessment of the sites and the other MACs will be published for public consultation for a 6 week period. Representations received will be sent to the Planning Inspectors.

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Appendix 7: Reserve sites

Maps of the amber and green sites follow this table (refer to paras xx of the report above)

Tier 1 Settlements Source Site Units Comments Plan Period B List WRO5CS 15 No developer, possible highways 15 Llwyn Onn constraint, possible windfall WR20CS Delivery of 200 Sustainable, not delivery within the first 200 KSS1 sooner 5 years of the Plan period, but can than planned deliver over the Plan period NSP NSP010, 189 Granted permission on appeal, included 0 Rhosrobin within our post April 2019 list of appeal site committments (WR13CS, WR04CS, WR06CS) APM APM07 3- New Site Submitted at Deposit, 0 Extension to 500 Deliverability concerns within first 5 KSS2 years and plan period, highways modelling, infrastructure, SA, landscape, ecology etc. Total 215

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B List GRE09CS 132 Questionable density, designated green ? wedge, landscape values. B List GRE15CS 110 Density, smaller site subject to an ? application which has been refused for 40 units NSP NSP009 10- Highways constraint, limited potential for 15 GRE004AS 15 small scale development c. 10-15 units Vicarage Lane/ Hillock Lane NSP NSP011 82 Current application, deliverable 82 Summerhill NSP NSP022 Duplicate - See GRE15CS above ? Vicarage Lane NSP NSP033 60 Council owned, affordable, has been 60 CH04CS Chirk through SA, constraints can be Green overcome with a smaller scale proposal, deliverable by Council/RSL but funding and phasing to be agreed B List CHIR002UCS Not available (landowner unwilling to 0 release) NSP NSP001 - Small site could come forward as a 0 RU01CS windfall Ruabon NSP NSPO02 Butts Not overcome reasons for rejection - 0 Hill (LL01CS) Highways constraint NSP NSP003 Not overcome reasons for rejection - 0 GWE001AS Green Wedge, appeal on the site Woodlands Farm NSP NSP005 Not overcome reasons for rejection - 0 CO001AS Highways constraint Heol Offa NSP NSP006 Not overcome reasons for rejection - 0 CO04CS Adwy Open Countryside Grange

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NSP NSP027- Not overcome reasons for rejection - 0 Ballswood Open countryside Quarry LL03AS NSP NSP031 – Not overcome reasons for rejection - 0 CH02CS Chirk Constrained small site, ecology and Green highways NSP NSP034 - Not overcome reasons for rejection - 0 CO02CS Land Constrained, employment use adjacent Adjacent to A525 Ruthin Road NSP NSP037 – Not overcome reasons for rejection - 0 GRE006CS Open countryside Old Wrexham Road, Gresford NSP NSP038 – Not overcome reasons for rejection - 0 GRE14CS Highways Treetops NSP NSP39- Small site 0 RU04CS Vicarage Fields NSP NSP40- Not overcome reasons for rejection - 0 Twinning Hill Open countryside Vicarage field NSP NSP42 New New Site Submitted at Deposit, no 0 Site off information provided, highways Summerhill constraint Road NSP NSP55 see See NSP040 0 NSP040 APM APM06 80 New Site Submitted at Deposit, no SA 0 Extension to info, Green Wedge constraint

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GWE06CS allocation NSP NSP057 – Tyn Not overcome reasons for rejection - 0 y Coed, Open countryside Coedpoeth Field fronting Tyn Y Coed CO01CS Total 157 Tier 3 Settlements Source Site Units Comments Plan Period B List O05OS 25 Deliverable 25 NSP NSP012 – 25 Been through the SA, deliverable 25 O04OS Bangor in first five years Road NSP NSP013 – Duplicate see above 0 O05OS NSP NSP014 – 25 Deliverable in first 5 years, been 25 O06OS adj St through SA Marys school NSP NSP056 Brymbo 350 The part of this proposal within the 350 Steelworks settlement boundary has potential as a windfall, but not in the first 5 years of the Plan (highways and deliverability concerns). The rest is outside settlement boundary. APM APM08 Extension 15 Deliverable 15 to allocated site Caego B List RO001AS Rejected in SA, landscape 0 NSP NSP004 – Not overcome reasons for rejection 0 BRO001CS – Open countryside Green wedge, Berse Road not adjacent to S/L NSP NSP008 – Not overcome reasons for rejection 0 HOL001AS Holt – Scale of development and

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(Bellis) impact on the character of the village and conservation area, best and most versatile agricultural land, historic conservation NSP NSP015 – Not overcome reasons for rejection 0 RT03CS – Deliverability in plan period Bersham tip NSP NSP017 – rear to Not overcome reasons for rejection 0 Golden Lion – Highways NSP NSP018 – New Submitted at Deposit, planning 0 Site, Bungalow permission refused and appeal lost Rossett - flooding NSP NSP020 Tupa Not overcome reasons for rejection 0 Penley – Constrained (highways, trees, PENL05CS ecology) and Planning Permission refused NSP NSP021 Not overcome reasons for rejection 0 RO003AS – – Flooding Darland Golf course NSP NSP023 Land at New Site Submitted at Deposit 0 Bryn Lane – Penley NSP NSP024 – Not overcome reasons for rejection 0 Madras Penley – Highways constraint, planning PENL02OS permission refused NSP NSP025 – Not overcome reasons for rejection 0 Mountfield – Flooding Bangor BA02CS NSP NSP028 Lavister New Site - Submitted at Deposit 0 NSP NSP030 Brymbo 350 New Site Submitted at Deposit 0 Steelworks (greenfield Ty Cerrig) NSP NSP036 Not overcome reasons for rejection 0 GRE002AS – Constrained (landscape) Marford Hall Farm

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NSP NSP043 Gamford Permission for conversion 0 Lane RO08CS / approved, demolition and re- RO09CS development not supported – within open countryside NSP NSP053 Cefn Not overcome reasons for rejection 0 Lodge - – Highways BRY01CS Total 440

Tier 4 Settlements Source Site Units Comments Plan Period B List BRN06CS 15 Deliverable 16 Bronington School NSP NSP007 New site - Submitted at Deposit 0 Marchwiel NSP NSP054 Not overcome reasons for 0 Bronington rejection - Highways, access, BRN01CS ecology, trees constraint Total 16

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Tier 1

WR05CS - Field adj. Llwyn Onn Water Works, Cefn Road

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WR20CS – KSS1

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Tier 2

CH01OS - Off B5070, Chirk

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CH03OS - Off B5070, Chirk

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GRE09CS - Land Adjoining Springfield and Marford

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GRE15CS / NSP022 - Vicarage Lane

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NSP009 - Hillock Lane

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NSP011 - Top Road, Summerhill

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NSP033 - Land at Chirk Green

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Tier 3

O04OS (NSP012) - Bangor Road

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O05OS / NSP013 – Adj. Maelor Court

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O06OS – NSP014 Adj. St Mary’s School

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NSP056 Brymbo Steelworks

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APM08 Extension to allocated site Caego

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Tier 4 BRN06CS - Land off Oakfield Close, Bronington

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Appendix 8: Matter 3 statement sites (i.e. sites that are being promoted by site proponents along with the Councils response to these sites)

Ref Name Site No. Details Provided Site Ref WCBC Response units M3.03 Hourigan Land East of 130- Planning statement with NSP007 Submitted at Deposit LDP, this was the Connolly on Yorke Avenue, 217 location plan submitted first time the site has been proposed in behalf of Marchwiel at Deposit in support of the preparation of the LDP, has not Gladman the Marchwiel site. been subject to the Candidate Site Assessment Process (BP04a, including SA/HRA), no detailed assessments provided. Chirk None provided in CH01OS, Statement refers to ‘Gladman land statement CH03OS, interests in Chirk’ but at no time during Part the preparation of the deposit plan have CH06OS Hourigan Connolly/Gladman made representations promoting sites in Chirk.

Furthermore the hearing statement mentions ‘interests in Chirk’ but does not expand further, only through the Council contacting Hourigan Connolly have the sites been identified (CH01OS, CH03OS, Part CH06OS).

These three sites were officer suggested sites during the pre-deposit stage of plan preparation, the sites were dismissed for the reasons below;

CH01OS Failed stages 2 & 3 of the Candidate Site Assessment Process

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Ref Name Site No. Details Provided Site Ref WCBC Response units (constraints on site which may be possible to overcome but there are more sustainable sites proposed for allocation).

CH03OS Failed stage 3 of the Candidate Site Assessment Process (constraints on site which may be possible to overcome but there are more sustainable sites proposed for allocation).

CH06OS Failed stage 1 of the Candidate Site Assessment Process (visual amenity, landscape, best and most versatile agricultural land).

M3.05 Lichfields on Chester Road, Location plan and NSP028 Submitted at Deposit LDP, this was the behalf of Lavister planning statement first time the site has been proposed in Taylor submitted at Deposit in the preparation of the LDP, has not Wimpey support of the Lavister been subject to the Candidate Site site. Assessment Process (BP04a, including SA/HRA) no detailed assessments provided. M3.08 DBA Estates Pen-y-Bont 60 Planning statement NSP016 Submitted at Deposit LDP, this was the on behalf of landfill site. submitted at Deposit. first time the site has been proposed in FCC Planning application the preparation of the LDP, has not Environment submitted with been subject to the Candidate Site supporting information; Assessment Process (BP04a, including Ecological surveys, SA/HRA).

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Ref Name Site No. Details Provided Site Ref WCBC Response units Transport Assessment, Landscape Visual, Planning permission (P/2018/0718) Appraisal, Open Space refused: The development lies in the Assessment, Landscape open countryside outside of a defined Masterplan, Noise settlement limit. Assessment, Ground Conditions Assessment, Landfill Gas Migration Assessment, Flood Risk Assessment, Drainage Strategy, Heritage Statement M3.09 Fischer Stansty Fields, 80 Proposed extension to NSP029 The proposed extension to an allocated German on Gwersyllt, an allocated site, site was submitted at Deposit LDP, this behalf of a Wrexham planning statement was the first time the significant consultee submitted at Deposit extension has been proposed in the Plan with a highways preparation of the LDP, the extension report. Statement for has not been subject to the Candidate hearing 3 in support of Site Assessment Process (BP04a, the site. including SA/HRA). Supporting information limited to a highways report. M3.12 WSP UK Ltd Bersham The site has been RT03CS Site rejected during pre-deposit on behalf of Colliery Site promoted in the pre- NSP015 preparation - Fails stage 1 of the Bersham deposit plan preparation Candidate Site Assessment Process - Quarries Ltd stages for mixed use Constraints unlikely to be overcome development. (Deliverability, landscape, ecology, trees, highways, cultural and historic Further representations heritage). received at Deposit promoting mixed use Site has an existing permission

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Ref Name Site No. Details Provided Site Ref WCBC Response units and a land reclamation (P/2008/0266) for reclamation, with an policy (current UDP application approved to extend the policy EC16) supported timescales for commencement of by an SA assessment. development (P/2015/0337). Work on site has not commenced. The site Examination statement permission includes a restoration M3.12 in support of the condition therefore a reclamation site. policy/allocation is not required.

Representation at The submission specifically promoting examination promotes energy recovery has not previously been re-using material from proposed during the plan preparation the site to generate (previous submissions related to mixed electricity. use, housing, employment and transport). This specific proposal has not been accompanied by any additional information (i.e. SA/HRA, site assessment). M3.13 Barton Brymbo 450 Sites have been BRY09CS The BDL proposals (NSP030/056) were Willmore on Steelworks promoted through the BRY10CS submitted at Deposit LDP, this was the behalf of Site pre-deposit plan BRY13CS first time the entire large site had been Brymbo preparation for BRY15CS proposed in the preparation of the LDP Developments residential and retail (Part) and has not been subject to the Ltd uses. NSP056 Candidate Site Assessment Process NSP030 (BP04a, including SA/HRA). Deposit plan submission promoting a masterplan During the pre-deposit stage of plan approach encompassing preparation a number of parcels of land all of the pre-deposit (BRY09CS/10CS/13CS/BRY15CS) had sites within a larger site been proposed and have been

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Ref Name Site No. Details Provided Site Ref WCBC Response units boundary. assessed using BP04b, summaries from the site registers as follows; Proposes land within the existing settlement limit BRY09CS - The site Fails Stage 3 of the on this site to be Candidate Site Assessment Process. allocated for mixed use Although some of the constraints could including 450 dwellings be addressed, there are more along with land that sustainable sites proposed for allocation adjoins the settlement and as such is not proposed to be boundary of Brymbo to Allocated in the LDP. the north west. BRY10CS Failed Stage 3 of the Current planning Candidate Site Assessment Process – It application for the site is possible constraints may be overcome promoted at Deposit but there are more sustainable sites with supporting proposed for allocation/development. information. BRY13CS – The site now has the benefit of planning permission and is already included in the housing supply As of 1st April 2017 or has been built out.

BRY15CS This site is covered by application P/2014/0166, which extended the time period to submit Reserved Matters in relation to a mixed use scheme including residential, retail, B1, B2, B8, leisure and a new access road - originally approved under CB00016 in 1995. The residential

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Ref Name Site No. Details Provided Site Ref WCBC Response units elements and new road are now complete and it would be difficult to justify further residential development as this would be contrary to the principles of sustainable development. The time in which to submit the Reserved Matters has now lapsed (25th April, 2017). A further outline application on this site for a supermarket and retail units has also lapsed (11th July, 2017).

In principle the LDP supports development of windfall sites within the settlement limit. M3.14 J10 Planning Land East of 500+ Submission at Deposit APM07 Submitted at Deposit LDP, this was the on behalf of KSS2 Plan stage promoting an first time this significant site extension Countryside extension to KSS2. has been proposed in the preparation of Properties Plc Further representation the LDP. submitted in hearing statements. This proposal has not been subject to the Candidate Site Assessment Process (BP04a, including SA/HRA), no supporting information supplied relating to key issues for this site (e.g. highways, infrastructure, green wedge, deliverability). M3.15 J10 Planning Land North A proposed residential NSP008 HOL01AS Failed Stage 1 of the on behalf of West of Holt and retail development (HOL01AS) Candidate Site Assessment Process - Bellis Bros Settlement (HOL01AS) has been Constraints unlikely to be overcome Boundary promoted during the pre- (Scale of development and impact on

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Ref Name Site No. Details Provided Site Ref WCBC Response units deposit plan preparation character of the village and with further Conservation area, best and most representation at versatile agricultural land, historic Deposit and within conservation). hearing submissions. M3.16 J10 Planning Land off 44 The site has been NSP009 The larger site (GRE15CS) was rejected on behalf of Vicarage promoted during the pre- (GRE15CS) in pre-deposit plan preparation; there Gower Homes Lane, deposit plan preparation, are constraints on the site (ecology, Gresford was re-submitted at the highways, trees) which may be possible Deposit stage and is to overcome but there are more further promoted in sustainable sites proposed for hearing statements. allocation.

A planning application However, the smaller site proposed at on a smaller parcel of Deposit is on the Council’s reserve list of the site considered in sites (table 6 above) subject to the need pre-deposit (GRE15CS) for additional sites being proven and the has been recently site constraints (highways) can be refused (against officer overcome development could be recommendation) with supported. an appeal to be lodged. M3.17 Lambert Land off St 40+5 Submission within the Allocated If the site is capable of delivering this Smith Mary’s Avenue hearing statement says site H1.14 number of units without having any Hampton on (H1.14) there is capacity to additional impacts, such as on highway behalf of deliver up to 45 safety, the Council would have no Pickstock dwellings (allocation is objections to the additional number of Homes for 40). dwellings proposed for this site.

Pre-application The most appropriate time to assess site submission made. yield in detail would be the planning

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Ref Name Site No. Details Provided Site Ref WCBC Response units application stage. North of 32 First considered during NSP013 The site has been previously considered Bangor Road, pre-deposit plan (O05OS) during pre-deposit stages of plan Overton preparation then preparation including assessment under submitted at deposit the candidate site assessment (BP04b). consultation stage with further statements for The site is on the Council’s shortlist of the hearings. reserve sites (table 6) should additional allocations be required. However, table Pre-application 6 contains options in higher tiers. submission made. South of First considered during NSP012 The site has been previously considered Bangor Road, pre-deposit plan (O04OS) during pre-deposit stages of plan Overton preparation then preparation including assessment under submitted at deposit the candidate site assessment (BP04b). consultation stage with further statements for The site is on the Council’s shortlist of the hearings. reserve sites (table 6) should additional allocations be required. However, table 6 contains options in higher tiers.