Wrexham Local Development Plan

BP 07 2013 - 2028

housing open space employment community transport education

Employment Land

This leafl et is available in accessible formats BP07 Employment Land Wrexham Local Development Plan 2013-2028

Contents 1.0 PURPOSE OF THIS BACKGROUND PAPER ...... 2

2.0 POLICY CONTEXT – NATIONAL, REGIONAL AND LOCAL PLANNING CONTEXT ...... 2

3.0 EMPLOYMENT LAND REVIEW AND WELSH GOVERNMENT POPULATION PROJECTIONS ...... 7

4.0 WREXHAM INDUSTRIAL ESTATE ...... 16

5.0 PROPOSED ALLOCATION AT WREXHAM INDUSTRIAL ESTATE ...... 20

6.0 PROTECTION OF EXISTING EMPLOYMENT AREAS ...... 26

7.0 Conclusion and Implications for the LDP ...... 27

Appendix 1: Location of Readily Available Employment Sites and Protected Employment Areas ...... 28

Appendix 2: Areas of Search – Strategic Employment Sites (source LDP Preferred Strategy, February 2016) ...... 29

Appendix 3: Readily Available Land at Wrexham Industrial Estate ...... 30

Appendix 4: List of Protected Employment Sites to be included in the Deposit LDP ...... 31

Appendix 5: Readily Available Supply of Land in WCBC (as of 1 st April 2017) ...... 34

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

1.0 PURPOSE OF THIS BACKGROUND PAPER

1.1 This background paper has been prepared to support the deposit Local Development Plan (LDP) 2013-2028.

1.2 The purpose of the paper is to set out the position of the Council in relation to the approach to the allocation of employment land in the LDP, and the protection of existing employment sites. The location and amount of land allocated has an important role to play in relation to the spatial strategy of the Plan (see Background Paper 10 Spatial Strategy and Distribution of Development), and examines the key elements that have informed the proposed employment allocation and protection of existing employment sites.

1.3 Throughout this paper reference will be made to other plans, documents and guidance as appropriate, copies of which can be viewed on the Local Development Plan Consultation Portal at hhtp://wrexhamldpwrexham.gov.uk unless they are referenced directly.

2.0 POLICY CONTEXT – NATIONAL, REGIONAL AND LOCAL PLANNING CONTEXT

Planning Policy Wales (PPW) Edition 9 (November 2016)

2.1 Planning Policy Wales states that planning policies for economic development must provide developers and others with scope to make choices to secure the efficient and effective use of resources including land. Plans and decisions must be based on up- to-date and locally specific evidence which demonstrates the suitability of the existing employment land supply in relation to the locational and development requirements of business. Local Planning Authorities (LPAs) are therefore required to undertake, and keep under review, an Employment Land Review.

2.2 PPW underlines the need for using evidence for setting an economic vision and guides development plans to follow a number of processes, including the following selected points:

• A broad assessment of anticipated employment change by broad sector and land use;

• Targets on land provision for the employment uses (Classes B1-B8), showing net change in land/floorspace for offices and industry/warehousing separately;

• Include policies relating to future development on existing employment sites to protect them from inappropriate development;

• To encourage the regeneration and re-use of sites which are still suitable and needed for employment;

• To control and manage the release of unwanted employment sites to other uses;

• Seek to provide the right amount of land and qualitative mix of sites to meet the market demand for economic development uses.

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2.3 The economy should also be supported through the planning system adopting a holistic approach and making provision for the needs of the entire economy (including non B class uses such as retail, leisure, health and public services), in addition to traditional employment land uses defined as B1, B2 and B8. Furthermore, more effective working and decision making should be promoted both within and between Local Authorities. LPAs are required to work collaboratively to ensure the respective Employment Land Reviews are undertaken at an appropriate strategic level and to cooperate to ensure that development takes place in the most appropriate locations in Wales even if that is outside of their administrative boundaries.

2.4 PPW also identifies a series of measures which aim to promote diversification in the rural economy including the need for local authorities to encourage the growth of self employment and micro businesses in rural areas by adopting a supportive and flexible approach to home working; adopting a positive approach to development associated with farm diversification in rural areas; and supporting the expansion of existing businesses located in the open countryside provided there are no unacceptable impacts on local amenity. 6 Technical Advice Note (TAN) 23: Economic Development (2014)

2.5 TAN 23 provides guidance on economic development and the role that the planning system plays in the success of the Welsh Economy. The guidance recognises the importance of the economy as a whole, identifying a positive approach to delivery of economic development and how benefits of economic development should be considered alongside social and environmental considerations. The TAN provides guidance for LPAs on:

• Developing high level economic planning objectives;

• Assessing the economic benefits of new development;

• Economic development and the rural economy;

• Preparing an evidence base for a LDP;

• Creating an economic development vision for a LDP; and

• Determining employment land supply.

2.6 The TAN refers to the economic benefits associated with new development and refers development to the most appropriate locations, suggesting a sequential test to assess locations. Similarly, a test is also applied to clarify and balance the economic, social and environmental impacts of development.

2.7 LPAs are required to work on a regional basis, recognising that market forces do not operate within local authority boundaries. Strategic planning therefore will identify the most appropriate locations for development and joint working to produce a common evidence base is encouraged.

2.8 The TAN considers the wide range of economic activities that can be sustainably accommodated in rural areas, recognising their contribution to sustaining communities

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and addressing the specific needs of established businesses. The use, re-use and adaption of existing rural buildings can play an important role in meeting rural employment land and advises that LPAs should have a positive approach to business re-use.

2.9 Development plans must be informed by a robust evidence base, collated at both the regional and local level. LPAs are expected to identify a broad vision for their Plan which is consistent with housing and other aspirations of their Development Plan.

2.10 Development plan employment land targets should aim to ensure that planning meets the demand for land and does not constrain economic growth through a shortage of land. Land provision targets maybe higher than anticipated demand to account for assessments being too low, to ensure no opportunities are missed and to allow for flexibility, choice and competition. Persistent oversupply of employment land however may cause harm where employment sites remain vacant for long periods and frustrate development for other land uses.

Technical Advice Note (TAN) 6: Planning for Sustainable Rural Communities (2010)

2.11 TAN 6 states that LPAs should support the diversification of the rural economy as a way to provide local employment opportunities, increase local economic prosperity and minimise the need to travel for employment. The TAN identifies a range of issues which the development plan should consider and address including the identification of a diverse range of sites suitable for employment use, farm diversification and encouraging the growth of self- employment and micro-business by adopting a supportive approach to home-based working.

The Wales Spatial Plan Update: People, Places, Futures (2008)

2.12 The Wales Spatial Plan (WSP) (2008 update) identifies Wrexham Town as a Key Settlement of National Importance, located within the Wrexham, Chester, Deeside Hub. Wrexham Town is also a Key Regeneration Area and the Wrexham Industrial Estate is identified as a Key Business Sector Area. National connectivity from the County Borough into the adjoining area of Cheshire West and Chester is significant, with the strategy for North East Wales aiming ‘to bring together distinct elements of the cross-border area of Flintshire, Wrexham and West Cheshire’. Key elements which have particular economic relevance for realising the vision for NE Wales are:

• Strengthening key hubs as a focus for investment in future employment, housing, retail, leisure and services. Outside the hubs, strong sustainable communities will be fostered within coastal, border and rural towns and villages to provide locally accessible jobs and services across the Area;

• Developing sustainable accessibility between hubs, coastal and border towns and rural parts of the Area. Improving accessibility on key road and rail corridors to maintain economic growth and provide development opportunities to the west; • Improving the quality and diversity of the economy, with a focus on high value manufacturing and services, including a high quality year-round tourism sector; and

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• Developing, in a focused and strategic manner, the skills and education of the current and potential workforce. It is vital that the Area’s children and young people develop the basic education, skills, wider knowledge and aspirations to enable them to access good job opportunities and meet the needs of local employers.

Regional Policy Context

North Wales Economic Ambition Board

2.13 Wrexham along with the other five local authorities in North Wales, the private sector, higher and further education and third sectors has joined the North Wales Economic Ambition Board (NWEAB) and has adopted a growth vision for the economy of North Wales to 2035 1. The aims are to improve the economic, social and environmental well-being of North Wales, to support and retain young people in the region, address worklessness and inactivity, support and enable private sector investment in the region to boost economic output and to create new job opportunities. In broad terms, the vision is to grow the value of the economy by 2.8% per annum to £20 billion and to create over 120,000 new job opportunities. There will be many different ways in which the partners try to deliver this vision including the growth deals for North Wales and Cheshire and Warrington – both of which support key investment in Wrexham which are consistent with the vision and strategic objectives of the Deposit Plan.

Mersey Dee Alliance

2.14 The Council is also a key partner in the Mersey Dee Alliance (MDA). The MDA was born out of recognition of shared economic, social and environmental interests across the West Cheshire, Wirral and North East Wales area. The Alliance was formed in April 2007 and in addition to Wrexham, comprises the local authorities of Cheshire West and Chester, Flintshire and Wirral, together with Chester University, Wrexham Glyndwr University, the Welsh Government and Mersey Travel. Whilst sitting either side of a national boundary, the Mersey Dee region has been recognised as a single economic sub-region, with a population close to 1 million 2.

2.15 The MDA’s role is to enhance the profile and identity of the North Wales/North West border region and maintain and develop the region’s competitiveness. It has published a number of strategies including a Sub Regional Spatial Strategy (2006-2021). 3 The recently published Mersey Dee Area Prospectus – Unlocking Our True Potential 4 sets out the transport infrastructure investment required to unlock the economic growth potential of the area in addition and complementary to rail investment identified in the Growth Track 360 prospectus 5. Investment in the transport infrastructure will act as a key enabler to help better link Wrexham’s key development sites to each other, to skilled labour and into the wider economy of the Northern Powerhouse and international routes allowing us to expand the potential economic offer. The prospectus identifies Strategic Development sites including; Wrexham Town Centre, Wrexham Industrial Estate (WIE) and Wrexham Technology Park/Western Gateway. These have been identified due to their significant growth potential 6.They represent

1 http://www.wcnwchamber.org.uk/wp-content/uploads/2016-08-Vision-for-North-Wales-Economy-FINAL-VERSION.pdf 2 http://www.wrexham.gov.uk/english/council/documents/council_plan.htm 3 http://www.merseydeealliance.org.uk/spatial-strategy/ 4 http://wcnwchamber.org.uk/wp-content/uploads/MDA-Prospectus-Unlocking-Our-True-Potential-English.pdf 5 http://cdn.frontburnr.co.uk/uploads/files/ch1/3087_Rail_Prospectus_pre_publication_draft.pdf 6 http://wcnwchamber.org.uk/wp-content/uploads/MDA-Prospectus-Unlocking-Our-True-Potential-English.pdf 5

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some of the region’s best investment opportunities and are protected for employment uses within the Plan. 7

2.16 The importance of WIE as a nationally / regionally important employment site is supported by number of regional strategic documents:

• A Winning Growth Bid for North Wales - Evidence to the Employment and Infrastructure Committee of the National Assembly for Wales into City Deals and the Regional Economies of Wales (NWAB) (May 2017) - Wrexham Industrial Estate is identified in the document as a key location, alongside Deeside Industrial Park, for industry in North East Wales. Furthermore Wrexham Industrial Estate is identified as a distributed growth hub in the North Wales Growth Vision. Whilst the amount of land required at WIE in relation to the Growth Bid has not yet been quantified, its identification adds weight to the need to allocate additional land (whether as an allocation or strategic extension area) in the WIE. • Mersey Dee Alliance Prospectus – Unlocking our True Potential (2017) - WIE is identified as a strategic development site within the Mersey Dee region. • Moving North Wales Forward – Our Vision for North Wales and The North East Wales Metro (March 2017) (Welsh Government) - The Integrated Transit Network Vision for North East Wales Travel to Work Area recognises WIE as a key employment zone and is identified for site bus links to hub/interchange at Wrexham and North Wrexham. • Growth Track 360 – Prospectus - WIE is identified as a growth opportunity.

2.17 Whilst there is no direct way to understand the exact quantitative impact of these documents it does serve to demonstrate that Wrexham and WIE are strategically important locations in a regional/national context.

Local Context

Our Wrexham Plan (Wrexham Local Service Board) 2013 – 2024 8

2.18 Economic aspirations contained in the ‘Our Wrexham Plan’ indicate that making Wrexham a place with a strong, resilient and responsible economy is a priority for the County Borough. Wrexham is therefore well placed to tap into economic opportunities in both Wales and North West England.

The Council Plan 2017-2022

2.19 The Council Plan 9 is the mechanism by which Wrexham County Borough Council publishes its well-being statement. It also highlights how local people have been involved in determining those objectives. The Council Plan is underpinned by the other strategies prepared by the Council and its partners. Economic aspirations contained within the Council Plan indicate that making Wrexham a place with a strong, resilient and responsible economy is a priority for the County Borough. This will be evidenced by a revitalised Wrexham Town Centre and surrounding neighbourhoods (via the

7 Employment Land Review WCBC & FCC, Oct 2015 8 http://www.wrexhamlsb.org/assets/pdf/lsbplan2013-2024.pdf

9 http://www.wrexhamlsb.org/assets/pdf/lsb_plan_2013-2024.pdf 6

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delivery of new and improved homes), the creation of businesses, jobs and growth of the arts and creative industries sectors to strengthen its regional position and make it the place people choose the live, work and invest in.

3.0 EMPLOYMENT LAND REVIEW AND WELSH GOVERNMENT POPULATION PROJECTIONS

3.1 The Employment Land Review (ELR) 10 has been prepared in order to inform the approach to employment land allocation and protection of existing employment sites in the LDP. The ELR assesses the supply, need and demand for employment land and premises (Use Class B) in the local authority areas of Wrexham and Flintshire. It has been carried out to provide robust evidence to underpin and inform the Council’s respective Local Development Plans (LDP).

3.2 The Study comprises three main elements:

• To review the existing employment land provision position, and the suitability and viability for the long term of sites and allocations for employment use in light of the current prevailing market conditions; • To build a robust and relevant evidence base of business needs across the two areas; and • To assess future quantitative employment requirements to help inform the employment land policies of the Councils’ LDPs.

3.3 In relation to Wrexham County Borough the ELR identified a projected jobs growth figure of 4,200 11 for the Plan period, a land take of between 2-3ha a year and the need to protect a range of existing employment areas. It also made recommendations regarding the need to provide additional land at Wrexham Industrial Estate (WIE).

3.4 The Preferred Strategy identified the need to provide a level of growth which allowed for 7500 jobs and 53ha 12 of employment land in order to accommodate the projected housing growth, and also identified a preferred search area to accommodate a need to allocate additional land at Wrexham Industrial Estate (WIE). It also recognised the need to protect existing employment areas from alternative uses. The jobs figures and land take identified at Preferred Strategy have been superseded as a result of changes to the Welsh Government Population projections (see BP01b Population and Household Projections with Dwellings & Employment Impacts and BP10 Spatial Strategy and Distribution of Development). The Welsh Government 2014 based migration led population projections have also been considered in relation to the link between projected population increase, housing and jobs growth.

3.5 Since the publication of the Preferred Strategy, further work has been carried out to:

• Understand the existing realistic supply of available employment land within the County Borough;

10 Employment Land Review Wrexham County Borough Council and Flintshire County Council (October 2015) WCBC 11 Employment Land Review Wrexham County Borough Council and Flintshire County Council (October 2015) WCBC - (Paras 9.29 and 11.7) 12 Preferred Strategy Background Paper No 1 Population and household projections with dwelling and employment impacts - March 2015 7

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• Investigate the potential land allocation at WIE; and • Identify the existing employment areas that should be protected from alternative uses.

3.6 The release of the Welsh Government 2014-based migration-led population projections has also been considered in relation to the link between projected population increase, housing and jobs growth. The housing, jobs growth and employment land figure forecast as a result of the changes to the household projections are 7750 new homes, 4700 jobs and 33ha of employment land.

3.7 Table 1 below identifies the resulting job and employment land figures associated with each of the 2014 based population variants and includes the figure in the Preferred Strategy for information and comparison:

Table 1 : Job and employment land requirements as a result of the 2014 based 5 and 10 year migration trend variants compared to that agreed in the LDP Preferred Strategy

Growth Option Jobs Employment land (ha) LDP Preferred Strategy 7,750 53ha figure (10,650 new homes) 2014 based 5 year migration 2,700 19ha trend (6000) 2014 based 10 year 4,700 33ha migration trend (7750)

3.8 The reduction in the housing projections has implications for the level of economic growth that the plan is seeking to achieve as shown in table 1 above.

Employment Land Requirement for the Plan Period

3.9 The 2014-based 10 year migration-led population projection indicates a jobs growth figure of 4,700 and a land take of 32.8 ha (rounded up to 33ha) over the plan period. The Employment Land Review (ELR, paragraph 9.29) identifies a jobs growth of 4,200 and indicates a minimum need for some 2ha/year of new employment land a year, however it states that a more optimistic approach would allow 2-3 ha/year taking account of past performance and the benchmark levels. This would give an over-all land take of between 30-45ha for the plan period (2013-2028). The ELR does not specify that the 2-3ha a year relates to the requirement for specific parts of the County Borough, but is a global figure for the County Borough. The ELR also makes a separate recommendation regarding the need to provide an additional 20-30ha of land specifically at Wrexham Industrial Estate (WIE).

3.10 There is, therefore, some variation between the jobs growth figures and employment land requirement predicted by the population led and employment sector led projections. Policy SP9 in the Deposit Plan refers to the employment sector jobs growth projection and land take i.e. jobs growth of 4,200 and a maximum land take of 45ha over the plan period based on the evidence available in the ELR. The justification for this is as follows:

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A - Jobs Growth Figure

• There is no agreed methodology which allows a perfect ‘fit’ between housing numbers, employment and the level of employment land allocations required. It should not be expected that the two sets of projections will match exactly. They are based on different data inputs, different drivers of growth, different assumptions about the future and different methodologies. However it is important nonetheless to show evidence of their relationships. Note: - When looking at predicting future growth, there are three main factors which can drive projections work – demographic change, change in the number of new dwellings and change in employment provision. The three factors are all interrelated – an increase in employment in the area may lead to in-migration and thus population growth, which requires additional housing provision or lack of sufficient housing provision, may cause people to move out of the area, taking their employment skills with them and discouraging employers from developing within the local economy. We try to balance these three elements of growth but cannot always do so within the statistical exercise of producing projections, as there is always a dominant driver of growth and there is no set methodology for providing this balance. Part of the population and housing projection work has been to calculate the number of jobs (jobs density calculation) required to meet the projected population increase in the County Borough over the Plan period. This is so we can provide evidence that, right from the outset, we have considered the relationship between housing numbers, employment and the level of employment land allocations required. 13

• There is a reasonable match between the jobs growth figure identified in the ELR and the jobs growth figure identified by the population projections which inform the housing numbers in the plan 14 (there is only a difference of 500 jobs between the two figures over the plan period or approximately 33 jobs per annum). This avoids discord between the housing and employment elements of the Plan. For example, if there was significant variation between the jobs figures derived through the two methods there would likely to be a mismatch between the amount of housing being provided and the ability of the area to accommodate the number of workers. This may result in either out or in commuting increasing in the County Borough contrary to sustainable development principles.

B - Employment Land Requirement

3.11 The ELR identifies a more optimistic approach which allows 2-3 ha/year taking (3ha a year over the plan period gives a land requirement of 45ha) account of past performance and the benchmark levels to deliver the projected jobs growth of 4,200 15 . The 2014 based 10 year migration trend indicates a land requirement of 33ha. The employment policies in the deposit LDP refer to the 45ha figure derived from the ELR. The justification for this is as follows:

13 This approach has been endorsed by the Inspectorate at the Cheshire West and Chester (CWaC) (Cheshire West and Chester Local Plan (Part One) Inspectors Report, Paragraph 50 and 51) examination into their core strategy, as well as by the Inspector examining the Newport LDP (Newport LDP Inspectors report, paragraph 3.18 – 3.23), and whilst they acknowledge that there is no perfect ‘fit’ between these three elements it is important nonetheless to show evidence of their relationships. 14 See BP01b - BP01b Population and Household Projections with Dwellings & Employment Impacts 15 The ELR derives a land take requirement through converting the projected jobs increase into a land requirement. (Part 9 ELR) 9

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• Responding to the evidence base; use of the ELR jobs growth figures to inform the anticipated employment land take ensures a clear and direct link to the land take proposed, based upon anticipated sectoral growth over the plan period. The jobs growth figure predicted by the sector growth (ELR) and population projection (WG population projections) are closely aligned.

• Referencing the ELR employment led jobs growth figure allows the plan to make reference to the higher 3 ha a year figure which links with the objective of the plan to promote economic growth, and reflects past performance (3.35ha 10 year average 16 ). This approach is in line with Technical Advice Note 23 (TAN 23) 17 which states that land provision targets may be higher than anticipated demand, to allow for the chance that the assessments are too low (the average employment land completions over the last 10 year has been 3.35ha) and to ensure that no opportunities are missed.

• The land take figure of 45ha reflects the uncertainty regarding the density of jobs delivered by new development. For example the recent development by Moneypenny at Wrexham Gateway has delivered approximately 1000 jobs on a 4 ha site (job density of 250 jobs per hectare), whilst the Gas Fired Power Station at WIE proposes to deliver 30 jobs on a 16ha site (job density of 0.5 jobs per hectare). These examples demonstrate the wide variations in the potential jobs densities delivered on sites in the County Borough, which supports a more optimistic approach which allows 2-3 ha/year 18 taking account of past performance and the benchmark levels to deliver the projected jobs growth of 4,200.

• It should also be recognised that it is difficult to compare overall jobs growth in the borough to the amount of land provided for traditional employment land uses (B1, B2 or B8), as jobs growth will also occur in sectors such as retail, education, tourism & leisure and health which do not fall within the B use classes but which contribute to economic development and hence job creation. In addition, the Local Econometric Forecasting Model (LEFM) which provides the sector growth analysis underpinning the ELR identifies that the largest sector growth over the plan period is in administration and health care, uses which are unlikely to result in a direct need for the release of employment land for these uses.

• The amount of employment land provided will also have to reflect the need to provide for a range and choice of sites in a variety of locations across the County Borough in support of the spatial strategy of the plan.

Existing Readily Available Employment Land Supply

3.12 The 2017 Employment Land Availability and Monitoring 19 report indicates an existing readily available employment land supply of approximately 65ha (as of 1st April 2017) within the County Borough as set out in Appendix 5 of this document.

16 Wrexham County Borough Employment Land Availability & Monitoring (April 2017) WCBC 17 Technical Advice Note 23: Economic Development (2014) – Welsh Government 18 Employment Land Review Wrexham County Borough Council and Flintshire County Council (October 2015) WCBC - Para 11.7) 19 Wrexham County Borough Employment Land Availability & Monitoring (April 2017) WCBC 10

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3.13 This supply comprises vacant land located within existing employment areas spread throughout the County Borough, and will be important to provide new employment opportunities throughout the County Borough in support of the overall spatial strategy (see Background Paper 10 Spatial Strategy and Distribution of Development).

Table 2: Supply and Land Requirement over the Plan Period Net land supply 2017 Land Requirement 201 3-2028 Surplus Employment Land Monitoring 65.75ha ELR figure – 45ha (3ha x 15) 20.75ha

3.14 Table 2 above indicates that based on an optimistic land take up rate of 3ha 20 a year over the plan period, a surplus of land would remain. However this is considered to be a favourable position because a land supply over and above the projected need ensures that there is good range and choice in sites for the market. This approach is in line with Technical Advice Note 23 (TAN 23) 21 which states that land provision targets may be higher than anticipated demand, to allow for the chance that the assessments are too low (the average employment land completions over the last 10 years has been 3.35ha 22 ) and to ensure that no opportunities are missed. They should also allow for flexibility, competition and choice (para 4.5.2 Technical Advice Note 23: Economic Development). The spread of sites across the County Borough also supports the spatial strategy of the plan, ensuring there are future employment opportunities co-located or in close proximity to proposed future housing allocations.

LDP Employment Land Supply, Spatial Distribution and Delivery

3.15 The employment land supply is formed of two constituent parts;

A Existing readily available sites (65ha 23 ): This supply is vacant land located within existing employment areas spread throughout the County Borough (a full breakdown of these areas is provided in appendix 5); and

B Proposed allocation at WIE: The only new allocation of employment land is at WIE. This comprises a net allocation of 28ha (once ecological mitigation and residential buffers are factored in).

Spatial Distribution

3.16 The ELR does not specify that the 2-3ha a year relates to the requirement for specific parts of the County Borough, but is an overall figure for the County Borough. This requirement will be met through the delivery of the new allocation at WIE, as well as the development of the vacant sites that make up the existing land supply (as set out in the Employment Land Availability and Monitoring). The ELR makes a separate recommendation regarding the need to provide an additional 20-30ha of land at Wrexham Industrial Estate (WIE) (see section 4.0 and 5.0 for further details). Table 3

20 Employment Land Review Wrexham County Borough Council and Flintshire County Council (October 2015) WCBC - (Para 11.7) 21 Technical Advice Note 23: Economic Development (2014) – Welsh Government 22 Wrexham County Borough Employment Land Availability & Monitoring (April 2017) WCBC 23 Employment Land Availability and Monitoring (April 2017) – WCBC 11

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below outlines the distribution of the supply of employment land by settlement tier, which is protected by policy EM1 of the Deposit Plan.

Table 3: Employment Land Supply by Tier Settlement Employment allocations/ Protected Total (ha) and Hierarchy employment areas percentage of readily Tier available employment land and new allocations for future employment development Tier 1: Protected Employment Areas 80.09 ha (28ha of Primary Key which comprises the Settlement • Wrexham Industrial Estate new allocation at / strategic WIE) (1)(45.39)ha +28.6ha) employment 85% area • Gresford Industrial Estate (7)(1.1ha) • Wrexham Western Gateway(9)(4.3ha) • Wrexham Technology Park(10) • Rhosddu Industrial Estate(12) • Whitegate Industrial Estate, Queensway (14) • Pulestone Industrial Estate(15) • Pandy Industrial Estate(18)(0.7ha) Tier 2: Protected Employment Areas 5.1ha Service 5.4% Centres • Chirk Industrial Estate, Chirk and Canal Wood Industrial Estate, Chirk(4)

• Wynnstay Technology Park, Cefn/Acrefair (8)(1.4ha)

• Five Crosses Industrial Estate, Coedpoeth(11)(0.28ha)

• Advance Park Industrial Estate, Rhosymedre, Cefn/Acrefair(13)

• Westminster Industrial Estate, Gwersyllt(20)

• Coppi Industrial Estate, Rhos(21)

• Vauxhall Industrial Estate, Johnstown and Gardden Industrial Estate, Ruabon(5)

• Ruabon Business Park,

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Settlement Employment allocations/ Protected Total (ha) and Hierarchy employment areas percentage of readily Tier available employment land and new allocations for future employment development Ruabon(24)(3.42ha)

• Llay Hall Industrial Estate and Riverside Business Park, Sydallt(23)

• Llay Industrial Estate, Llay(2)

Tier 3: Protected Employment Areas 8.6ha Local 9% Service • Lightwood Green Industrial Estate, Centres Overton(22) Bangor • Rossett Business Village, Rossett/Lavister(25) • Penley Industrial Estate, Penley(17)

• Two Mile Industrial Estate, Brynteg(16)

• Croesfoel Industrial Estate and Bersham Enterprise Centre, Rhostyllen (6)(0.6ha)

• Former Steelworks Site, Brymbo(3)(8ha)

Tier 4: Protected Employment Areas 0.3ha Minor 0.32% Village • Southsea Industrial Estate, Southsea(19)(0.3ha)

Tier 5: No protected employment areas 0% Hamlets

Other Former Hafod Tileries 0.29 0.31% Totals 94.38 ha 100%

Delivery and Viability of Employment Land

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3.17 As stated above the identified need for employment land will be delivered through the development of the new allocation at WIE as well as the development of existing vacant plots throughout the County Borough. In relation to the viability and deliverability of the employment sites, this was taken into consideration by the ELR when assessing the employment sites 24 .

3.18 In order to understand the realistic supply of employment land available, the review of the employment sites conducted as part of the ELR applied the following criteria

• Sites greater than 0.25ha; • no significant physical constraints; • not held to meet the expansion needs of specific businesses; and • not required for ecological mitigation.

3.19 Pro-formas were also produced to consider site specific issues associated with the sites forming the existing land supply (appendix 4 – ELR). The pro-formas included the following information relevant to deliverability and viability:

• Market Availability • Planning Status • Proposal • Constraints • Planning Issues • Likely development potential • Potential guidance market segment uses • Serviced • Period at which site will be available for development.

3.20 Those sites where issues relating to constraints, market availability (sites being held for expansion), or deliverability have been highlighted and were not included in the readily available land supply.

3.21 The information contained in the proformas give an indication of the market availability of sites which provides an indication of the period over which sites may come forward. It should be noted however that providing a trajectory of employment land delivery is extremely difficult. The plan, nevertheless, provides a number of sites which provide a range, choice and flexibility which support the overall spatial strategy.

Business Needs over the Plan Period

3.22 The ELR identifies the employment sector change (see table 106, ELR) predicted over the plan period. This gives an indication of the types of jobs that are likely to be created over the plan period. The sector growth is then linked to land requirements.

3.23 If these business needs are split solely between the sectors projected to grow, then the division would be as follows (Table 111). This shows the annual growth of 2.5ha. N.B. Whilst non B class uses are shown, the land requirement is for B1, B2 B8 uses only. The ELR does not recommend allocation for non-B uses. It does provide

24 See Chapter 6 and Appendices 4 and 10 of the ELR (BP 14

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commentary on health and education uses (see para 9.39-9.41), and the land requirement for these uses beyond the B use class requirement associated with these uses.

3.24 It is difficult to predict in what locations within the County Borough this growth will occur. This decision would be made by the new and expanding businesses. However as noted above, the ELR has identified a viable and deliverable, readily available land supply.

3.25 As part of the research undertaken in the ELR, local property agents were consulted and the findings of the study reflect an understanding of the business requirements in the County Borough and have been accounted for in the recommendations of the ELR.

3.26 Approximately 78% of the employment land supply is located in WIE (consisting of 43ha on existing vacant plots and 28 ha on the WIE, KSS3 site). This broadly aligns with historic take up which shows that the majority of land take up has been at WIE 25 . The remainder of the land is spread throughout various sites in the County Borough (full details are shown in table 3: Employment Land Supply by Tier).

3.27 Using the ratio in table 111 above as a guide, the demand will come from B1 and B8 uses with a 50% split. Appendix 4 shows the range of B uses appropriate within the employment land supply. The majority of sites are able to accommodate a range of B uses which would provide a range and choice to new and expanding business in the County Borough. It should also be recognised that there is a surplus of land available over and above the requirement for the plan period, which further supports the range and choice of land available.

3.28 This is considered to be a favourable position because a land supply over and above the projected need ensures that there is good range and choice in sites for the market. This approach is in line with Technical Advice Note 23 (TAN 23) 26 which states that land provision targets may be higher than anticipated demand, to allow for the chance that the assessments are too low (the average employment land completions over the last 10 year has been 3.35ha) and to ensure that no opportunities are missed. They

25 ELM 2016 – Part 4 – In the period 1996-2016 62% of employment land completions has been in the east community panel area (encompassing WIE). NB. The majority of the area beyond the WIE in the east community panel area is rural and it is therefore a reasonable assumption that the development identified has occurred within the WIE. 26 Technical Advice Note 23: Economic Development (2014) – Welsh Government 15

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should also allow for flexibility, competition and choice (para 4.5.2 Technical Advice Note 23: Economic Development).

Land Take up Rates

3.29 Employment land take up rates and the location of new development will be monitored annually via the Employment Land Monitoring process and Annual Monitoring Report. This will provide information on the effectiveness of the land supply in providing sites in line with the needs of business. It will also provide information on the overall demand. Should the take up of land run ahead of that predicted then this can be identified as an issues, and consideration of the knock on implications e.g. on housing provision can be considered as part of the formal review process.

4.0 WREXHAM INDUSTRIAL ESTATE

4.1 While the findings of the ELR suggest that the County Borough as a whole has sufficient employment land to meet its needs (see table 2 above), the qualitative research undertaken indicates a growing land supply shortfall, relative to identified demand at Wrexham Industrial Estate.

4.2 Wrexham Industrial Estate (WIE) is recognised as a nationally important employment area, and is important in the context of the local economy (approx. 80% of the employment land take-up in the County Borough in the period 2006-2015 has been on land at the WIE). Recent infrastructure improvements to the road network, which included a £30 million investment, and the completion of HMP Berwyn demonstrates the continued success of the area.

4.3 WIE is a regionally/nationally important employment area identified as the County Borough’s Key Business Sector in the Deposit Plan. The WIE plays an important role within the Mersey Dee area. It is also identified as a key employment area in a number of regional/ national strategic documents 27 . This highlights its importance in a national, regional, and local context.

Supply

4.4 In order to understand where future demand for sites could be accommodated, the ELR assessed the existing land supply at WIE. The current supply of readily available land on the estate stands at 45.39ha (Appendix 3) as of 1 st April 2017.

4.5 There is 13.19ha of readily available land remaining within the existing WIE boundary as identified in the Unitary Development Plan (UDP). A total of 7 available sites make up the 13.19ha and are generally smaller scale plots. Of these, 5 of the sites are under 2 ha in size, and 2 are approximately 3.3ha each. This limited number of smaller sites does create a limit on the type and size of company that can be accommodated. Having a sufficient range in the size of vacant plots is important in order to create an offer to retain local companies seeking to expand and to attract new companies into the County Borough.

27 Wales Spatial Plan (2008); A Growth Vision for the Economy of North Wales – North Wales Economic Ambition Board; Mersey Dee Alliance Prospectus – Unlocking our True Potential; Moving North Wales Forward – Our Vision for North Wales and the North East Wales Metro. 16

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4.6 There is an additional area of land adjacent to WIE, which was allocated in the UDP as a single user site under policy E3 and comprises 32.2ha of undeveloped land. However the Gas Fired Power Station scheme comprises approximately 15ha of the available land, and has been granted planning permission (July 2017). Furthermore, the northern section has permission for B8 use (P/2011/0891), reserved matters having been approved on 19/09/2016 (P/2016/0722). The period for submission of reserved matters and commencement of development has been extended by way of a section 73 permission granted on 05/04/2017. These sites therefore form part of the existing employment land supply within the County Borough.

4.7 The ELR anticipated that 90% of the remaining supply of readily available land could be taken up by 2017. In reality the readily available supply of land has reduced from 54.89ha (including single user site) to 46.6ha as of 1 st April 2017. This is a reduction of 15% in the period (2014-2017). Whilst the reduction is not as significant as anticipated in the ELR, it demonstrates that the overall supply has reduced further. Should either of the planning permissions on the E3 single user sites (the UDP refers to the site as a single user site, however subsequent granting of separate planning permissions on the north and the south of the site have been granted) be implemented then this would lead to a significant reduction in the existing supply of land (the E3 site represents 72% of the remaining supply of land).

4.8 The ELR demonstrated a vacancy rate of 5% at WIE. Since preparation of the ELR the vacancy rate has reduced to 4%. 28 This further reduction in the percentage of vacant units is evidence of the on-going appeal of the area. A vacancy rate of 7-10 percent is considered reasonable in terms of giving occupiers a choice of premises type, locations, sizes and tenures to suit their needs. A below average vacancy rate on the WIE is further evidence of a diminishing range and choice on the estate.

4.9 As most sites have some plans for change or are held for the expansion of specific firms, there is a shortage of readily available land on which to create an ‘offer’ for the future marketing of the estate to inward investors or existing businesses. WCBC’s Business and Investment Officers report that a lack of range and choice is deterring businesses from locating at the Industrial Estate. Given the economic focus of the Plan, and the clear evidence of need for an extension to the WIE, ensuring a sufficient supply of land at the Industrial Estate is vital within the overall context of the plan.

4.10 In addition, there are significant ecological constraints on land at Wrexham Industrial Estate. The ELR accounted for site specific ecological issues where they were known at the time but accepted that further issues could emerge as individual sites are brought forward for development. Whilst the detailed mitigation required for the planning permissions granted on the E3 sites are known, there is less detail on the other remaining sites. This may result in some further reduction in the developable area available for development, which in turn could be a factor in business deciding to locate elsewhere if there is limited choice remaining on the estate.

Demand

4.11 At the County Borough level, WCBC Housing and Economic Development Department report receiving regular inward investment enquiries, from a range of national and international sources. These are focused in Wrexham Industrial Estate

28 Source: WCBC Economic Development Officers, September 2017. 17

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and also include requirements from large local businesses with expansion needs. Over the last three years approximately 77% of enquiries received by WCBC Business and Investment Officers for sites or premises in the County Borough were seeking accommodation at WIE, demonstrating the enduring demand for the estate for new employment uses. The significance of this demand is emphasised by the fact that the location is not dependant on any short term grant or other assistance to attract and retain businesses. The ELR also identified that approximately 80% of the employment land take-up in the County Borough in the period from 2006-2015 has been on land at the WIE. This quantitative information was supported by consultation with a range of private sector stakeholders,29 which indicated that terms of location, areas within the main urban areas of Wrexham town including Wrexham Industrial Estate are the most popular.

4.12 Specific requirements are for sites:

• of 2-4.5 ha to meet the needs of inward investors and large local firms looking to grow; • small businesses (30-40 employees) looking for 0.4 ha plots which could provide design and build options for owner occupation; • Industrial units of 929-1,858 sqm; and • some smaller, sub-500 sqm.

4.13 The ELR interviewed stakeholders who argued that the development of the prison will boost market demand at Wrexham Industrial Estate as supply chain and affiliated companies seek to locate close to the facility. Existing Industrial Estate occupiers, benefiting from prison supply contracts may also be prompted to seek additional or expanded accommodation. No formal research has been carried out on the economic impact of the prison to date, however anecdotal evidence from WCBC Business and Investment Officers indicated that the building of the prison is increasing demand for ancillary uses to locate on WIE. This was supported by responses from private sector stakeholders carried out as part of the ELR 30 .

4.14 The ELR therefore recommends that the LDP identify additional land at Wrexham Industrial Estate, where the Estate’s proximity and accessibility to the key strategic settlement of Wrexham Town provides a sustainable opportunity for people to live and work in the same area, reducing the need to travel and commute outside the County Borough.

4.15 The reducing land supply and continued demand at WIE was identified in the ELR, which makes a recommendation regarding the need to allocate additional land.

4.16 Given such requirements the ELR recommends that the new allocation should not be less than 20-30 ha in size, exclusive of ecological mitigation needs.

29 Employment Land Review Wrexham County Borough Council and Flintshire County Council (October 2015) WCBC - (Section 5)

30 Employment Land Review Wrexham County Borough Council and Flintshire County Council (October 2015) WCBC - (Para 5.12)

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Employment Land Review: Justification for additional allocation of Land on WIE

4.17 While the findings of the ELR suggest there is sufficient employment land to meet forecast need in the County Borough as a whole, the qualitative research indicates a growing land supply shortfall, relative to identified demand at Wrexham Industrial Estate.

4.18 The ELR found specifically that:

• At the 31st March 2014 study base date Wrexham Industrial Estate had a gross baseline supply of 139.04ha, but when land considered unlikely to come forward, held for the expansion of existing firms or proposed for alternative uses is excluded, that total reduced significantly, to 65.79 ha.

• Based on current planning consents and remaining allocations, up to 90 percent (59 ha), could be taken up over the next three years. Thus the long term supply of viable land at Wrexham Industrial Estate may actually be comparatively small.

• As most sites have some plans for change or are held for the expansion of specific firms, there is a shortage of readily available land on which to create an ‘offer’ for the future marketing of the estate to inward investors or existing businesses.

• In addition, there are significant ecological constraints on land at Wrexham Industrial Estate. The study accounted for site specific ecological issues where they were known at the time but accepted that further issues will emerge as individual sites are brought forward for development. Research into the ecological constraints of Wrexham Industrial Estate is ongoing. However, as a worst case up to half of the remaining land supply, some 33 ha, may be undevelopable due to ecological constraints.

• Agents, developers and WCBC officers with responsibility for marketing the estate report good demand for land and premises. Specific requirements are for sites of 2-4.5 ha to meet the needs of inward investors and large local firms looking to grow, small businesses (30-40 employees) looking for 0.4 ha plots which could provide design and build options, for owner occupation and Industrial units of 929- 1,858 sqm, along with some smaller, sub-500 sqm requirements.

• There is a low vacancy rate (around 5 percent) across the estate for office and industrial premises. If a vacancy rate of 7-10 percent is considered reasonable in terms of giving occupiers a choice of premises types, locations, sizes and tenures then Wrexham Industrial Estate has an undersupply of property options at this time.

• Stakeholders argue that the development of the prison will boost market demand at Wrexham Industrial Estate as supply chain and affiliated companies seek to locate close to the facility. Existing Industrial Estate occupiers, benefiting from prison supply contracts may also be prompted to seek additional or expanded accommodation.

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4.19 The allocation of an extension on the WIE is the only new allocation that the plan will make for employment purposes, the rest of the employment areas within the County Borough will be protected by policy EM1 in the Deposit Plan in accordance with the findings of the ELR.

5.0 PROPOSED ALLOCATION AT WREXHAM INDUSTRIAL ESTATE

5.1 The evidence indicates that additional allocations are required in order to continue to create a range and choice of sites to support the important role that WIE plays in the County Borough’s economy. This will help to enhance this regionally/nationally important employment area which is identified as a key employment area in a number of regional/ national strategic documents (see regional policy context above).

Search Area Selection Process

5.2 Prior to consultation on the Preferred Strategy in April 2016 a process was undertaken to consider the merits of 2 separate search areas adjacent to the edge of the existing boundary of WIE which could accommodate a new allocation. A full explanation of the assessment process can be found in Background Paper 5(BP05): Wrexham Industrial Estate Expansion Selection 31 .

5.3 The assessment considered that any further expansion of the WIE is likely to have some environmental, visual or other impacts. Welsh Government Technical Advice Note (TAN) 23 ‘Economic Development’ (para 2.1.5) requires planning authorities considering a site allocation for employment that could cause harm to the environment or social cohesion to ask the following 3 questions in order to help clarity and balance the economic, social and environmental issues:

I. Alternatives - Could demand be met on a site where development would cause less harm, and if so where? This is also required to be considered as part of the Plan’s Sustainability Appraisal. II. Jobs Accommodated – How many jobs could potentially be created on the site? III. Spatial Merit – Would development contribute to policy objectives, e.g. the spatial strategy?

5.4 With regard to alternatives (I), given that the identified need is specifically for additional employment land at the Wrexham Industrial Estate the need would clearly not be met by a site in an alternative location. There is however a need to ensure that any site proposed for allocation will cause least harm, in terms of environmental and visual impact, compared to other possible sites at the Estate. Site selection should therefore be subject to a site assessment process which ensures that the demand could not be met on another site at the Estate where development would cause less harm.

5.5 With regard to jobs accommodated (II), while the actual number of jobs created on the site will be dependent on the nature of the future end users, which is unknown at this stage, given the likely size of the area concerned (up to 30 Hectares) and a job to ratio density of 143 per hectare (based on national average jobs density of 21 sqm per job

31 Preferred Strategy Background Paper 5: Wrexham Industrial Estate Expansion Selection (Feb 2016) - WCBC http://wrexhamldp.wrexham.gov.uk/portal/ldp_ebsd 20

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and the County Borough’s average density development of 3000 sqm per hectare), it is anticipated that the allocation could potentially accommodate over 4000 jobs.

5.6 So far as Spatial Merit (III) is concerned, the site would comprise the only key strategic employment site allocation in the LDP and is considered central to the economic strategy of the plan by providing a high quality employment site to meet a specific demand (as identified in the ELR) in a location in proximity and accessible to the key strategic settlement of Wrexham Town. This is a fundamental part of delivering sustainable development principles as identified in PPW and is a cornerstone of the Plans Strategy. The site would therefore provide a sustainable opportunity for people to live and work in the same area, potentially reducing the need to travel and commute outside the County Borough. This accords with the key principles of sustainability identified in Planning Policy Wales (Ch.4. Para. 4.6.2) and also addresses the concerns raised by the planning inspectorate for LDP1 in relation to the need to balance the sustainable growth of employment and homes in the County Borough 32 .

5.7 Following consideration of a range of factors, search areas A & B (see appendix 2) were considered to offer the best potential for a possible expansion area to the Wrexham Industrial Estate. In considering options for the expansion the following factors were considered and are discussed below:

I. Environmental factors (Green Barrier, Special Landscape Area, Flood Risk, ecology, agricultural land quality, contamination) II. Accessibility; and III. Infrastructure provision

Environmental factors

5.8 As indicated on Plan A (appendix 2), the area to the east of the WIE is designated as green wedge in the Unitary Development Plan (UDP). Subsequently, as part of the LDP preparation process, a review has been undertaken of Green Wedges in the County Borough. The findings of the review did result in a reduction in the overall size of the green wedge to the east of WIE; however it has been retained to the north east.

5.9 An area of land to the southeast of the Estate is designated as a Special Landscape Area in the UDP, as indicated on Plan A (appendix 2). The assessment noted at the time that Special Landscape Areas would be reviewed as part of the LDP preparation process. The subsequent review did not retain an SLA in that location based on approved methodology for undertaking SLA reviews.

5.10 The majority of the land surrounding the industrial estate is grade 3a or 3b agricultural land apart from a small section to the south west, adjoining Clywedog Road South, which is grade 2. Both Grades 2 and 3a are classed as ‘Best and most Versatile’ agricultural land and are afforded the highest levels of protection in national planning policy as finite resource that must be protected, any loss of land in these grades to expand the Estate would have to demonstrate why development on land in a lower grade was not possible.

32 Paragraphs 7.2 – 7.4, Inspectors Preliminary Report of Findings (Feb 2012) http://www.wrexham.gov.uk/assets/pdfs/planning/ldp/withdrawal/ED23%20Wrexham%20LDP%20Preliminary% 20Findings%20Report.pdf 21

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5.11 With regard to ecology, the Wrexham Industrial Estate is unique in that it contains a wide range of important habitats, including County Borough wildlife sites, within a relatively small area. For example much of the land adjoining the south east boundary of the Estate comprises the ‘Oaks’ wildlife site. Extending to approximately 22 hectares this area supports a wide range of species such as Polecat, Barn Owl and the rare and threatened Grizzled Skipper butterfly, as well as rare plant species. While some habitats are irreplaceable and should be protected from development, others areas provide opportunity to improve wildlife connectivity and/ or recreate habitats in association with development. In addition Great Crested Newts (GCN’s) are prevalent on the WIE and maintaining their Favourable Conservation Status (FCS) is a key planning policy consideration that must be balanced with the need to ensure the future economic development of the area, not only for the County Borough but also the wider region as identified in the WSP, the MDA prospectus and the North Wales Growth Bid (soundness test 1, does the plan fit? LDP Manual (edition 2, August 2015).

5.12 With regard to Flood Risk, Welsh Government Technical Advice Note (TAN) 15 advises that LPA’s should aim to direct new development away from areas which are at high risk of flooding. As indicated on Plan A, areas to the south and south east of the Estate, adjoining the river Clywedog are located within identified flood risk areas which will also constrain development in these areas.

Accessibility

5.13 There are currently two principal access routes into the WIE, both involving recently constructed new lengths of highway. The northern WIE access road link provides direct access into the Estate from the A534, connecting via an improved roundabout to Abenbury Road, Ash Road North and Bryn Road at the northern Estate boundary. The new southern link road similarly provides direct access into the southwest edge of the Estate from the A525 at Cross Lanes, connecting to Cefn Road at Five Fords prior to entering the Estate. Generally therefore land at the North and Southwest of the Estate, Areas A and B on Plan A (appendix 2) afford the best potential for future expansion in terms of accessibility. WCBC Economic Development section indicated a preference for site A in accessibility terms, as it provides direct access to the road network serving north Wales and the north west of England, which regionally reflects the wider economic base that Wrexham contributes to in economic terms (i.e. there are greater links with the north west of England in employment terms than there are with Shropshire, Powys etc., as reflected in the aforementioned regional documents identified in the regional policy context section above).

Infrastructure Provision

5.14 As part of the assessment process Dwr Cymru/ Welsh Water, NRW and Council Departments have been consulted and while further modelling and assessments will be required in association with any specific schemes there were no objections to development in either Area A or B on infrastructure grounds. Dwr Cymru/Welsh Water confirmed that capacity exits in the Five Fords Treatment works to accommodate development.

5.15 Welsh Government Agricultural Division carried out agricultural land quality assessments in the search areas, which revealed that Area B comprises predominately Grades 2 and 3A land, which is classed as ‘Best and Most Versatile’.

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Area A however comprises predominately Grade 3B land. Neither area is considered likely to suffer from contamination though further investigations would be required.

5.16 While both Areas A and B include areas of habitat the Council’s Ecology and Biodiversity officer has indicated that she would not support development within Area B as it incorporates substantial set aside mitigation areas provided in association with the highway improvement works referred to previously. Area A however offers the potential to provide managed mitigation and improved wildlife corridors linking existing Great Crested Newt ponds within the area, in association with any development.

5.17 The Council’s highways department confirmed that in principle suitable access can be provided to sites in both Areas A and B. In its response Assets and Economic Development indicated a preference for a site within Area A, given its better accessibility to the motorway network and the markets of the North West.

5.18 It was concluded that Area A offered the best potential for locating a new extension to the Wrexham Industrial Estate.

Specific Site Allocation

5.19 Building upon the work carried out in relation to the search areas identified in the Preferred Strategy it was necessary to focus on land within the search area that could accommodate the identified need.

5.20 The search area included land to the north of Francis Lane. This was discounted as access would be necessary along either Francis Lane or Hugmore Lane. The highways section has indicated that access off Francis Lane would be unfeasible. Furthermore development in this area would result in an illogical extension detached from the existing built up area of WIE.

5.21 It was considered appropriate to focus on the area adjacent the existing built up area of the Industrial Estate to the north of Bryn Lane and south of Francis Lane for the following reasons:

• Proximity to the recently upgraded road • Proximity to the existing built up area which forms a logical extension to WIE and offers potential to reduce the overall visual impact • Absence of any significant constraints • Potential to link ecological mitigation into the overall WIE green network

5.22 The site boundary as shown in Map1 was identified:

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Map 1: Proposed WIE Strategic Employment Allocation

5.23 The site comprises 39 ha, of which 10.5ha is for ecological mitigation and to act as a buffer between the residential properties and the edge of the developable areas of the site. The remainder (28.5 ha) is the developable area.

5.24 The following key material planning considerations have been identified associated with the proposed allocation:

5.25 Residential Amenity - There are five adjoining residential properties. In order to reduce the impact of the proposed allocation on the adjacent dwellings it is proposed that a 50m buffer be retained between the edge of the residential curtilages on the edge of the allocation and any part of the developable area. This is in line with the minimum gap maintained between the residential properties at Pentre Maelor and the nearest employment areas as per policy E17 of the current UDP. It is also proposed that the uses in closest proximity (beyond the buffer area) to the residential properties be restricted to B1 uses which include offices, research and development of products and processes, and light industry appropriate in a residential area.

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5.26 Ecology and Trees - An indicative green network plan has been produced identifying areas to be retained for ecological mitigation and the protection of existing hedgerows and important trees, ponds and corridors connecting the existing ponds and one relocated pond. The green network proposed on the site has been considered from the outset in order to understand the land take needed for its implementation and also to ensure the Favourable Conservation Status of protected species in the area such as the Great Crested Newt (GCN) and other locally important species.

5.27 Landscape Impact - The area is characterised by gentle topography with few high points, regular shaped medium sized agricultural fields, surrounded by hedgerows and trees which form part of the hedgerows. Existing development such as large warehouse type building and tall structures are associated with WIE and development of this nature adjoins the site.

5.28 Whilst it is recognised that development of the site will have a landscape impact, locating the site next to the existing built up area can begin to reduce the impact. Whilst the level of detail regarding potential development on the site is not known at this stage, there a number of approaches that could seek to reduce the overall landscape impact.

5.29 The specific design of development on the site would not be known until detailed planning permissions were submitted; however there is planning permission on the adjacent site (land off Bryn Lane and Ridley Wood) for an 18m high building. The Planning Inspector came to the conclusion that the landscape impact could be mitigated. Retention of perimeter hedgerows and trees and landscaping associated with the ecological mitigation combined with building design principles such as the use of recessive colours to elevations and appropriate siting to avoid noise and visual intrusion to sensitive receptors could be used to reduce the overall landscape impact.

5.30 Highways and Access - The Council’s Highways Department has confirmed that in principle suitable access can be provided to the site off Bryn Lane.

5.31 Drainage and Flooding - No part of the site is identified in the TAN 15 DAM maps. There are limited areas at risk of surface water flooding and any detailed proposals would need to demonstrate suitable means of surface water disposal. The Council’s Senior Flood Management Officer does not object to the site.

5.32 Minerals - The site is not underlain by any mineral of economic importance.

5.33 Landownership – All the existing landowners have confirmed that they would support the allocation of their land for employment uses.

5.34 Planning History – Planning permission (P/2015/0396 and P/2015/0397) was granted at appeal for a solar farm development on part of the site. The developers have an option on the land. The owner of the majority of the land covered by the planning permission has indicated that there was approximately 12 months left on the option held by the promoters (as of September 2017) of the solar farm scheme to purchase the land, and that it has been passed on to a 3 rd party. The land owner does not anticipate the development coming forward and has no objection to the site being allocated for an employment use. The owner of a smaller parcel of land, also covered by the planning permission, has no objection to the site being allocated for

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employment uses. No further applications to discharge the conditions associated with the planning permission have been submitted to the local authority which further indicates that there is no intention to progress the proposal.

6.0 PROTECTION OF EXISTING EMPLOYMENT AREAS

6.1 The ELR reviewed a total of 31 Employment Areas across Wrexham; this includes areas that are principally industrial estates, areas allocated in the UDP for employment purposes, areas with extant permissions together with land in use by large B1/B2/B8 employers. Each area has been appraised and assessed through a combination of site visits, local intelligence, consultations with some owners and the views of those involved in the local property market (full details of the assessment undertaken can be found in Chapter 6 of the ELR). The assessment undertaken has been used to identify those existing employment areas that should be protected in the LDP from alternative uses, as well as areas that could be considered for alternative uses.

6.2 Alongside the new strategic allocation the LDP will seek to protect existing employment areas from alternative uses (see appendix 3 for full list of protected employment areas). As well as providing existing employment opportunities some areas include vacant plots that can accommodate future jobs growth across the County Borough (these sites make up the existing employment land supply as identified in the Employment Land Availability and Monitoring Report 33 ). Further detail regarding the role that the employment areas play within the spatial strategy can be found in Background Paper 10 Spatial Strategy and Distribution of Development

6.3 The areas to be protected in the LDP are identified in appendix 4. In line with the recommendations made in the ELR, the following sites are not proposed to be included as protected sites:

• Pickhill, Cross Lanes – The site contains a creamery, and the rural nature of the facility means that development for alternative uses would be difficult. It is not therefore recommended that this site be protected for employment uses. Any future applications should be decided on their own individual merits.

• Maelor Abattoir, Cross Lanes - A small site, occupied by a sole operator that forms part of the County Borough’s agricultural sector rather than providing B- Class employment. Protection of this site for B Class employment would therefore appear unnecessary.

• Clutton Agricultural, Cross Lanes - As with Maelor Abattoir, this site is seen to form part of the County Borough’s agricultural sector rather than providing B-Class employment. Protection of this site for B Class employment would therefore appear unnecessary.

• Cambrian Price Industrial Estate, Wrexham Town - Small, mostly budget employment area, occupied by a range of trade businesses and motor garages. Most premises are occupied and the area continues to meet business needs. However, the economic value of the location is limited and in the long term the

33 Wrexham County Borough Employment Land Availability & Monitoring (April 2017) – Section 8 Update to Appendix 14 - Supply Summary ELR - WCBC 26

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industrial estate can be considered as a redevelopment opportunity, capable of meeting other needs within central Wrexham. It is identified in the Wrexham Town Centre Masterplan as a regeneration opportunity.

6.4 The ELR identified a number of other employment areas that could be considered for alternative uses (Advance Park Industrial Estate, Rhosymedre, Pulestone Industrial Estate, Wrexham Town, Penley Industrial Estate, and Southsea Industrial Estate). It is considered appropriate to retain these as protected employment areas due to the role they play in providing local employment opportunities in support of the overall spatial strategy of the plan.

6.5 Alongside the protection of employment sites the LDP will contain a policy which allows for appropriate employment uses in the countryside (EM4) in order to provide employment opportunities in the more rural areas of the County Borough in line with national Planning Policy Wales.

7.0 Conclusion and Implications for the LDP

7.1 The LDP will seek to ensure that a sufficient range size and choice of employment sites is available to accommodate projected jobs growth of 4,200 and a land requirement of 45ha over the plan period. It will do so through the protection of the existing readily available land supply of 65ha (policy EM1). In response to the evidence base, it will also allocate land for a strategic employment site of approximately 28ha, once ecological mitigation and residential buffers are factored in (policy SP11). This will ensure that there is a sufficient range and choice of sites at Wrexham Industrial Estate in support of the area’s important role within the local and regional economy. The plan will also protect existing employment sites which play an important role in supporting the overall spatial strategy of the LDP.

7.2 The requirement for in the region of 45ha of employment land is therefore justified in order to provide a flexible range of sizes and types of employment sites across the County Borough to meet potential future employment demand.

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Appendix 1: Location of Readily Available Employment Sites and Protected Employment Areas

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Appendix 2: Areas of Search – Strategic Employment Sites (source LDP Preferred Strategy, February 2016)

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Appendix 3: Readily Available Land at Wrexham Industrial Estate

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Appendix 4: List of Protected Employment Sites to be included in the Deposit LDP

Ref Protected Size (including size of Current B uses Employment Area available development sites (identified in the ELR where applicable) but which made no recommendation to review the appropriateness or otherwise of the b classes identified in each area for protection going forward in the LDP)

1 Wrexham Industrial Size of employment area B1, B2, B8 Estate 513.45ha

Available development sites 45.39ha

2 Llay Industrial Estate, Size of employment area B1, B2, B8 Llay 82.7ha

3 Former Steelworks Size of employment area 8ha N/A Site, Brymbo Available development sites 8ha

4 Chirk Industrial 66.87ha B1, B2 Estate, Chirk and Canal Wood Industrial Estate, Chirk

5 Vauxhall Industrial Size of employment area B1, B2, B8 Estate, Johnstown 30.1ha and Gardden Industrial Estate, Ruabon

6 Croesfoel Industrial Size of employment area 17ha B1, B2, B8 Estate and Bersham Enterprise Centre, Available development sites Rhostyllen 0.58ha

7 Gresford Industrial Size of employment area B2, B8 Estate, Wrexham 18.1ha Town Available development sites

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

1.1ha

8 Wynnstay Technology Size of employment area B2 Park, Cefn/Acrefair 8.42ha

Available development sites 1.4ha

9 Wrexham Western Size of employment area B1 Gateway, Wrexham 14.7ha Town Available development sites 4.3ha

10 Wrexham Technology Size of employment area B1 Park, Wrexham Town 23.3ha

11 Five Crosses Size of employment area B1, B2, B8 Industrial Estate, 7.9ha Coedpoeth Available development sites 0.28

12 Rhosddu Industrial Size of employment area B1, B2, B8 Estate, Wrexham 12.9ha Town

13 Advance Park Size of employment area B1, B2, B8 Industrial Estate, 6.1ha Rhosymedre, Cefn/Acrefair

14 Whitegate Industrial Size of employment area B1, B2, B8 Estate, Queensway, 10.1ha Wrexham Town

15 Pulestone Industrial Size of employment area B1 Estate, Wrexham 2.98ha Town

16 Two Mile Industrial Size of employment area B1, B8 Estate, Brynteg 0.94ha

17 Penley Industrial Size of employment area B1, B8 Estate, Penley 4.4ha

18 Pandy Industrial Size of employment area B1, B8 Estate, Gresford, 4.45ha Wrexham Town Available development sites

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

0.7ha

19 Southsea Industrial Size of employment area B1 Estate, Southsea 1.82ha

Available development sites 0.31ha

20 Westminster Size of employment area B1, B8 Industrial Estate, 3.8ha Gwersyllt

21 Coppi Industrial Size of employment area B1, B2, B8 Estate, Rhos 3.94ha

22 Lightwood Green Size of employment area B2, B8 Industrial Estate, 5.22ha Overton

23 Llay Hall Industrial Size of employment area B1, B2, B8 Estate and Riverside 7.88ha Business Park, Cefn y Bedd, Sydallt

24 Ruabon Business Size of employment area N/A Park, Ruabon 3.42ha

Available development sites 3.42ha

25 Rossett Business Size of employment area B1 Village, 0.91ha Rossett/Lavister

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Appendix 5: Readily Available Supply of Land in WCBC (as of 1 st April 2017)

Employment Land Supply Summary – Wrexham April 2017

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info Wrexham Industrial Estate – Sites Allocated under UDP Policy E1 E1.2 Abenbury 1.70 53 24 Not Available No 0 Way P/2015/0361. Industrial unit for Cytec expansion nearly complete August 2016. E1.4 Ash 7.30 50 28 Not Available No 0 Road Acquired by The Village Likely to South (ii) Bakery Group for further be expansion within develope Wrexham Industrial d prior to Estate. LDP completio n Application P/2015/0968 for the erection of a new bakery pending (Aug 2016) (approx. 6.62 ha with remaining area set aside for ecological mitigation). E1.6 Bryn 3.60 33 15 Not available No 0 Cottages Suggested by Council Assume it ecologists as a possible will be ecological ecologica refuge/mitigation site l mitigation E1.7 Bryn 3.65 62 20 Not available No 0 Lane Under development for Under a biological treatment developm facility. Completed ent/ April 2015. ecologica Other land set aside for l ecological mitigation mitigation E1.8 Clywedo 1.90 45 21 Not available No 0 g Road Owner has aspirations Owner North to develop this land for has services service use

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info Ecological issues may aspiration also make development s/ difficult. ecologica l issues E1.9 Clywedo 2.20 41 21 Not available No 0 g Road Owner has aspirations Owner East, to develop this land for has Wrexham services service Industrial use Estate Ecological issues may also make development aspiration difficult. s/ ecologica l issues E1.10 Clywedo 1.21 61 20 Available Yes 1.21 g Road Planning permission Unless South (i) industrial units on part develope Land in the west to be d prior to retained for ecological LDP mitigation, including completio provision of a pond. n E1.11 Clywedo a) 51 20 Available Yes 1.96 g Road 0.48 b) Outline planning Unless South (ii) b) permission for five units develope 0.48 d prior to c) 1 LDP completio 1.96 n total E1.12 Clywedo 6.50 52 22 Available Yes 3.25 g Road Owner has aspirations Unless South (iii) for a development of develope light industrial units here d prior to Approx 50% of site is LDP developable as a result completio of ecological n constraints. E1.13 Coed 0.17 46 16 Not Available No 0 Aben P/2014/0277 – Industrial Site now Road unit complete August develope 2016 d E1.14 Dunster 0.80 52 19 Not available No 0

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info Road Land will largely be held Expansio for the exclusive use of n land Lloyds Animal Foods only Western. E1.15 Former 2.90 43 23 Not available No 0 Tetra Contains Greater Not Pak Crested Newt ponds Serviced which are likely to inhibit development. Council Ecologists would wish to see this land retained as an ecological mitigation site E1.17 Redwithe 0.90 47 19 Available Yes 0.9 r (ii) E1.19 Redwithe 0.90 47 19 Partly Available No 0 r (iv) Potentially up to half the land (0.45 ha) could be set aside as a wildlife corridor. Evidence from Economic Development not likely to come forward. E1.20 Redwithe a) 60 28 Partly Available Yes 0.77 r (v), 2.03 a) P/2015/0843 – Unless b) Industrial unit granted develope 0.82 26 th May 2016 – to be d prior to Total included in 2016- LDP 2.85 2017 land supply. completio ha (approx1.18 ha under n construction) b) Under development for 12 B1 office units (0.45ha developed) E1.21 Ridley 3.30 47 22 Available Yes 3.3 Wood Welsh Government Unless Road, holding the land for the develope expansion of Cytec and d prior to has (or will shortly be) LDP taking it off the market completio

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info n Sub Total 41.8 Net Total 11.39 4 Wrexham Industrial Estate – UDP Policy E3 Single User Site E3 UDP 32.2 55 29 Available Yes 32.2 Single 0 Northern Section (Site Unless User Site (a)): Has outline develope permission for a 46,950 d prior to sqm B8 storage and LDP distribution unit completio Southern Section (Site n (b)): Has outline permission for a 37,160 sqm B2/B8 development Site has permission for gas powered fire power station Sub Total 32.2 Net Total 32.2 0 Wrexham Industrial Estate – Other Development Land within the Employment Area Boundary Site A Abenbury 6.00 47 24 Not available No 0 Way (ii), Expansion land for JCB Expansio JCB n land Expansio only n Land Site B Cefn 11.5 42 25 Not available No 0 Park, 0 A wide range of Assume it Redwithe ecological constraints will be r Road render the site ecologica undevelopable l mitigation Site C Coed 2.35 28 19 Partly Available Yes 1.8 34 Aben On the market, for sale, In part Road (ii as development or & iii) storage plots of 0.40 ha or more. Council Ecologist view

34 Site has been re-measured and updated from 1.7 to 2.35, leaving the net area as 1.8ha. 37

BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info is that the central area of the site (some 0.55 ha) should be retained, for ecology, Site F Redwithe 0.74 39 19 Not available No 0 r Road(ii) Held for the expansion Expansio of Nutrafeed n land only Site G Site G 0.99 66 28 Not available No 0 Redwithe Land could not be Assume it r Road(i) developed without the will be loss of much of the ecologica established woodland l and the likely mitigation interference with the wildlife corridor. The Council Ecologist view is that this site would make an ideal ecological reserve area. Site Bridge 26.0 48 28 Not available No 0 Hi Road 0 Has consent for, and is Under (Fireston under development for, developm e Site) a prison. ent for prison Site Bridge 20.1 66 28 Not available No 0 Hii Road 0 The bulk of this site will Assume it (Fireston be retained to provide will be e Site) ecological mitigation ecologica associated with the l adjacent prison. mitigation

Part of site has also now been developed by F Lloyd Penley.

Sub Total 67.68 Net Total 1.8 Land Elsewhere in Wrexham – Sites Allocated under UDP Policy E1 E1.22 Wynnsta 1.40 62 33 Available Yes 1.4

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info y Remaining development P/2016/0 Industrial plot at Wynnstay 735 Estate, Technology Park Outline Acrefair Planning Applicatio n (With All Matters Reserved ) For Mixed Use including 6 No Light Industrial Units (Use B1) PENDIN G E1.23 Gresford 1.10 62 42 Available Yes 1.1 Industrial Estate, Pandy E1.24 Vauxhall 0.71 36 18 Not available No 0 Industrial Three sites, all of which Expansio Estate, appear to be being held n land Johnstow by, or developed for the only n use of, adjacent occupiers. E1.25 Llay 3.30 51 27 Not available No 0 Industrial North Wales Police To be Estate intend to build a new develope custody suite and d for offices here – Use Class Class C2A Secure C2A Residential Institution Secure Residenti al Institution E1.26 Llay 2.90 51 27 Not available No 0 Industrial North Wales Police To be Estate intend to build a new develope

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info custody suite and d for offices here – Use Class Class C2A Secure C2A Residential Institution Secure Residenti al Institution E1.28 Llay 1.40 41 25 Not available No 0 Industrial Site is bounded by other Constrain Estate ownerships and may be ed inaccessible. E1.29 Llay 1.20 43 21 Not available No 0 Industrial Held as a long term Expansio Estate asset by a national n land construction firm only E1.30 Llay 0.47 52 20 Not available No 0 Industrial Site is (effectively) Develope Estate developed to the level d required by the owner. E1.31 Llay 6.40 40 24 Not available No 0 Industrial Access constraints and Constrain Estate multiple ownerships ed would make it difficult to (subject deliver a single to further coherent development appraisal) here. But further appraisal needed before a definitive answer can be given as to viability/deliverability. E1.32 Coppi 0.40 49 19 Not available No 0 Industrial Remaining land In use In use Estate, for open storage Rhos E1.35 Pandy 0.70 57 27 Available Yes 0.7 Industrial Full Planning Unless Estate, Permission for 2 develope Pandy industrial units totalling d prior to 855 sqm on 0.085 ha LDP completio n

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info E1.37 Rhosddu 0.90 51 24 Not available No 0 Industrial Likely to be held as Expansio Estate, expansion land for n land Wrexham Toolpak. only town E1.39 Ruthin 8.80 83 50 Available Yes 4.298 Road Development expected Unless Develop in the short/medium develope ment term. 4.502 ha has d prior to Area been developed for B1 LDP (Western offices, leaving a net of completio Gateway) 4.298. n , Wrexham town Sub Total 29.6 8 Net Total 7.498 Land Elsewhere in Wrexham – Other Development Land Site K Llay 0.80 52 20 Not available No 0 Industrial Site in active use for In use Estate lorry parking by P. R. (H) Pugh Haulage Contractors Site L Former 8.00 49 28 Available Yes 8 Brymbo Although the owner has Subject Steelwor retained a long term to further ks commitment to this site, commitm they have also ents from continued to defer the owner B1/B2/B8 development that in favour of residential developm options. ent will be delivered. Site M Ruabon 23.0 77 47 Partly Available Yes 3.42 Business 0 The latest planning In part Park, application Adjacent (P/2014/0021 Granted A483 2nd October 2015) for Ruabon Business Park will result in 85 percent 41

BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info of this site being developed for non B- class uses. Site N Buildings 0.31 37 20 Available Yes 0.31 5&6, Plas Not Power Serviced Colliery, Southsea Site O Westmin 0.82 55 24 Not available No 0 ster Likely to held as Expansio Industrial expansion land for D P n land Estate, Williams Holdings. only Gwersyllt

Planning permission since secured for outline residential development (P/2014/0931). Site P Land at 0.28 57 19 Available Yes 0.28 Minera Proposed for three Unless Building buildings containing 11 develope Supplies, two-storey Class d prior to Five B1/B2/B8 office and LDP Crosses workshop units completio Industrial n Estate, Minera Site Q North of 0.95 60 22 Not available No 0 Tomlinso Likely to held as Expansio n’s expansion land for n land Dairies, Tomlinson’s Dairies. only Pen y Palmant Farm, Minera Site R North of 0.58 N/A N/A Available Part of 0.58 CTM Extant planning existing Wholesal permission employm e, ent area Croesfoel not to be Industrial allocated Estate in the LDP, however

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BP07 Employment Land Wrexham Local Development Plan 2013-2028

Site Name Size, Site Site Availability Should it Net Ref. ha Scoring - Scoring be Land Total - Market- Allocated Supply led Sub- in LDP/ Total Additiona l Info does form part of the supply of readily available employm ent land. Site S Hafod 0.29 N/A N/A Available Part of 0.29 Tileries Extant planning overall permission scheme for redevelop ment of brownfiel d site. Sub Total 35.0 3 Net Total 12.88 Grand Total 206. Grand Total 65.77 April 2017 43 April 2017 Source: Update to Appendix 14: Employment Land Review, Wrexham County Borough Council and Flintshire County Council, BE Group, 2015

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