Local Development Plan 2013 - 2028 KPD13

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Preferred Strategy Consultation Report of Findings (March 2018)

This leafl et is available in accessible formats

Contents 1.0. Introduction and Background ...... 2 2.0 The Engagement Process ...... 2 3.0 Key Findings ...... 4 4.0 Summary of Representations by Question Number ...... 7 5.0 Site Register ...... 44 6.0 Alternative Site Submissions – Proposed as a result of the Preferred Strategy Consultation ...... 55 7.0 Unduly made Representations ...... 55 8.0 Conclusion ...... 55

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1.0. Introduction and Background

1.1 In accordance with the Regulations, consultation on the Local Development Plan Pre-Deposit documents was carried out for a seven week period between 12 February 2016 and 1 April 2016. The consultation documents were made available at the Contact Centre Wrexham, Redwither Tower, Wrexham Industrial Estate, all public libraries in the County Borough, and on the Council’s website.

1.2 The Preferred Strategy consultation document1 identified the key land use issues for the County Borough that the Plan will seek to address, the Vision for the County Borough up to 2028 together with the aims and objectives to achieve that Vision. Additionally, it also identified a number of strategic growth and spatial options along with the Council’s Preferred Strategy for the future development of the area.

1.3 The Preferred Strategy (February 2016), was accompanied by the following documents:

 The Sustainability Scoping Report (October 2014)  Initial Sustainability Appraisal Report (February 2016)  Habitats Regulations Assessment (February 2016)  Test of Soundness Self-assessment Report (February 2016)  Over 60 associated Topic/Technical background papers and Evidence based documents.

1.4 In addition to these documents, the Council also published the Site Register, together with the initial assessments that have been made of their suitability for development along with their compatibility with the Preferred Strategy.

2.0 The Engagement Process

2.1 In an attempt to engage as wide an audience as possible in the Pre-Deposit public consultation exercise, the Council used a variety of means of communication as outlined in the revised Delivery Agreement (DA).

2.2 The consultation methods used are summarised below:

 Letters or emails to approximately 7500 consultees (approx. 6000 letters and 1500 emails) on the Local Plan database notifying them of the consultation and where to view the proposals.

 Letters or emails to all Statutory consultation groups, organisations and forums detailed under B1 to B5 within appendix 1 of the Revised Delivery Agreement (Dec 14) as well as Community Councils, Local Members, Council Departments, members of the public and agents who submitted sites for consideration during the call for sites process in 2012/2013 and

1 http:wrexhamldp.wrexham.gov.uk

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those who had previously submitted representations as part of the LDP 1 preparation process.

 In addition, the households and businesses that were within a 50 metre radius of the 2 Key Strategic Sites (KSS) and the preferred Area of Search on WIE were also sent letters notifying them of the consultation and where to view the relevant documents etc.

 Site notices were also placed around the KSS to inform members of the public who pass by, through or use the KSS, of the consultation and the proposals for the KSS.

 A Notice was placed within the WCBC Internal Friday Bulletin.

 A notice was placed in the local ‘Essentials Mag’ magazine which is distributed around , and .

 Seven public exhibition/drop-in sessions of the proposals were arranged at the venues listed in Table 1 below. The table also identifies the number of visitors that attended the sessions. Officers were on hand to discuss the proposals which give Q & A opportunities and advise on how comments on consultation documents could be made.

 Email notifications being sent out to those who have registered an interest in the Local Development Plan with Directgov (520), a notification facility available through the Council’s website.

 The Local Service Board and Community Council Forum meetings were attended by Officers from the Planning Policy Team. The consultation event was also advertised on the Local Service Board Consultation Portal ‘Your View Wrexham’.

 Copies of the documents were made available during normal office hours, for public inspection free of charge at the following locations; Contact Centre Wrexham, Redwither Tower Reception Area, Wrexham Industrial Estate and in all Public Libraries across the Borough.

2.3 The documents were also placed on the Wrexham Local Development Plan consultation Portal which could also be accessed via the “Consultations” section on the front page of the website.

2.4 A response form was made available to help people submit comments. It included a total of 26 questions, specifically about the Preferred Strategy and asked respondents to state whether they agreed or disagreed to the proposals and policies. A further 3 questions sought feedback on either the Initial Sustainability Report (Q.27), the Evidence Base (Q.28) or the Background and Topic Papers (Q.29). Respondents could also decide which questions to answer. Forms could be completed on line, via the consultation portal and submitted in other formats, such as a letter or email were also accepted.

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Venue Address Date Time Visitor Numbers Rossett & Burton Station Avenue, Tuesday 16th 09.00am 37 Village Hall Rossett, Wrexham, February 2016 – LL12OEH 1.00pm Guildhall, Road, Thursday 18th 09.00am 29 Meeting Room 1 Wrexham, LL11 February 2016 – 1AY 1.00pm Glyn Wylfa Castle Road, Wednesday 3.00pm - 43 Centre , Wrexham 24th February 7.00pm 2016 Second Avenue, Wednesday 09.00am 23 Resource Gwersyllt, 2nd March – Centre, Activity Wrexham 2016 1.00pm Room Wrexham Road, Tuesday 8th 3.00pm - 23 Council Ruthin Wrexham March 2016 7.00pm Road Offices Pentre Gwyn Road, Friday 18th 09.00am 13 Community Wrexham, March 2016 – Centre 1.00pm Overton Village Penyllan Street, Thursday 24th 3.00pm - 70 Hall Overton, March 2016 7.00pm Wrexham, TOTAL 238

Table 1 – Exhibitions/Drop-in sessions

3.0 Key Findings

3.1 A total of 23652 representations were received during the statutory consultation period, 978 on the Preferred Strategy and 1387 on the Site Register. A summary of the representations received on the register is provided in section 5.0 of this report.

3.2 The public consultation generated a wide range of opinions and it was unsurprising that not all of these opinions were compatible with each other. Nevertheless, it has been possible to identify how many respondents supported or disagreed with the different policies/policy approaches and

2 The responses comprise those directly submitted directly online, via email and also comments received in writing.

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summarise the key issues and comments. A summary of these are set out in the following paragraphs. All comments can be viewed on the Council’s Consultation Portal (www.wrexham.gov.uk/ldp) and documents KPD14 and KPD14a provide a summary of all comments received together with WCBC Officer responses.

3.3 Table 2 below identifies the representations made on the Preferred Strategy by consultee type. A summary of the key issues raised through the public consultation on the Preferred Strategy is set out in section 4.0 below, in the order of questions as they appeared in the Preferred Strategy consultation document. Matters to be addressed by the Deposit Plan as a result of representations received is also included at the end of each section. Comments received on the site register are contained in section 5.0 of this report and information regarding the alternative sites submitted is contained in section 6.0.

Consultee Type Number Category of (LDP represent manual) ations B1 Agents/Consultants 18 B1 Developers/Housebuilders/Housing 147 Associations B1 General Public 464 B2 Community Councils 142 B1 Local Members 28 B1 Organisations 10 B2 Local Health Board Betsi Cadwaladr 20 B2 Adjoining LA's ( and 6 ) B2 NRW 11 B2 Utility Providers and Statutory 7 Undertakers (Welsh Water and United Utilities) B2 (Plans Branch) 16 B5 Other (Royal Mail)Tarmac Trading 7 B5 Other Environmental Groups (CPAT, 23 Clwydian Range & Dee Valley AONB Joint Committee) B5 Local Community, Conservation & 28 Amenity Groups B5 Other National/Local Organisations 20 (Canal and River Trust, Authority) B1 Internal WCBC (Play Development Co- 31 ordinator) TOTAL 978 TABLE 2: LDP Preferred Strategy consultation – no of representations by consultee type

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Alternative Site Submissions – Proposed as a result of the Preferred Strategy Consultation

3.4 The Town and Country Planning (Local Development Plan) () (Amendment) Regulations 2015 came into force on 28th August 2015, and removed the alternative sites submission stage from the Local Development Plan process. Subsequently, Alternative Sites can be submitted during the Preferred Strategy consultation period.

3.5 68 Alternative Sites were proposed through representations to the Preferred Strategy, these are located across the County Borough mainly for housing development but some are for employment, retail and mixed use.

Site Register

3.6 The Council published the Site Register (SR) in tandem with the Preferred Strategy to afford residents and other stakeholders an opportunity to make comment on those sites of interest to them.

3.7 The SR identifies all the sites that have been submitted by interested parties for consideration (during the call for sites process between November 2012 and February 2013). It also includes sites identified within the Urban Capacity Study (update 2015); and additional sites suggested by Officers identified as potentially suitable for development.

3.8 It was made clear in the SR that by listing a site on the register that it did not represent a commitment on the part of the Council to take sites forward for inclusion in the LDP. It included both Strategic and non-strategic sites, identifying those considered to accord with the Preferred Strategy.

3.9 Unsurprisingly the SR generated a large number of responses in relation to individual sites totalling 1387. Chief amongst these related to Wrexham 250, Overton 195, Penycae 170, 136, 120 and Rossett 113 with other notable numbers from Bangor 37, Gresford/Marford 58, Horseman’s Green 51, and 32.

3.10 Around 1000 of these responses were made by the public, the remainder came from Community Councils, Agents and Developers, statutory and other consultees. A significant number of responses 1153 were opposing sites, with 81 supporting and 153, neither supporting or objecting. Of those in support, these were mostly representing site owners.

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4.0 Summary of Representations by Question Number

General Comment on Preferred Strategy Presentation

4.1 Welsh Government commented upon the significant amount of work undertaken by the Council in developing the Preferred Strategy. The presentation of individual documents, the clear links to the evidence base and the accessibility of documents on the website were all excellent.

(Q1) Preferred Strategy - Key Issues and Drivers

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 1 73 (52) 23 (16) 4 (3) 71

4.2 Overall there was a general consensus of agreement with the Key Issues and Drivers identified with the majority of responses agreeing (73%), the minority disagreeing (23%) and only a small percentage not stating either way (4%). However, it was felt that that there could be some further clarification or refinement to some of them, whilst others suggested the inclusion of additional key issues.

Comments Supporting the Key Issues and Drivers:

4.3 Many of the comments made in response to this question demonstrate support for the Key Issues and Drivers but this question also included comments on the unsuitability of some of the settlements in the County Borough for future development. These comments are not reported here; as they have been captured in the Site Register responses (see section xx below). General comments of support included the following:

 Support of a brownfield first approach to protect greenfields.  Well documented issues relevant to Wrexham.  Support WCBC's considerable efforts to research and determine future needs throughout the county.  Agree with strengthening Wrexham Town as a key settlement of national importance.  Support the clear links to the seven well-being goals of the ‘Well-being of Future generations Act’ and also to "Our Wrexham Plan", for which the Health Board is a partner.  Agreed that there is a lack of brownfield capacity within the Borough to accommodate the projected household growth and the increasing needs of the population along with the need to build on greenfield sites.

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Comments not Supporting the Key Issues and Drivers:

4.4 From the small percentage that did not support the Key Issues and Drivers, comments were as follows:

 Disagree that there is a lack of brownfield sites within the County Borough.  Contradiction between protecting Green Infrastructure Network and the need to build on greenfield sites, particularly as some of the candidate sites are on greenfield land.  More creative options should be used to address the lack of brownfield capacity.  No specific mention of the Historic Environment in the Key Drivers.  Believes that the area is not over-represented in manufacturing.

General Comments

4.5 Other general comments on the Key Issues and Drivers, which may result in refinement, alteration or the inclusion of additional issues are summarised below:

 Careful analysis of the scope of each issue/driver is needed to ensure none are given excessive or inadequate prominence.  Confusing having issues and drivers mixed together, believe it would be clearer if they were in separate lists (HBF).  The statement 'There is a need to prioritise infrastructure investment through new development e.g. education, highways, public open space and affordable housing’; ‘is not a key issue or driver (HBF).  Question the use of the word, ‘accessible’, in the statement, ‘Providing accessible housing’ as this could have a wide range of meanings e.g. price, location, design and links to a range of transport (HBF).  The statement, ‘Capacity of some settlements may be constrained’, needs further clarification (HBF).  Some issues and drivers are missing; prime agricultural land cannot be reclaimed once destroyed; green barriers should be retained; highways and sewage systems need upgrading.  Children’s opportunities for play are protected and improved and should be added to the list of key issues.  Bullet point 14 "Ensuring...... SAC" should be split as it refers to protected landscapes/sites/species which are protected under different legislation and could be expanded to include reference to blue infrastructure such as canals and waterways.  Opportunities to grow the County Borough's leisure, tourism and recreational facilities should be a key issue and driver given Welsh Government's aim for tourism to grow in a sustainable way and the Wales Spatial Plan update to improve the tourism sector and the Council's Destination Management Action Plan.

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 The need to reverse the decline in housing delivery is absent and should be included as a key issue.  Should be more specific about why settlements are considered to be constrained. E.g. environmental, physical, result of existing UDP policies or due to infrastructure provision.  The statement ‘Need to prioritise infrastructure investment through new development’, appears to be suggesting that new development should be used to address existing infrastructure deficiencies. With the exception of affordable housing, new development should only be required to deliver or improve infrastructure commensurate to the needs or demands created by itself.  The lack of brownfield capacity is not limited to the development of new homes. This issue should highlight the lack of brownfield capacity for all types of development. The LDP should allocate sufficient land, releasing greenfield land where necessary to meet all of the County Borough's development needs.  Issues around Agricultural Land Classification, nature conservation and minerals etc. are far too ambiguous. Should provide the evidence base which identifies the spatial distribution, quantum and value of each of these.  Prioritising infrastructure deliverability and phasing of infrastructure are important.  The Green Barrier and Special Landscape Areas are one of the biggest constraints to the existing settlements whilst the requirement of infrastructure to develop these areas further should remain a high priority.  The vision refers to the wider gateway location within Wales and objective SO1 to the Wrexham--Chester hub, however, it should be clear how wider regional issues and strategies have been considered.  The key issues and drivers would benefit from detail on key strategies such as the Economic Ambition Board and the Mersey Dee Alliance and commentary on the position of the LDPs of neighbouring authorities. It is important that the role of Wrexham in the wider region is recognised and the benefits of the delivery of Wrexham’s LDP for the region are clearly articulated. The Council should evidence how its strategy has been informed by working with neighbouring authorities to deliver common regional objectives and demonstrate how, for example, the chosen employment strategy does not undermine that of Flintshire and/or the wider region (WG).

Matters to be addressed by the Deposit Plan

4.6 Key Issues and Drivers – all the comments are noted and consideration will be given to refinement, clarification, alteration or the inclusion of additional issues. The benefits of the delivery of Wrexham’s LDP for the region will be clearly articulated in the emerging Deposit Plan.

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(Q2) Preferred Strategy - Vision and Objectives

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 2 65(37) 32(18) 4(2) 58

4.7 Consultees were generally in agreement to the 12 objectives, seeing them as positive and broadly aligning with the vision, the Wales Spatial Plan and Planning Policy Wales. The majority of responses, 65% were in agreement whilst 32% did not agree and only 4% did not specify either way.

4.8 The Vision was generally thought to be positive, but specific comments included:

 Not identifying aspirations in terms of providing employment for everybody.  The Vision does not take the opportunity to say how the County Borough will change nor is it distinctive to the Borough (WG).

4.9 In relation to the objectives particular concerns have been raised about Objective S08 in relation to providing infrastructure for new developments. The concerns mainly relate to the problems with existing services and infrastructure provision or the potential additional strain upon these

4.10 Concerns have also been raised about the potential conflict between, for example, objectives, SO5 for delivering housing and SO6 – promoting a healthy and active lifestyle and SO9 - protecting the natural environment, particularly where it is recognised in the Key Drivers that greenfield land will need to be released to accommodate future development.

4.11 In terms of support, the following comments were made:

 Taylor Wimpey supports the Council's vision of a strong and sustainable Borough providing for everyone's needs. Growth and opportunities are as equally balanced within Key Settlements and Local Service Centres.  The objectives are stated in admirably succinct language.  Support for approach which seeks to enhance quality and distinctiveness of the natural, built and cultural heritage, along with specific support for objective SO9.  Welcome the inclusion of the historic environment in Objective SO9  Welcome the identification of the economic objectives SO1-SO4 and the clear importance of delivering economic growth.  Recognition of the clear links with "Our Wrexham Plan"  Recognition of the importance of the County Borough within the wider Wales and UK economy.

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Matters to be addressed by the Deposit Plan

4.12 Specific comments about the objectives which may need addressing before including within the Deposit LDP include:

 The multifunctional nature of waterways should be highlighted for the role they can play in delivering economic, social and environmental objectives.  An additional objective specifically supporting socially and economically viable communities in the Borough’s settlements outside Wrexham.  Need for an integrated transport policy and better direct rail links with other major cities.  Not forward looking enough. The most important hub to give Wrexham a chance by being part of a large population mass is Liverpool and Manchester. If the Northern Powerhouse ever comes to exist then we should be a part of it with all the necessary infrastructure to connect us up and make us far more economically viable and attractive to the outside world.  The HBF believe that the need to provide more housing to meet the areas need and support its economic aspirations and its location/ relationship to North West should be made clearer. This need for more housing to support the County is not properly articulated by the phrase, ‘facilitating a mixed diverse community’.  No mention of the importance (immeasurable) of preserving countryside for its aesthetic beauty.  has been considered but not the Welsh landscape.  Should make a specific reference to the Local Authority’s statutory duty to secure sufficient opportunities for children’s play. Could be included as a distinct objective under the ‘social heading’ or perhaps added to objective S06: Promote and encourage a healthy, active and safe lifestyle .  Objective SO2 should be expanded: Support a vibrant, diverse and competitive local economy that provides a range of job opportunities meeting the needs of the population for employment and to enable the new and existing businesses to grow in Wrexham County Borough.  Wrexham has a wealth of wonderful countryside that is attractive to visitors and residents, the maintenance and nurturing of this does not seem to be in the plan.  Objective SO4/SO6: Infrastructure needs to be provided for active travel, as this is virtually non-existent in the county and what used to exist has been removed. Long distance, all weather walking and cycling routes are required.  S05 Should there be mention of Social Housing.  Tarmac Trading Ltd recommend the inclusion of wording in Objective SO11 which seeks to safeguard mineral resources and makes reference for the need to ensure that adequate buffer protection or standoffs are provided in line with Policy SP12. This is in order to

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safeguard resources/reserves as well as preserving the amenity of neighbouring land uses.  Some of the objectives would benefit from spatial expression, to set out how objectives will be met through a spatial approach (WG).  Should be an objective that references the need to protect and support the continued growth of Wrexham Industrial Estate as supported by the Wales Spatial Plan and the Council's Economic Prosperity Strategy.  Meeting housing need in the County Borough should be a major Objective. Delivery of housing is only mentioned once in Objective SO5 under the Social sub-heading.  Objectives of the Plan need to recognise the need and importance of housing delivery under each strand of sustainability. Consideration should be given to avoiding segregation of the Objectives into three strands of sustainability, mutually dependent and should not be viewed in isolation.

4.13 Consideration will be given to the refinement of the Vision and Objectives based upon the comments above and by making the Vision more distinctive to the Borough and adding spatial expression to the objectives where appropriate.

(Q3) Preferred Strategic - Level of Growth (Option B)

Q. No. %Agreed %Not % Not Total no. of Agreed Stated Responses 3 31(26) 62(53) 7(6) 85

4.14 The majority of responses, 62 % did not agree 31% agreed and only 7% did not answer either way. The following supporting comments were made:

 Welsh Government support the Council’s considerations of both employment –led projections (Option A) and population based projections derived from the latest 2011 based Household Projections (options B-D).They also support the inclusion of the flexibility allowance.  Consider that Option B has been suitably demonstrated as being sound and appropriate.  Option B will help deliver service and infrastructure within Mawr and assist in the goals and proposals of the Plas Kynaston Canal Group.  Supports this option but has concerns about the green barrier developments in the urban villages particularly Gwersyllt North.  Some land in appropriate locations could be allocated either for housing or employment or both/ to allow flexibility if needs change in the future.  Clwydian Range and Dee Valley AONB Joint Committee support an approach which seeks to limit growth to reduce negative environmental impacts.

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 Barrett Homes - Option B broadly aligns with the Welsh Governments 2011-based projections.  Gwersyllt Community Council - Previously supported the employment led projection but considers 11,000 too high. The target should be changed to a more achievable target of 10,000 dwellings.

4.15 Flintshire County Council welcomes the fact that their previous comments have been taken into account and no objection is raised by their members to growth Option B.

4.16 Denbighshire County Council highlights that it is imperative at Plan- Examination stage to challenge house builders to deliver the promised number of houses.

4.17 Comments not supporting the Preferred Strategic Level of Growth (Option B):

 The scale of housing is too much. It is out of proportion to the need and excess of any previous rate of housebuilding. Several hundred houses are for sale or rent, demand is not high.  Prefer Option D, as more homes means more need for public services.  Option B will place too much strain on infrastructure such as highways, education, schools, council services and health.  High number of premises unoccupied and for letting on Wrexham Industrial Estate.  Level of growth is un-sustainable because of the demands that will be placed on public services and road congestion.  A number of housebuilders prefer Option A –as it would address the identified shortfall and support economic growth aspirations. Objective evidence demonstrates that housebuilding has been constrained by the economic recession and the Green Barrier restricting the delivery of sites.  The original withdrawn LDP which included provision for 8,000 homes was more realistic.  Projected need does not account for the number of homes for rent or sale.  Believes the population calculations are fundamentally flawed. Basing figures on the recession is fundamentally flawed.  The evidence for the justification of Option B relates to the findings of the Sustainability Appraisal. This assumption is premature given the detailed site selection process has yet to be completed.  Lacks adequate ambition and fails to respond positively to Planning Policy Wales. Concerned that an employment led projection appears to be dismissed in favour of a migration led approach (Redrow).  Should convert empty buildings instead of building on greenfields and flood plains.  Wrexham is unable to afford the provision of infrastructure associated with proposed housing levels.

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 The industrial estate is 500 ha employing 7000, 53 ha is woefully inadequate to deliver 7500 new jobs in the County.

4.18 Welsh Water highlight that they have a duty to extend and improve their assets to accommodate future growth. They aim to ensure sufficient infrastructure exists for domestic development and seek to address deficiencies through capital investment in their 5 year Asset Management Plan.

4.19 Welsh Government state that it is for the LPA to justify its housing provision having regard to Planning Policy Wales. The plan would benefit from additional contextual commentary relating to the unique economic factors which were experienced in Wrexham and resulted in the maintenance of growth throughout the recessionary period. It will also need to illustrate a 5 year supply on adoption.

Matters to be addressed by the Deposit Plan

4.20 As the plan moves forward into a more detailed site analysis a finer grained Sustainability Appraisal of the sites will be undertaken. The Plan will explain the unique economic factors in Wrexham and demonstrate a 5 year deliverable housing supply.

(Q4) Preferred Strategic Spatial Strategy

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 4 53(32) 42(25) 5(3) 60

4.21 The majority of responses, 53 % agreed and 42% did not agree and 5% did not answer either way. The following comments were made:

In terms of support, the following comments were made:

 Natural Resources Wales considers that the settlement hierarchy that has been identified will ensure development will take place in the most sustainable settlements.  A developer supports the approach to housing on greenfield land adjoining sustainable settlements such as Overton.  should become the Rural/Urban Transport Hub for the South Wrexham, the Dee Valley and the Pontcysyllte WHS with improved rail and transport infrastructure.  Agree with Wrexham Town being the centre of development. Any development outside should be on brownfield.  Believe it would be beneficial to create two tiers of Local Service Centres to establish which have the highest level of infrastructure and services such as Rosset in particular, which is one of the more sustainable Local Service Centres.

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 Offa Community Council - Reservations over dominance of town centre sites being developed for residential resulting in new employment being concentrated on WIE. Equal priority should be given to Western Gateway Business Park.  This aspect of the plan seems sound and well thought through.  Feel that exhibits more characteristics of a key Settlement than other local services.  The Preferred Spatial Strategy rightly identifies the importance of sustainable growth around settlements including Tier 3.  Community Council welcomes any proposed development that is focussed on Wrexham and the larger villages in the County Borough.  Agree that Tiers 1 and 2 are best placed to provide the size of housing required near employment and all the infrastructure and facilities required.  Cross boundary consideration should also include working with West and Chester.  Spreading development throughout the Borough is in the best interests of all. has a sustainable shopping street and many local services.  Clywdian Range and Dee Valley AONB Joint Committee, Chirk Town Council and Bronnington Community Council support Option 3.  Barrett Homes support the spatial strategy and key strategic sites. For such a scale of development to be delivered over the remaining Plan Period a significant and reliable source of greenfield allocations is necessary  Support Brymbo as a local service centre within the settlement hierarchy.  Option 3 preferred. Rural services are declining because they are declining economically.

Comments not supporting the Preferred Strategic Spatial Strategy:

 HBF agree with the Spatial Strategy which offers an opportunity for a wide range of housing to be delivered and avoids over reliance on one particular area. However they go on to suggest more flexibility at this stage, there may be settlements which are unsuitable for development and as such do not offer any opportunities for growth due to constraints.  Brymbo developments consider that Brymbo should be considered a key settlement.  Amend settlement tiers to allow for smaller sites to be allocated.  Outlying villages already overdeveloped and cannot cope with further development.  Development should be focussed on Tiers 1 and 2. Other options require much investment and step outside an integrated approach.  Object to the loss of green fields and trying to force extra houses into small villages.

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 Brownfield sites should be favoured wherever they are before greenfield sites.  Develop derelict land rather than greenfields by Wrexham Rugby Club and 's playing fields.  Disagree that Overton has relatively good accessibility by non-car modes. Should be moved to either Tier 4 or 5.  Object to the inclusion of Burton on the basis of poor facilities.  has not been fully exploited based and the decline of the high street and the number of empty properties.  Emphasis of growth around the town centre should include the settlements of Pentre and Cross Lanes which have much improved highways provision to the industrial estate.  Further development would not be supported in Gwersyllt due to its highways and ecology.  Gwersyllt Community Council suggests an alternative option: Focus development on Wrexham Town coupled with new development in Pentre Maelor and Cross Lanes which is close to WIE and available employment opportunities.  The true test will come when the split of development between Primary and Key Settlement and other settlements is identified, if the strategy is to succeed.  Option 1 should be the Preferred Strategy. Growth should be focussed on Wrexham town with smaller growth in secondary settlements.  Whilst Option 3 and Coedpoeth as a Tier 2 Settlement are supported, the settlements status is not reflected by the proposed limited employment allocation at the Five Crosses Industrial Estate.  Canal and Rivers Trust, suggest that the strategy should still acknowledge the opportunity for the reuse of previously developed land and buildings and its intent to work with landowners to bring these sites forward.

General Comments

4.22 Welsh Government state that the spatial strategy is clearly articulated informed and assessed by the LDP Vision and Objectives. If there is evidence at this stage that some settlements cannot accommodate growth, the Preferred Strategy should be clearer on this point. In assessing individual sites and sites in combination, the Council will need to demonstrate that sites are genuinely available and deliverable.

4.23 Flintshire County Council endorse this approach on the basis that it distributes growth across the Borough and provides a sustainable approach by allowing growth in the lower tier settlements.

4.24 Welsh Water highlight that not every settlement in the County is served by its own Wastewater Treatment Works (WwTW), and that the catchment areas of some of the WwTw cover numerous settlements. In terms of preferred

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spatial Growth Option 3, the impact will be dependent on the amount of growth within the individual catchment areas.

Matters to be addressed by the Deposit Plan

 Discussions have taken place with key infrastructure delivery partners and ongoing engagement will continue throughout the LDP process.  The Deposit Plan will provide clarity on the components of housing supply and demonstrate that all components are viable and deliverable within the plan period.

Comments on the Draft Strategic Policies and Policy Approaches

(Q5) SP1 Economic Growth, Employment and Enterprise

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 5 64(27) 33(14) 2(1) 42

4.25 The majority of consultees agreed (64%) with the approach to Economic Growth, Employment and Enterprise as set out in policy SP1, quite a few also disagreed (33%).

Key issues raised in relation to this policy covered:

 The proposed level of growth is too low. An appropriate expectation of growth in jobs would require an equivalent increase in employment land allocations.  A need to identify the approach to employment allocations in settlements in the lower tiers of the settlement hierarchy.  Links to sustainability and providing employment opportunities near to where people live.  The need to consider the wider economic benefits of uses beyond the traditional ‘B’ uses.  Opposition to the extension of WIE.  The need to protect amenity of existing business, and avoid conflict with alternative uses being promoted near established employment areas.  A requirement for a clear link between the evidence base and the level of proposed employment provision as the current explanation of the level of provision appears contradictory (WG).  A need to justify the oversupply of employment land (WG)  Inclusion of an additional bullet point which relates to maintaining viable communities outside Wrexham.

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 Suggested inclusion of following text, ‘All development proposals should safeguard the amenities of existing businesses and provide mitigation measures’.  As well as ensuring a supply of deliverable employment land, it should also be ensured that facilities to support these uses and their employees are also delivered to ensure the County Borough remains an attractive location for new and existing businesses and that Wrexham Industrial Estate continues to perform its function as a major regional and national employment centre.  SP1 should still highlight that housing delivery is an essential component of a successful economy.

Matters to be addressed by the Deposit Plan

4.26 Demonstrate clear explanation between the level of employment provision provided for in the LDP and the requirements set out in the evidence base. Consideration re-wording of policy and supporting text to address some of the issues raised.

(Q6) Strategic Policy 2 Infrastructure Priorities and Developer Contributions

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 6 63(25) 35(14) 3(1) 40

4.27 Although most consultees agreed to this policy (63%), quite a few also disagreed (35%). Whilst many comments were expressing support and agreed that new development should provide for key infrastructure, it was felt that the extent of this requirement should be established through viability.

4.28 Welsh Water provided confirmation that it is their aim to ensure sufficient infrastructure for domestic development and indicted that an adopted development plan gives weight when seeking Asset Management Plan (AMP) funding. It was advised that Ofwat will only provide funding where development is confirmed. It was further identified that where specific infrastructure improvements are required to bring a development forward in advance of investment through the AMP, that support is given to provision within the policy to seeking financial contributions from developers to secure the improvements.

In terms of changes or improvement, the following comments were made:

 Improvements to health care provision should be included.  Mitigation to protect and conserve the historic environment should be included.  HBF object to the words, ‘expected to provide’. Should be made clear that developers only need to provide infrastructure where it is directly

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related to the development and necessary, and should not be seen as an opportunity to address existing infrastructure problems.  HBF also consider that neither ‘ecological mitigation’ nor ‘surface water management’ should be included in the list, but that ‘water and sewerage infrastructure’ should be as this is more fundamental to the delivery of development.  Securing sufficient opportunities for play should also be included as a key infrastructure priority.  After 'Ecological Mitigation' insert, ‘and enhancement’.  Supporting information to justify the list of infrastructure requirements is needed.  Further detail about affordable housing is needed, including the threshold above which a contribution will be required and the proportion of affordable housing to be sought.  A contribution towards affordable housing should only arise where there is need and only where it is viable.  Ecological mitigation should not be included as infrastructure and should be part of the more detailed policies relating to the protection and enhancement of biodiversity.  One comment received suggested that this policy is not necessary.

4.29 Furthermore, on a general note, one comment referred to the need to invest in properly co-ordinated infrastructure provision, where it is clearly identified when local and central government contribute.

Matters to be addressed by the Deposit Plan

4.30 The Deposit Plan will need to be based on the most up to date viability evidence which should include the potential for a CIL charge. The list of requirements for CIL contributions will need to be refined along with greater clarity about what is required and when.

(Q7) Policy SP3 Wrexham Town and Wrexham Town Centre

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 7 80(24) 13(4) 7(2) 30

General Comments

4.31 The majority of respondents (80%) were supportive of the approach. While there was general consensus, there were observations which aim to improve the policy or which highlight issues to be covered in the Deposit Plan.

4.32 Welsh Government commented that no reference is given in the policies to the retail need identified in the retail assessment reports. The background papers note that the convenience need will be distributed amongst the lower order centres but this is not stated in a strategic policy which ideally it should

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be to indicate the retail strategy of the plan. For comparison goods it is understood the strategy is to locate sites for the identified need in Wrexham town centre. The strategic policy should be clear on this point.

4.33 There was some concern from other respondents not to lose opportunities to deliver traditional employment in the town (i.e. employment excluding retail, tourism, education and civic functions).

Comments supporting the approach to Wrexham Town and Wrexham Town Centre:

 Support for focussing development in tier 1 Wrexham from some house builders and an agent acting for a food retailer.

 Support for the policy as a means of tackling town centre accessibility and safety issues and as an opportunity to claim trade back from outside the County Borough.

 The House Builders Federation support the regeneration role housing can play but request that the direct/indirect regeneration benefits are part of the wider viability consideration.

Comments not supporting the approach to Wrexham Town and Wrexham Town Centre:

 Opposition was commonly related to the development of greenfield Key Strategic Sites on the edge of Wrexham with observations that this will be to the detriment of access to the town centre.

 While not opposing the policy there was concern from one respondent that the important role of the Racecourse was not recognised in the policy; one respondent opposed development in Wrexham if it was to the detriment of people who already lived there; and for one respondent there was some concern the policy was too focused on Wrexham and not considering the contribution other service centres can make, particularly Cefn Mawr.

 There was some concern from an agent for a food retailer that the policy does not recognise the clear demand for retail in the County Borough and the role Bodhyfryd could make in meeting this need. They also expressed concern that the objectives actually focus on the town centre alone, which does not clearly demonstrate the flexibility required to promote the objectives across the wider town area (which needs to be clearly defined). They propose that two separate policies must be presented, clearly defining the objectives for a) Wrexham Town (wider area) and b) Wrexham Town Centre.

 Furthermore, it was felt that there should be alignment and clarity between the Wrexham Town Centre Masterplan and Wrexham Town Centre boundaries to remove any confusion. Given there is a clear

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quantitative as well as qualitative need for additional retail floorspace, opportunity sites such as the Bodhyfryd site within the draft Town Centre Masterplan should be allocated to include retail use; and the town centre boundary should be expanded in line with PPW to accommodate growth in retail floorspace.

Matters to be addressed by the Deposit Plan

4.34 Deposit Plan to contain a retail hierarchy, including district and local centres, town centre boundary, primary and secondary shopping streets. Clarity about the retail needs and approach to meeting those needs and a criteria based policy for determining applications on unallocated sites.

(Q8) Policy SP4 Transport and Accessibility

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 8 66(23) 23(8) 11(4) 35

General Comments

4.35 The majority of respondents (66%) were supportive of the approach, (23%) disagreed and 11% did not answer either way. While there was general consensus, there were observations which aim to improve the policy or highlighted issues to be covered in the Deposit Plan.

4.36 There was acknowledgement that addressing congestion and transport issues are necessary to help regenerate the Town, unlock sites for development and meet the LDP housing targets.

4.37 There were concerns that just improving the junction of the A483 and A525 will not be sufficient as there are other junctions e.g. junction 5 of the A483 with identified constraints and there will be a knock on effect on junctions wider afield.

Comments supporting the approach to Transport and Accessibility:

 Welsh Government supported the emphasis in the Preferred Strategy on accessibility and health and the importance of having an effective strategy for transport.

 There were some general comments that were supportive, particularly with regards to improving Junction 4 of the A483 and to improving rail use.

Comments not supporting the approach to Transport and Accessibility:

 There was concern from a house builder that the requirement for contributions to specific projects should be limited to the level of impact

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that the particular development would have proposing the wording of the Policy should be amended accordingly.

 There were respondents who do not support the approach to transport but their comments were not about the policy as such but the negative implications that development in Overton, other tier 3 settlements and the Key Strategic Site at Bryn Estyn Lane would have on the policy ambitions to encourage sustainable transport.

 There were some general comments from a wide range of respondents and developers on improving the policy to address omissions or emphasis including; putting a stronger focus on creating safer residential streets to support children’s independent mobility and play; a need to seek places suitable for new rail stations and halts; the need to make other less sustainable travel options less attractive; absolute pedestrianisation in Wrexham Town Centre without exemptions (including blue badge holders); and a need to provide roadside services on key routes.

Matters to be addressed by the Deposit Plan

4.38 Detail the approach to delivering infrastructure necessary to support the strategy and objectives of the plan.

(Q9) SP5 Protecting, Conserving and Enhancing the Natural Environment

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 9 71(27) 24(9) 5(2) 38

4.39 Although most consultees agreed with this policy (71%), nearly a quarter also disagreed (24%). The key issues/ themes relating to the policy are identified below:

 Contradiction between policy to preserve natural environment and development of greenfield sites.  Need for reference to wetlands in policy.  Need to differentiate between the relative importance of different features within the environment.  General improvement in the overall clarity of the policy.  Welsh Government – With regards to the approach to non-European sites, need for distinction between the different tiers of designation. Need to adequately cover flooding in the plan. We also need to continue to work with them to establish the BMV of sites moving forward.

Matters to be addressed by the Deposit Plan

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4.40 The wording of the policy in the Deposit Plan will need to make clear the approach to different tiers of environmental designations. Some amendment and improvement in the overall clarity of the policy wording is necessary. The issues of flooding and BMV agricultural land will also be dealt with at this stage.

(Q10) Green Wedge

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 10 72(21) 28(8) 0(0) 29

4.41 Although most consultees agreed with this policy (72%), quite a few also disagreed (28%).

 Contradiction b etween policy and proposals to develop greenfield sites.  Potential impact upon the character of certain areas as a result of change to Green Wedge.  Comments regarding the need to conduct review of all existing Green Wedge designations.  Need to balance requirements for Green Wedge against the need to provide land for development.  Need to review the indicative boundaries of the Green Wedge areas identified in the Green Wedge Strategic Review (Stage 1).  Object to the grouping of some sites together as part of the Green Wedge assessment.  Additional land associated with KSS2 should be excluded from Green Wedge.

Matters to be addressed by the Deposit Plan

4.42 Completion of the second stage of the Green Wedge review is necessary prior to the Deposit LDP consultation. The Council will consider the points raised regarding the boundaries of the indicative Green Wedge areas identified in the Stage 1 review in light of site specific comments received. Comments made regarding the methodology used will also be considered, and whether amendments to the approach is necessary.

(Q11) Policy SP6 Promoting Health & Wellbeing

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 11 81(26) 16(5) 3(1) 32

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4.43 The majority of respondents (81%) were supportive of the approach with (16%) disagreeing and (3%) not answering. While there was general consensus there were observations which aim to improve the policy or highlighting issues to be covered in the Deposit Plan.

Comments supporting the approach to Health & Wellbeing:

 The Local Health Board supports the approach in being consistent with the objectives shared by partners in ‘Our Wrexham Plan’.

 A respondent had concerns the policy does not give enough recognition to the importance of securing sufficient opportunities for children’s play.

 The point was raised that to promote walking, cycling and healthy lifestyles that developments should be located in close proximity to shopping employment etc. and that developments should provide opportunities to encourage healthy active lifestyles and integrate with existing networks.

 One respondent identified the role canals, green and blue corridors and bringing the natural environment into urban areas can play in promoting healthy lifestyles.

 One respondent promoted development around the Aqueduct as having potential to encourage walking and cycling.

Comments not supporting the approach to Health & Wellbeing:

 The Coal Authority had concerns that land instability has not been referred to in the policy or in the strategy.

 Rather than commentary on the approach to Health and Wellbeing outlined in SP6 there were localised concerns that growth in Llay, Overton, Penycae and Rossett would impact negatively on public open space and recreation provision in these areas, that growth in these areas would be contrary to the aims of policy SP6.

Matters to be addressed by the Deposit Plan:

 An assessment of the location of development and ability of sites to encourage active travel will be undertaken in selecting sites, this will be informed by the role of green networks, blue infrastructure, etc.

 As part of the site selection process we will need to take into account the nature, scale and extent of land instability.

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(Q12) Open Space, Sport and Recreation

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 12 80(24) 17(5) 3(1) 30

4.44 Although most consultees agreed to this policy (80%), quite a few also disagreed at (17%). The key issues/ themes relating to the policy are identified below:

 Contradiction between policy and potential development of greenfield sites.  Consider re-wording in order to identify wide spread benefits of open space to all members of the public.  Need to incorporate play sufficiency work.  House Builders Federation – Acknowledgement of new ways of providing open space e.g. shared facilities, all weather pitches etc. New development should not always be expected to provide on-site provision. Policy should be flexible and allow for off-site provision.  Link between open space and green infrastructure should be highlighted in the policy.  Need for more informal open space.  Need for clarity of quantity standard in Deposit Plan. Allow for flexibility i.e. off-site provision, and or contribution to existing sites.

Matters to be addressed by the Deposit Plan

 No policy wording was included in the Preferred Strategy. The points raised above are relevant and will need to be considered in the development of the open space, sport and recreation policy in the Deposit LDP.

(Q13) Allotments and Food Growing

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 13 96(25) 4(1) 0(0) 26

4.45 The responses to the inclusion of Allotments and Food Growing were greatly positive, with the majority of consultees agreeing (96%) to the inclusion of this as a topic area in the Deposit LDP and with only a very small minority disagreeing (4%).

4.46 With this high level of support, only a few comments were made, most notably:

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 Rather than just promoting communal growing space, more actual space should be identified and made available for this purpose.

 Agreed with recommendation that existing allotments are preserved and the provision of new allotments expanded in or around new developments.

 The HBF have no objection in principle but any policy which requests the provision of allotments must be supported by an up to date evidence base of existing provision and need. Also indicated that reference should be made to the growing move towards informal community growing spaces.

 Welcome the idea of ensuring a future for more allotments, properly managed and controlled.

Matters to be addressed by the Deposit Plan

 Identify the existing provision and collect data on the evidence of need.

(Q.14) Housing Provision Policy SP7

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 14 49(17) 49(17) 3(1) 35

4.47 The responses to Policy SP7 on housing provision were fairly equal in terms of the percentage that agreed (49%) and those that disagreed (49%).

4.48 It was felt by three respondents that the housing figures should be higher at 13,010 in line with the employment-led scenario and that 11,715 houses is too low. It was thought that the higher figure would be more appropriate to deliver the housing and economic growth envisaged in the Wales Spatial Plan and would better reflect Wrexham’s position as the key focus for housing and employment in North Wales. It was also mentioned that the reliance on 150 dwellings per annum as windfall is too unrealistic given that 81 dwellings were recorded in the JHLAS and that the number of allocations therefore needs to be increased.

4.49 One respondent indicated that the levels of growth are too ambitious and one suggested that the provision should be clearly identified as a minimum requirement

4.50 Objections have also been raised relating to the title of the chapter heading under which this policy lies, which has prompted such comments as, ‘Not sure why the main purpose of a policy for housing provision is to support equality….surely this is the role of the Local Plan as a whole, not just parts of it such as housing. Policy SP7 - housing provision should be a chapter in its

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own right, not hidden in a chapter headed, “A More Equal Wrexham”, which we find illogical and confusing.’ and ‘all other strategic policies have clear titles which reflect the strategy, this is not the case for this one, it relates to the provision of housing yet the word housing is not in the title.

4.51 Concern was also expressed by the HBF that there seems to be an overreliance on large strategic sites. The HBF suggest that to show a five year land supply during the life of the plan the allocation of a range of smaller sites is also required in addition to the strategic sites to enable development to come forward in the early years of the plan. 4.52 One comment related to the need for housing developments to have access to multiple spaces for play in close proximity.

4.53 The provision of a flexibility allowance is supported, however, it was highlighted that it needs to be demonstrated that this is sufficient enough to respond to economic challenges and unforeseen circumstances.

General Comments

 The Deposit LDP should clearly set out the components of the supply and demonstrate that they are viable and deliverable over the plan period.  An explanation on how sites will be phased will be required. This should be informed by the housebuilding industry to provide evidence of the ability or otherwise of housebuilders to meet build rates and also the delivery of infrastructure.  Commentary is needed in the LDP on how the level of affordable housing required has influenced the scale and location of growth.  The threshold for securing affordable housing suggested in the viability study of 25 units seems high. This needs to be clearly evidenced including the involvement of all relevant stakeholders.

4.54 In terms of the general comments on policy wording, the following comments were made:

 The use of the term expected in the policy, new development will be expected to’ is not supported. Some or all of the requirements will not be justified in every case and are inappropriate for market-led housing schemes. The policy should be more flexible.  Not clear how a proposal for new housing development can redress the imbalance between market and affordable housing. This appears unreasonable. New development should not be burdened with "redressing any identified imbalance between market and affordable housing". Instead a specific requirement for affordable housing provision quantum and tenure should be included in the policy. The reference to "any" is too broad and open. A reference to viability should be added to ensure developers have the opportunity to provide evidence to justify not complying with policy, specific to housing mix i.e. affordable housing provision, should the need arise. This way, there is flexibility and strength in the LDP’s ability to meet its housing targets.

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 Emphasis should be placed on the importance of meeting needs for affordable rural housing for local people.  Question asked about the meaning of the term maximise, in delivering affordable housing and that viability should be used.  In terms of density, there is support for not setting a blanket density but it was felt that the emphasis should be on the efficient use of land and delivering housing in a range of types and densities appropriate to a locality and should be informed by context, character and design aspirations, as well as the need to deliver upon the Council’s housing targets.  Question asked about the extent to which a mix of types of housing will be dictated.  One comment suggested a re-wording of the policy to ensure it supports development in accordance with the overall spatial development pattern, along the lines of ‘the Council will promote the effective reuse of land by encouraging housing development including redevelopment, infill and the change of use of existing buildings to housing, on all sites suitable for that purpose. Supporting housing development on unallocated sites within settlements.’

Matters to be addressed by the Deposit Plan

4.55 The Plan will need to clearly demonstrate that sites are genuinely available and deliverable within the plan period. Phasing of development will also be required. Consideration will be given to the re-wording of policy, to ensure greater clarity including more detailed explanation and careful use of wording. Key timings, phasing and funding mechanisms will be essential to ensure that infrastructure can be provided to the required timescales.

(Q.15) Gypsy and Traveller Accommodation Approach

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 15 62(8) 31(4) 8(1) 13

4.56 Although the highest percentage of responses agreed (62%) to the approach proposed for Gypsy and Traveller Accommodation in the Local Development Plan, the percentage that disagreed was 31% and 8% did not answer either way.

4.57 However, the only significant comments raised in respect of this matter refer to not putting a restriction on the number of private pitches that can be built on one site (in accordance with the views of the Planning Inspector in considering Gypsy and Traveller provision in the withdrawn LDP) and the need to make provision to meet the requirements of the updated GTAA as referred to in the Preferred Strategy.

Matters to be addressed by the Deposit Plan

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4.58 The Deposit Plan should make provision to meet any identified need for Gypsy and Travellers over the full plan period 2028, in line with the results of the GTANA 2016. In addition the plan will include a criteria based policy as advocated within national policy.

SP 8 - Location of New Development (Q.16)

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 16 51(26) 43(22) 6(3) 51

4.59 There was a relatively even balance in responses to this question, with 51% agreeing, 43% disagreeing and 6% not answering. The key issues/ themes relating to the policy are identified below:

 Concerns regarding scale of development.  Pressure on existing infrastructure.  Brownfield sites should be developed prior to the allocation of any green field sites.  Concern regarding the capacity of settlements to accommodate development.  Queries regarding employment opportunities in the lower tier settlements.  Betsi Cadwaladr Health Board stated that there are implications for capacity and sustainability of health services in the area, including primary care, community services, hospital services & mental health services. Need to consider the implications of the aggregated population growth and map this to assessment of population health needs.  Concern that the policy indicates that the development of a previously developed site in one of the key settlements or local service centres may be resisted if opportunities are still available in the primary key settlement.

Matters to be addressed by the Deposit Plan

4.60 The consultation did highlight concern regarding the scale and location of development. A lot of these concerns were identified in response to sites included in the site register. The deposit LDP will include all proposed Key Strategic and non-strategic allocations, and will indicate the scale of development proposed in each settlement.

4.61 Concern regarding the appropriate scale of development tended to focus on the ability of local infrastructure including highways, schools, sewerage, health care provision etc. to cope. An understanding of the potential impact upon local infrastructure and any necessary mitigation will be required prior to the allocation of sites in the Deposit Plan.

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4.62 The deposit LDP should clarify the employment opportunities in the lower tier settlements which are earmarked for development. The deposit LDP should outline the approach to the phasing of development between the various tiers.

(Q17) Key Strategic Sites and Area of Search

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 17 49(21) 44(19) 7(3) 43

4.63 There was a relatively even balance in responses to this question, with 49% agreeing and 44% disagreeing. The key issues/ themes relating to the policy are identified below:

 Object to over development as it would result in severe impact on , and have been subject to significant recent growth.  Further development should be in this instance focussed on brownfield sites within settlement.  Loss of greenfield land, adverse impact on roads, increased traffic congestion, safety for cyclists and loss of sustainable transport links to the countryside.  Russell Homes (UK) Ltd do not support Policy SP9 because they believe that KKS1 & KKS2 are undeliverable within the Plan Period.

KKS1: Lower Berse Farm, Ruthin Road, Wrexham

 Redrow support the broad principle of identifying the two Key Strategic Sites. The issues with the junction at the A483 are acknowledged, but it is also recognised that there are capacity issues at the junction, not only for the development of KSS1, but also in relation to the Western Gateway and the development of the town centre, as the Preferred Strategy recognises. The capacity problems may ultimately, have to involve Welsh Government funding, however it is hoped that KKS1 can progress without placing undue financial burden on the project which would threaten its viability.

 Three representations highlight that the fields and adjacent areas are prone to surface water flooding .Loss of greenfields will lead to loss of identity. Use brownfield first.

KKS 2 Land to the east of Cefn Road

 Offa Community Council express serious reservations about KKS1 Concerned about the merging of the two communities of Offa and Bersham which would have adverse effect on communities. Adverse

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transportation impacts, environmental impacts; social impacts/negative implications on local communities and quality of life/strain on local facilities especially schools, health care and recreation provision. Significant improvement needed to the A483/A525 junction. The playing fields are Ysgol Clywedog must be retained.

 Barratt Homes objects to the extent of KKS2 as it fails to include all of the land being promoted for development by them (Alternative Site Ref WR001AS). They propose that the KSS2 boundary is extended to include the full extent of land being promoted by Barratt Homes. It is hoped that the Council would recognise its potential as a key stand- alone Key Strategic Site capable of delivering in the region of 500 dwellings.

Other general comments:

 Ysgol Morgan playing fields should be retained  Concern about the additional traffic resulting from the proposed development. Policy seems contradictory, bullet point 4 states that Ysgol Morgan Llwyd playing fields are to be retained yet these have been included in the overall proposed development area, they constitute almost half of the entire Cefn Road frontage of the site. If they are retained they surely should be shown on the plan.  The development of Lower Berse Farm is adjacent to the only alternative walking/cycling route on the A483.  Aldi Stores Limited UK requests that SP9 includes convenience retail provision.

Employment: Area of Search Land to the North of Bryn Lane, Wrexham Industrial Estate.

 Concerned about the expansion of the industrial estate, as there appears to be a number of large empty plots and empty units.  Welsh Government highlight that the Plan needs to be clear on the mitigation strategies needed as part of the WIE expansion and how this fits in with the existing frameworks for protected species at the industrial site.  Kingmoor Park Properties Limited support this aspect of the policy if the land at Bryn Lane is allocated for employment uses and included within the settlement boundary.  Not interested in industrial development on the north of Wrexham Industrial Estate as identified in the area of Search ‘A’. Consultee owns the land and is pursuing the development of a solar farm.

General Comments

4.64 HBF concerned that presuming the Key Strategic Sites are at an early stage, then they are concerned that there is some very detailed and specific requirement contained with strategic policy, which would seem to prejudge any further development brief or planning application.

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4.65 Welsh Water - The scale of growth proposed at the KKS1 and 2, along with their location, means there will be a requirement for off-site sewers to be provided to the boundary of and within the development site.

4.66 Tarmac Trading Ltd - are particularly concerned regarding WRO9CS and WR10C. Although, they have no impact in terms of mineral sterilisation, a particular concern would be potential visual impacts from Quarry on potential development. They believe that in order to protect new development from the potentially harmful amenity issues associated with mineral working, new development should be channelled to areas that would not result in the loss of mineral resources or should seek the extraction of minerals prior to development.

 Betsi Cadwaladr Health Board – Ask for consideration of health services infrastructure on the key strategic sites.  Flintshire – no significant impacts upon Flintshire therefore not concerns raised on these sites.  Denbighshire –advised that supplementary planning guidance for these sites is available for developers as soon as possible because Plan delivery and Strategy implementation depend upon them  Welsh Government – states that the evidence supporting the strategic sites is limited at this stage. The Council will need to demonstrate that the Key Strategic sites can be delivered.  North and North Wales Canal and Rivers Trust - suggest a new Strategic Opportunity site should be identified focused on the Cefn Mawr/World Heritage Site/Trevor Basin

Matters to be addressed by the Deposit Plan

 The Council will continue to liaise with Welsh Water to monitor the capability of their infrastructure to accommodate the planned development within the LDP and inform them of future works planned through their regulatory investment.  The indirect impacts of the key strategic sites will form part of the Council's considerations regarding their inclusion within the Deposit LDP.  Evidence base will need to demonstrate that the Key Strategic Sites can be delivered.

(Q.18) Policy SP10 Conserving, Protecting and Enhancing the Historic Environment

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 18 91(29) 6(2) 3(1) 32

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4.67 Consultees who responded to this question were overwhelmingly in support of this Strategic Policy and its aims with 91% being in agreement and only 6% disagreeing with the Policy. Whilst not every consultee provided further comments, the majority who did, expressed their support for the Policy with additional comments recognising the role of the Historic Environment in supporting economic health through tourism, regeneration and employment as well as supporting sustainable communities through cultural wellbeing. In terms of regeneration and tourism, comments received related specifically to the WHS, Cefn Mawr and Brymbo.

 Suggest that cultural well-being be given recognition given its contribution to creating sustainable communities and suggest an additional policy for inclusion that resists the loss or change of use of existing community and cultural facilities unless suitable replacement facilities are provided on site or in the vicinity;  To ensure economic regeneration of Cefn as well as heritage led regeneration, the village needs to be reunited to the aqueduct to bring tourism into Cefn Mawr in meaningful numbers or eventually all the shops restored under the THI scheme will close and all the conservation work will be lost;  Enhancement of Historic Environment tourist assets should also produce additional employment opportunities;  Suggest the phrase "Scheduled Ancient Monuments and heritage assets" might be more appropriate in the final bullet point of SP10 and the seventh bullet point of the Topic / criteria based policies;  Signage on public footpaths should be bilingual across the County Borough;  Promoting tourism with all the heritage and history is much needed and will help remove the negative label Wrexham often has;  Planned and effective development can only enhance use, assimilation and discovery of the vital heritage in the county;  Current development proposals for Brymbo are based upon the area becoming a vibrant, heritage-led, mixed use destination. Retention and utilisation of the important historic assets will only be possible if Brymbo itself is allowed to regenerate and prosper. The Local Plan should be seeking to assist this process (Brymbo Developments Limited);  We welcome the inclusion of policies that look to protect and enhance the County Borough's heritage assets, particularly SP10. The Deposit LDP should contain focussed heritage policies that aim to ensure the continued protection and management of its local assets, such policies must be locally distinctive and consistent with neighbours e.g. World Heritage Site (Welsh Government);  Policy wholly consistent with AONB Management Plan (Dee Valley and Clwydian Range AONB Joint Advisory Committee);  Welcome recognition of the World Heritage Site within the policy and the role of the historic environment in adding value to regeneration proposals, attracting businesses and stimulating economic growth. Reference should also be made to non-designated heritage

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and cultural assets such as canal and related infrastructure (Canal Rivers Trust).

4.68 Those consultees who disagreed with the Policy expressed concern over the wording of the policy in relation to the impact of new proposals on heritage assets and offered an alternative to the text to read "proposals which do not harm the significance of the following heritage assets, will be supported". An additional comment expressed concern over the requirement to protect Wrexham’s heritage as a matter of urgency and suggested proposals for the demolition of existing buildings rather than refurbishment and repair, be refused permission by default.

Matters to be addressed by the Deposit Plan

4.69 As part of the Deposit Plan detailed criteria and topic based policies will be developed that support the Strategic Policy in relation to the World Heritage Site (WHS), Buildings at Risk, managing change within Conservation Areas and heritage-led regeneration. Tourism and regeneration opportunities surrounding the WHS will also be considered further and it is the intention that the LDP will support tourist facilities subject to a specific criteria-based policy. Consideration will also be given to the rewording of the Strategic Policy.

(Q. 19) Welsh Language

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 19 89(16) 0(0) 11(2) 18

4.70 The majority agreed with the proposed approach (89%) and (11%) did not answer either way. Welsh Government highlight the need for the Council to ensure that the SA considers the likely effects of the plan on the Welsh Language.

Matters to be addressed by the Deposit Plan

4.71 The deposit LDP should include statement on how policies take into account of the language in potential impact. The Sustainability Appraisal (SA) also takes into consideration the potential impact of the LDP on the Welsh language.

(Q.20) Policy SP11 Sustainable Design Principles

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 20 78(24) 15(4) 7(2) 27

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4.72 A high proportion (78%) of consultees agreed with Policy SP11 with 15% expressing disagreement and 7% not answering either way. Of the total respondents, just under half provided additional comments. Some consultees who supported Policy SP11 were positive in their appraisal of the policy particularly in relation to ensuring connectivity, good access, good design and the inclusion of heritage. However the need to bear in mind proportionality in relation to cost and scale of development was raised.

4.73 Respondents who disagreed with the policy expressed concern that SP11 was too detailed for this stage of plan preparation and that it is too specific. The Policy was also criticised for not having regard to children and their play and access to play requirements. Summaries of the key comments are provided below:

 Further consideration will need to be given to how this will be developed into design policies in the Deposit Plan.  Accept that the general principles of sustainability and good design are supported by national policy. SP 11 does seem to go into a lot of very specific detail compared to other SP policies. The HBF would suggest that such detail should be left to the next stage of the plan following further evidence gathering by the Council (HBF);  Sustainable development must pay greater attention to how children can use and move through space within their local communities, with a focus on ensuring children can make use of all that their neighbourhoods have to offer (rather than being confined to designated places for playing). This begins to emphasise the importance of children being able to walk and ride throughout their neighbourhoods independently and the role of the LDP in supporting this. Wrexham Play Sufficiency Assessments 2013 and 2016 should be included in the evidence base for this policy;  It is not clear whether its requirements have been the subject of viability testing. There is certainly no reference to this in the evidence base. We also express concern that the requirements of the policy are quite detailed when compared to other strategic policies of the Plan and suggest that the policy is less specific and more flexible (Barton Wilmore on Behalf of Barrett Homes).

Matters to be addressed by the Deposit Plan

4.74 Careful consideration be given to the precise wording of the policy and the evidence used to support this policy.

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(Q.21) Area of Outstanding Natural Beauty

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 21 100(23) 0(0) 0(0) 23

4.75 The majority agreed with the proposed approach (100%).

 Area of Outstanding Natural Beauty Joint Committee support this policy approach.

Matters to be addressed by the Deposit Plan

 No matters raised. The deposit LDP will include policies relating to the AONB.

(Q.22) and Canal World Heritage Site

Q. No. %Agreed %Not % Not Total no. of Agree Stated Responses d 22 91(21) 9(2) 0(0) 23

4.76 Significant support was shown for the approach to the WHS with 91% agreeing and only 9% disagreeing. Where comments were made in support of the approach generally, concern was also expressed that Cefn Mawr would not be included as part of the wider Destination Management of the WHS area as Cefn Mawr had previously been excluded from two previous masterplans concerning the area and land surrounding and nearby Trevor Basin and the former Flexsys site.

4.77 Respondents who disagreed with the approach provided additional comments that expanded on their concerns which are summarised below:

 Do not consider that the proposed approach outlined in the WLDP sufficiently addresses the unique challenge and opportunities presented by this important asset and the opportunities presented within the vicinity of Trevor Basin/Cefn Mawr area. The Trust requests that the approach is reconsidered in order to better reflect the wider ambitions and opportunities presented in this part of the WHS (Canal and Rivers Trust);  The beauty of the WHS has always been that it is quiet and undeveloped and this policy would change this. Development is already being permitted which damages the area and prevents use by the public.

4.78 The Canal and Rivers Trust are keen to ensure that a strategic vision is developed for the WHS area and consider that the Trevor Basin/Cefn Mawr

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area provides the opportunity to deliver much needed visitor facilities. The approach to the WHS included in the Preferred Strategy fails to reflect the potential of candidate Site AO6CS in helping to achieve sustainable growth and regeneration, particularly canal based tourism, leisure facilities and improved access and interpretation of the WHS as well wider redevelopment. The Trust highlight the ongoing collaborative work of CRT, WCBC and Eastman (formerly Solutia UK ltd) to delivering an all- encompassing and deliverable masterplan for the wider area around Trevor Basin which should be used to inform the LDP.

Matters to be addressed by the Deposit Plan

4.79 It should be noted that there is a requirement within the WHS nomination document and Management Plan to have consistent Development Management Policies relating to the WHS within the adopted LDP’s for Denbighshire, Wrexham and and the approach outlined as well as the topic based policies proposed for the LDP must meet this.

4.80 The potential of site A06CS in supporting the protection of the WHS and in meeting regeneration and tourism aims needs to be investigated further as part of the preparation of the Deposit Plan.

(Q23) Tourism Approach

Q. No. %Agreed %Not % Not Total no. of Agreed Stated Responses 23 96(23) 4(1) 0(0) 24

4.81 Significant support was shown for the approach to Tourism with the majority of respondents agreeing (96%) and the minority (4%) disagreeing.

4.82 The only comment received where the response does not agree with the approach refers to the provision of visitor facilities and infrastructure being planned at the World Heritage Site and Trevor Basin and the fact that Cefn Mawr does not form part of this. However, in response, it must be noted, that although the Preferred Strategy highlights key priorities in terms of tourist facilities at existing tourist destinations, it does not specifically preclude any areas from tourism development, and does set out that the LDP will include policies to support tourism opportunities. It also recognises that other tourism opportunities may arise and the intention is to support these subject to a specific criteria based policy.

4.83 Where comments were made by those who support this approach, it was welcomed and considered a ‘good thing’, particularly in helping to sustain areas that may otherwise wither and by supporting economic health. Another response in support used this as an opportunity to comment on how the aim for the former steelworks site in Brymbo is to tie into the attractions and industrial heritage of north east Wales with the area becoming a vibrant, heritage-led, mixed use destination for tourists.

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Matters to be addressed by the Deposit Plan

4.84 None at this stage.

(Q24) Strategic Policy SP12 - Minerals Supply and Safeguarding

Q. No. %Agreed %Not % Not Total no. of Agreed Stated Responses 24 79(19) 17(4) 4(1) 24

4.85 The key issues/ themes relating to the policy are identified below:

 The majority of respondents (79%) were supportive of the approach with 17% disagreeing and 4% not answering either way.  No mention of environmental sensitivity or environmental restoration to replace lost habitat.  Whilst Tarmac Trading Ltd support the principle of growth in the County Borough, this should not be to the detriment of mineral resources. In order to protect new built development from the potentially harmful amenity issues associated with mineral working, new development should be channelled to areas that would not result in the loss of mineral resources or should seek the extraction of minerals prior to development. This approach would protect sensitive new development and mineral working from one another.  Barrett Homes agree in principle to the aims of Policy SP12 in relation to the safeguarding of minerals. However, they stress that an up-to- date and accurate evidence base is essential to ensure that land is not safeguarded unnecessarily as a result of inaccurate information relating to the quality or commercial viability of mineral deposits thought to be affected.  Welsh Government highlight the need for the Council to demonstrate the rationale for making such allocations and that the potential for the extraction of mineral resources prior to the undertaking other forms of development has been considered in line with policy requirements.  Clwydian Range & Dee Valley AONB Joint Committee believe the policy outlines environmental constraints and an approach to meeting predicted demand for crushed rock from sites outside the AONB, but this is not reflected in the policy itself.

Matters to be addressed by the Deposit Plan

4.86 The Deposit LDP will provide clear evidence on how mineral supply and safeguarding has affected the development of the Deposit Plan and allocations.

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4.87 Detailed policies will demonstrate what is meant by the term’ sustainable location’. A background paper will demonstrate how mineral supply and safeguarding has been taken into account and shaped the LDP...

(Q25) Strategic Policy SP13 Sustainable Waste Management

Q. No. %Agreed %Not % Not Total no. Agreed Stated of Responses 25 91(20) 5(1) 5(1) 22

4.88 Significant support was shown for this policy with the majority of respondents agreeing (91%) and the minority (5%) disagreeing and 5% not answering. The key issues/ themes relating to the policy are identified below:

 Offa Community Council agree with the recommendation that local recycling sites should be retained within the town and re-introduced where possible.  This is the way forward, allying reduced and reducing transport to localised, managed and sustainable schemes.  Welsh Government has urged the Council to undertake a Renewable Energy Assessment.  There are opportunities for sustainable energy production/distribution in the 3 strategic sites (e.g. district heating, waste to energy) and this should be specifically mentioned in the policy so that it gets consideration e.g. the provision of sustainable energy systems will be encouraged.  Welsh Government emphasise that the Council must identify those employment sites considered suitable for waste management facilities.  Clwydian Range & Dee Valley AONB Joint Committee comment that neither the policy nor supporting text makes any reference to environmental constraints such as the AONB on such development, and the committee would recommend that this should be reflected in the policy.  Canal & Rivers Trust, suggest that the opportunity provided by canals for heating and cooling systems for developments adjacent to canals as well as generating hydro-electric power should be acknowledged as a renewable energy option.

Matters to be addressed by the Deposit Plan

4.89 Sites which are considered suitable for waste management facilities will be identified at the Deposit Plan stage.

(Q26) Renewable Energy Approach

Q. No. %Agreed %Not % Not Total no. Agreed Stated of

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Responses

26 88(21) 4(1) 8(2) 24

General Comments

4.90 The majority of respondents (88%) were supportive of the approach, with only (4%) disagreeing and (8%) did not specifying either way. While there was general consensus there were observations which aim to improve the policy or highlighting issues to be covered in the Deposit Plan.

4.91 Welsh Government are disappointed that the Council is yet to undertake a Renewable Energy Assessment, which has restricted the Council’s ability to consider the renewable and low carbon energy potential as part of the assessment of new development sites. In accordance with national policy, the Council should through the Deposit LDP maximise opportunities for district heating and generation schemes by co-locating new proposals and land allocations with existing development and heat supplies and users.

4.92 Concern from Cadw that the potential harmful impact of this type of development on heritage assets has not been recognised in the supporting text (while habitats, species and landscapes are recognised).

Comments Supporting the Approach to Renewable Energy

4.93 Natural Resources Wales are satisfied the Renewable Energy Assessment will provide evidence to underpin the approach in the LDP.

4.94 Energy and related developments, notably large scale wind and solar projects, can have significant landscape and other environmental impacts, and the AONB committee would suggest that in framing such policy and guidance, due weight is given to the need to conserve and enhance the nationally protected landscape of the AONB and its setting.

Comments Not Supporting the Approach to Renewable Energy

 There is concern from a house builder that a policy setting out the requirement for district heat networks to be incorporated into Key Strategic Sites would have viability and deliverability implications.

Matters to be addressed by the Deposit Plan

 Revisit the opening paragraph to explicitly recognise national obligations to the protection of heritage. The Renewable Energy Assessment evidence base document will be completed and used to inform policy direction and inform site selection (positively support technology and protect potential renewable resources). Viability implications of renewable energy policy requirements will be considered for the strategic sites and general deliverability of the plan.

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 Welsh Government has urged the Council to undertake a Renewable Energy Assessment. The Deposit Plan should maximise opportunities for district heating and generation schemes by co-locating new proposals and land allocations with existing development and heat supplies and users.

(Q27) Initial Sustainability Report

4.95 There was no specific support or opposition to the Sustainability Appraisal. However house builders did raise issues in relation to how the SA affects consideration of sites they are proposing. Key issues, concerns raised included the following:

 One respondent disagreed with the scoring of the growth options arguing that more growth does not mean a correlated adverse impact on environmental issues but that harm is directly related to the site selected and its proximity to Wrexham.

 Another respondent said the SA must be guarded against drawing conclusions linking market values with associated uplift in the delivery of infrastructure and other benefits unless it has concurrently given appropriate consideration to whether the development costs are equal or lower than development costs in areas of lower market value. On balance, however, they concede that the process for concluding that Option 1 should be supported as a KSS appears to be sufficiently robust.

 Given the extent of the strategic sites there is merit in assessing both parts of the site, as a split site for the purposes of the SA. This allows for the KSS to be split if this would accelerate delivery.

Matters to be addressed by the Deposit Plan

4.96 Viability implications on infrastructure delivery to be considered in more detail for the key strategic sites and wider plan deliverability. The sustainability implications of splitting the KSS’s to be considered in future iterations of the SA.

(Q28) Key Evidence Base

4.97 A number of comments were made about the evidence base, which have been noted. Specific comments included:

 Question why the Gypsy Traveller Accommodation Needs Assessment has only been done up until 2018.  Green Wedge Review – Comment regarding the extent of some of the indicative Green Wedges in the stage 1 review. Accept some areas need to be released from existing Green Wedge designation in order to accommodate development.

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 Wrexham Strategic Highways Road network Capacity and Improvement Study – Key stakeholders should be consulted in order to inform decisions regarding site allocations.  The Clwydian Range & Dee Valley AONB Joint Committee suggest that the AONB Management Plan should be listed in the evidence base.  North and North Wales Canal & Rivers Trust highlights that ‘The Destination Management Plan’ demonstrates the importance of the tourist sector to the economy and its priority to invest in Key hubs such as the World Heritage Site.  The Key Evidence reviews should have been completed before the LDP was put to consultation.

Matters to be addressed by the Deposit Plan

4.98 The revised Gypsy Traveller Accommodation Needs Assessment (2016) will inform the deposit LDP and will cover the period to 2028.

4.99 The comments relating to individual areas of indicative Green Wedge in the Green Wedge Strategic Review Stage 1 will need to be considered prior to designations being included in the deposit LDP.

4.100 The AONB Management Plan will be listed as part of the evidence base in the Natural and Built Environment.

(Q29) Background and Topic Papers

4.101 The key issues/ themes relating to the background and topic papers are identified below:

 Criticism that the consultation period was not long enough to allow interested parties to read the supporting documents.  BP1 Population and Household Projections – Questioning approach to housing supply.  BP2 Settlement Hierarchy - Settlements should not be considered in isolation when considering sustainability issues.  BP2 Settlement Hierarchy Development should be encouraged in tier 3 settlements to support sustainability in the areas surrounding those settlements.  BP2 Settlement Hierarchy Query regarding the justification for the placing of certain settlements within the hierarchy.  BP3 Key Strategic Sites – Question the level of development the KSS are capable of delivering.  BP4 Candidate Site Assessment - Approach is crude and simplistic  BP5 Wrexham Industrial Estate Site Expansion – Question the deliverability of a large scale expansion of WIE.  Topic Paper 2 – Question the level of new employment land required over the plan period.  Topic Paper 4 – Wrexham Town centre and Retail – Comment regarding the potential extension of town centre boundary.

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 Topic Paper 5 – A more up to date source of education capacity is required.  Topic Paper 6 – Natural Environment - Avoid adding undue weight and significance upon designations that might be preventing settlements from expanding.  Topic Paper 9 – Minerals - Need evidence of the merits or otherwise of deposits, this needs to be undertaken in a strategic way to inform allocations.  Tests of soundness – A number of comments regarding the extent to which the tests of soundness are being met.  Natural Resources Wales – Habitats Regulation Assessment (HRA) - The in-combination and cumulative impacts of committed developments do need to be considered under the scope of the HRA. NRW are in discussions about available capacity at the receiving sewerage treatment works as part of the on-going LDP process.  Natural Resources Wales – Sustainability Appraisal (SA) - Satisfied that the SA has successfully explored all options against the SA objectives, and will continue to work with Wrexham to establish specific mitigation measures identified in the SA.

Matters to be addressed by the Deposit Plan

4.102 The Background Papers will be updated in order to include new evidence, and in order to respond to representations where appropriate.

4.103 It is noted that in some instances additional work is needed to inform the evidence base e.g. education capacity and mineral resources.

4.104 Continue to consult with NRW and Dwr Cymru Welsh Water in order to understand capacity at the receiving sewerage treatment works as part of the on-going LDP process, and to establish specific mitigation measures identified in the SA.

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5.0 Site Register

5.1 The Council published the site register (SR) in tandem with the Preferred Strategy to afford residents and other stakeholders an opportunity to make comment on those sites of interest to them.

5.2 The SR identifies all the sites that have been submitted by interested parties for consideration (during the call for sites process between November 2012 and February 2013). It also includes sites identified within the Wrexham County Borough Urban Capacity Study (update 2015); and additional sites suggested by Officers identified as potentially suitable for development.

5.3 It was made clear in the SR that by listing a site on this register that it did not represent a commitment on the part of the Council to take sites forward for inclusion in the LDP. It included both Strategic and non-strategic sites, identifying those considered in accord with the Preferred Strategy.

5.4 Unsurprisingly the SR generated a large number of responses in relation to individual sites totalling 1387. Chief amongst these related to Wrexham 250, Overton 195, Penycae 170, Llay 136, Brymbo 120 and Rossett 113 with other notable numbers from Bangor 37, Gresford/Marford 58, Horseman’s Green 51, and Penley 32.

5.5 Around 1000 of these responses were made by the public, the remainder came from Community Councils, Agents and Developers, statutory and other consultees. A significant number of responses 1153 were opposing sites, with 153, neither supporting or objecting.

5.6 In terms of positive support there were 81 responses supporting sites, almost all were representing site owners.

5.7 In more detail:

 Wrexham; The majority of responses naturally relate to the sites which form the Key Strategic Sites, which between them generated 181 responses (167 opposing them);

 There were also a number of representations under Key Strategic Sites and Area of Search Policy SP9 summarised under question 17 (see Para 4.67 above)

 Overton; Responses in Overton were fairly evenly spread, bar 3 (O03CS, O04CS, O07OS) across the range of sites proposed in the locality and were overwhelmingly in opposition 189 out of a total of 195 comments made.

 Penycae; Responses were overwhelmingly in opposition - 164 out of a total of 170 comments made, with PEN04CS Chapel Field, receiving the most objections 28. There were also a number of petitions; one petition totalling 195 signatories against PEN04CS, one with 71

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signatories opposed to sites PEN04CS /PENY02OS (Adjacent Junior School) /PEN10CS Penycae Junior School /PEN02CS Land off Copperas Hill; and one of 14 against PEN04CS / PENY01OS (Stryt Issa) and Penycae in general and one with 50 signatories against PEN04CS and Penycae in general. It must be stressed that petitions are classed as one representation.

 Llay: Responses in Llay were fairly evenly spread across the range of candidate sites proposed in the locality and were overwhelmingly in opposition 129, petitions in opposition of sites were received totalling 249 signatories. The combined representations mainly opposed Haywards Field (LLAY003NUCS); Llay Road (LL01OS); adjacent Llay Hall farm (LL02OS) and (LL03OS); land west of Gresford Road (LLA04OS) and land south of straight mile (LL05OS).

 Rossett: While all candidate sites in Rossett received objections the bulk relate to RO01OS – Former Darland Golf Course (54) and RO02OS – South of Rosset Road (12). There was also a petition with 72 signatories opposed to a range of candidate sites in Rossett.

5.8 No comments were received from consultees about sites in the following settlements; Cross Lanes, , , , Sydallt, Tallarn Green, , or Worthenbury.

5.9 Finally, there were comments received from Archaeological Trust (122 neutral observations that can be resolved at planning application stage with 3 site objections); Community Councils opposing sites (Acton, Bangor, Caia, Chirk, Gwersyllt, Llay, Offa, Overton, Penycae, Sesswick) and neighbouring authorities Flintshire (no objections to the candidate sites).

5.10 The main reasons given by those objecting to sites in the register included the following;

 Adverse transportation impacts;  Adverse environmental impacts;  Adverse social impacts/negative implications on local communities and quality of life/strain on local facilities especially schools, health care and recreation provision;  Impact on local character and identity;  Land drainage and flooding (where applicable);  Development not meeting local needs and affordability;  Loss of good quality agricultural land (where applicable);  Others site should be used i.e. brownfield;  and adverse health impacts.

5.11 The number of representations received on individual sites contained within the Site Register is set out in Table 3 below. A total number for each settlement is also included.

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Settlement Site Neutral Object Support Total /Cefn Mawr A01OS 1 1 Acrefair/Cefn Mawr A02OS 1 1 Acrefair/Cefn Mawr A06CS 1 1 1 3 Acrefair/Cefn Mawr A07CS 1 1 Acrefair/Cefn Mawr A08CS 2 2 Acrefair/Cefn Mawr CEFN016NUCS 1 1 Acrefair/Cefn Mawr Total 6 2 1 9 Bangor BA01CS 3 3 Bangor BA01OS 1 1 Bangor BA02CS 16 16 Bangor BA03CS 2 2 Bangor BA04CS 1 14 15 Bangor Total 1 36 0 37 BET001UCS 1 1 2 Bettisfield BET002UCS 1 1 Bettisfield BET003UCS 1 1 Bettisfield BET006UCS 1 1 Bettisfield BET01CS 2 2 Bettisfield BET02CS 1 1 Bettisfield BET03CS 1 1 Bettisfield Bettisfield General 2 2 Bettisfield Total 1 10 0 11 BRN02CS 1 1 Bronington BRN03CS 2 2 Bronington BRN05CS 1 1 Bronington BRN06CS 1 1 Bronington BRN07CS 1 1 Bronington BRN08CS 1 1 Bronington BRN09CS 1 1 Bronington BRN10CS 1 1 Bronington Total 6 0 3 9 Broughton BRO05CS 2 2 Broughton BRO06CS 1 1 Broughton BRO08CS 1 1 Broughton BROU004UCS 1 1 Broughton BROU005UCS 1 1 Broughton BROU007UCS 1 1 Broughton Total 2 3 2 7 Brymbo BRY06CS 1 1 Brymbo BRY08CS 1 1 Brymbo BRY09CS 5 1 6 Brymbo BRY10CS 1 1 2 Brymbo BRY11CS 1 1

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Settlement Site Neutral Object Support Total Brymbo BRY12CS 1 1 Brymbo BRY15CS 1 1 2 Brymbo BRY16CS 1 1 2 Brymbo BRYM001UCS 1 1 Brymbo BRYM002UCS 1 1 Brymbo BRYM005UCS 1 16 17 Brymbo BRYM007UCS 15 15 Brymbo BRYM006UCS 1 16 17 Brymbo BRYM010UCS 1 16 17 Brymbo BRYM020UCS 1 16 17 Brymbo BRYM022UCS 15 15 Brymbo BRYM023UCS 1 1 Brymbo BRYM024NUCS 1 1 Brymbo Brymbo General 2 2 Brymbo Total 14 102 4 120 Burton BU01CS 1 5 6 Burton BU03CS 1 1 2 Burton BU05CS 3 3 Burton BU06CS 3 3 Burton BU07CS 3 3 Burton Burton General 1 1 Burton Total 2 16 0 18 BW01CS 1 1 Bwlchgwyn BW03CS 2 2 Bwlchgwyn BW04CS 1 1 Bwlchgwyn Total 1 3 0 4 Chirk CH01CS 1 1 2 Chirk CH02CS 1 1 Chirk CH02OS 1 1 Chirk CH03OS 1 1 Chirk CH04OS 1 1 Chirk CH05CS 1 1 2 Chirk CH06OS 1 1 Chirk CHIR003UCS 1 1 Chirk CHIR004UCS 1 1 Chirk CHIR008UCS 1 1 2 Chirk CHIR009UCS 1 1 Chirk CHIR012UCS 1 1 Chirk Total 6 7 2 15 Coedpoeth CO01CS 2 2 Coedpoeth CO01OS 1 2 1 4 Coedpoeth CO02CS 1 1 1 3 Coedpoeth CO03CS 1 1

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Settlement Site Neutral Object Support Total Coedpoeth CO03OS 1 1 2 Coedpoeth CO04CS 1 2 3 Coedpoeth CO05CS 1 1 1 3 Coedpoeth CO06CS 1 1 1 3 Coedpoeth CO07CS 1 2 3 Coedpoeth CO09CS 1 1 Coedpoeth Coedpoeth General 1 1 Coedpoeth Total 5 10 11 26 Dolywern/Llwynmawr D001CS 1 1 Dolywern/Llwynmawr DOL001NUCS 1 1 Dolywern/Llwynmawr Total 0 0 2 2 Garth GA02CS 1 1 Garth Total 1 1 GC01CS 1 1 Glyn Ceiriog GC02CS 3 1 4 Glyn Ceiriog GC03CS 4 1 5 Glyn Ceiriog GC04CS 14 1 15 Glyn Ceiriog GC06CS 1 1 2 Glyn Ceiriog GLYN001UCS 1 1 Glyn Ceiriog Total 1 23 4 28 Gresford/Marford GR01OS 20 20 Gresford/Marford GR02OS 2 2 Gresford/Marford GRE01CS 1 7 8 Gresford/Marford GRE02CS 2 1 3 Gresford/Marford GRE03CS 1 1 Gresford/Marford GRE04CS 1 1 Gresford/Marford GRE05CS 7 7 Gresford/Marford GRE08CS 2 2 Gresford/Marford GRE11CS 1 1 Gresford/Marford GRE12CS 1 1 Gresford/Marford GRE14CS 1 1 Gresford/Marford GRE15CS 8 1 9 Gresford/Marford GRES008UCS 1 1 Gresford/Marford GRES010NUCS 1 1 Gresford/Marford Total 3 50 5 58 Gwersyllt GWE01CS 1 1 Gwersyllt GWE01OS 1 1 Gwersyllt GWE02CS 1 1 Gwersyllt GWE02OS 1 1 Gwersyllt GWE03CS 2 1 2 5 Gwersyllt GWE04CS 1 1 Gwersyllt GWE05CS 1 1 Gwersyllt GWE06CS 1 1

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Settlement Site Neutral Object Support Total Gwersyllt GWE07CS 1 1 Gwersyllt GWE08CS 1 1 1 3 Gwersyllt GWE09CS 1 1 Gwersyllt GWER001UCS 1 1 Gwersyllt GWER002UCS 1 1 Gwersyllt GWER003UCS 1 1 Gwersyllt GWER004NUCS 1 1 Gwersyllt GWER005NUCS 1 1 Gwersyllt GWER006NUCS 1 1 Gwersyllt Gwersyllt General 1 1 Gwersyllt Total 10 10 4 24 Gwynfryn GWY02CS 1 1 2 Gwynfryn GWY03CS 1 1 2 Gwynfryn Total 1 2 1 4 Halton HAL01CS 1 1 Halton HALT001UCS 1 1 Halton Total 0 0 2 2 Hanmer HAN01CS 1 1 Hanmer HAN02CS 1 1 Hanmer HAN03CS 1 1 Hanmer HANM001UCS 1 1 Hanmer HANM002UCS 1 1 Hanmer Total 5 0 0 5 Holt HOL04CS 1 1 Holt HOL05CS 1 1 Holt HOL06CS 2 1 3 Holt HOL07CS 1 1 Holt HOL09CS 2 2 Holt Total 3 3 2 8 Horseman's Green HG01CS 1 5 5 Horseman's Green HG02CS 1 7 8 Horseman's Green HG03CS 1 6 6 Horseman's Green HG04CS 1 5 5 Horseman's Green HG05CS 5 4 Horseman's Green HORS001UCS 1 6 7 Horseman's Green HORS002UCS 8 8 Horseman's Green HORS003UCS 3 3 Horseman's Green Horseman's Green General 1 1 Horseman's Green Total 5 46 0 51 Llanarmon DC LDC01CS 1 1 Llanarmon DC LLAN001UCS 1 1 Llanarmon DC Total 2 0 0 2

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Settlement Site Neutral Object Support Total Llay LL01CS 2 2 Llay LL01OS 1 18 19 Llay LL02CS 4 4 Llay LL02OS 1 19 20 Llay LL03CS 3 3 Llay LL03OS 1 19 20 Llay LL04CS 1 2 3 Llay LL04OS 18 1 19 Llay LL05OS 16 1 17 Llay LL06OS 1 8 9 Llay LLAY001UCS 2 2 Llay LLAY002NUCS 2 2 Llay LLAY003 NUCS 12 12 Llay Llay General 4 4 Llay Total 5 129 2 136 MA01CS 1 1 Marchwiel MA01OS 1 1 Marchwiel MA06OS 1 1 Marchwiel MARC001UCS 1 1 Marchwiel Total 2 2 0 4 MIN01CS 1 1 Minera MIN01OS 1 1 Minera MIN02CS 1 1 Minera MIN03CS 1 1 2 Minera MIN04CS 1 1 Minera MIN05CS 1 1 Minera MIN06CS 1 1 Minera MIN07CS 1 1 2 Minera MINE002UCS 1 1 Minera Total 3 7 1 11 Overton O01CS 19 19 Overton O01OS 15 15 Overton O02CS 22 22 Overton O02OS 12 12 Overton O03CS 1 6 7 Overton O03OS 22 1 23 Overton O04CS 9 9 Overton O04OS 17 1 18 Overton O05OS 17 2 19 Overton O06OS 15 15 Overton O07OS 5 5 Overton O08OS 18 1 19 Overton Overton General 12 12

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Settlement Site Neutral Object Support Total Overton Total 1 189 5 195 Penley PENL001UCS 3 3 Penley PENL01CS 3 3 Penley PENL01OS 1 3 4 Penley PENL02CS 3 3 Penley PENL02OS 3 3 Penley PENL03CS 3 3 Penley PENL03OS 3 3 Penley PENL04CS 3 3 Penley PENL04OS 3 3 Penley PENL05CS 1 3 4 Penley Total 2 24 6 32 Penycae PEN01CS 12 12 Penycae PEN02CS 1 14 15 PEN02CS (Petition Penycae with 71 signatures) 1 1 Penycae PEN03CS 1 13 14 Penycae PEN04CS 24 24 PEN04CS (Petition Penycae with 14 signatures) 1 1 PEN04CS (Petition Penycae with 195 signatures) 1 1 PEN04CS (Petition Penycae with 50 signatures) 1 1 PEN04CS (Petition Penycae with 71 signatures) 1 1 Penycae PEN05CS 2 1 3 Penycae PEN06CS 16 16 Penycae PEN07CS 1 10 11 Penycae PEN08CS 15 15 Penycae PEN09CS 1 12 1 14 Penycae PEN10CS 5 5 PEN10CS (Petition Penycae with 71 signatures) 1 1 Penycae PEN11CS 9 9 Penycae PENY001UCS 1 1 Penycae PENY002UCS 2 2 Penycae PENY01OS 7 7 PENY01OS (Petition Penycae with 14 signatures) 1 1 Penycae PENY02OS 7 7 PENY02OS (Petition Penycae with 71 signatures) 1 1 Penycae PENYCAE General 5 5 Penycae PENYCAE General 1 1

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Settlement Site Neutral Object Support Total (Petition with 14 signatures) PENYCAE General (Petition with 50 Penycae signatures) 1 1 Penycae Total 4 164 2 170 PO01CS 1 1 2 Pontfadog PONT001UCS 2 2 Pontfadog Total 1 3 0 4 Rhos/Johnstown/ JOHN002UCS 1 1 Rhos/Johnstown/Ponciau JOHN014UCS 1 1 Rhos/Johnstown/Ponciau JOHN021UCS 1 1 Rhos/Johnstown/Ponciau JOHN024UCS 1 1 Rhos/Johnstown/Ponciau JOHN025UCS 1 1 Rhos/Johnstown/Ponciau JOHN029NUCS 1 1 Rhos/Johnstown/Ponciau RHO03CS 1 1 Rhos/Johnstown/Ponciau RHO08CS 1 1 Rhos/Johnstown/Ponciau RHO09CS 1 1 Rhos/Johnstown/Ponciau Total 9 0 0 9 Rhostyllen RT01CS 1 1 Rhostyllen RT03CS 1 1 2 Rhostyllen RHOS001UCS 1 1 2 Rhostyllen Total 2 2 1 5 Rossett RO01CS 3 3 Rossett RO01OS 54 1 56 Rossett RO02CS 2 2 Rossett RO02OS 1 11 12 Rossett RO04CS 2 2 Rossett RO05CS 1 2 3 Rossett RO06CS 1 4 5 Rossett RO08CS 1 1 1 3 Rossett RO09CS 1 1 1 3 Rossett RO10CS 3 3 Rossett RO11CS 4 4 Rossett Rossett General 2 16 18 Rossett Total 7 103 3 113 Ruabon RU01CS 1 1 Ruabon RU02CS 1 1 Ruabon RU03CS 1 1 Ruabon RU04CS 1 1 Ruabon RU06CS 1 1 Ruabon RU08CS 1 1 Ruabon RU09CS 1 1

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Settlement Site Neutral Object Support Total Ruabon RU10CS 1 1 2 Ruabon RU11CS 1 1 Ruabon Total 4 0 6 10 Southsea SOUT001UCS 1 1 Southsea SOUT006UCS 1 1 Southsea Total 2 0 0 2 Tanyfron TAN02OS 1 1 Tanyfron TAN03OS 1 1 Tanyfron Total 2 0 0 2 Trevor TREV001UCS 1 1 Trevor Total 1 0 0 1 Wrexham WR04CS 1 1 Wrexham WR06CS 1 1 2 Wrexham WR07CS 1 14 15 Wrexham WR08CS 1 5 6 Wrexham WR09CS 2 28 30 Wrexham WR10CS 2 27 29 Wrexham WR11CS 1 26 27 Wrexham WR12CS 1 1 Wrexham WR13CS 1 1 1 3 Wrexham WR14CS 4 4 Wrexham WR15CS 1 1 2 Wrexham WR16CS 6 6 Wrexham WR17CS 1 1 2 Wrexham WR18CS 2 1 3 Wrexham WR19CS 1 26 1 28 Wrexham WR20CS 3 37 2 42 Wrexham WR23CS 1 1 Wrexham WR24CS 1 1 Wrexham WR25CS 1 1 1 3 Wrexham WR26CS 1 1 2 Wrexham WR27CS 1 1 2 Wrexham WR28CS 1 3 4 Wrexham WXT001UCS 1 1 Wrexham WXT002UCS 1 1 Wrexham WXT003UCS 1 1 Wrexham WXT004UCS 1 1 Wrexham WXT005UCS 1 1 Wrexham WXT007UCS 2 2 Wrexham WXT009UCS 1 1 Wrexham WXT010UCS 1 1 Wrexham WXT011UCS 1 1 Wrexham WXT012UCS 1 1

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Settlement Site Neutral Object Support Total Wrexham WXT013UCS 1 1 Wrexham WXT014UCS 1 1 Wrexham WXT015UCS 1 2 3 Wrexham WXT016UCS 1 1 Wrexham WXT017UCS 1 1 Wrexham WXT018UCS 1 1 Wrexham WXT019UCS 1 1 2 Wrexham WXT020UCS 1 1 Wrexham WXT022UCS 1 1 Wrexham WXT024UCS 1 1 Wrexham WXT072NUCS 1 1 Wrexham WXT077NUCS 1 1 Wrexham WXT078NUCS 1 1 Wrexham WXT079NUCS 1 1 Wrexham WXT080NUCS 1 1 Wrexham WXT083NUCS 2 2 Wrexham WXT084NUCS 2 2 Wrexham WXT085NUCS 1 1 Wrexham WXT088NUCS 1 1 Wrexham WXT090NUCS 1 1 Wrexham Total 33 206 11 250 Wrexham Industrial Estate WIE02CS 1 1 2 Wrexham Industrial Estate Total 1 0 1 2 Grand Total 153 1152 81 1152 Table 3 – Breakdown of Site Representations

Matters to be addressed by the Deposit Plan

5.12 These representations received during the site register consultation will be considered and taken into account as part of the non-strategic site selection process for the Deposit Plan. Whilst the Council may consider that representations have been taken into account, representors may disagree.

5.13 It is important to note however that whilst local views must be considered, the duty is to decide each site on its planning merits. As a general principle, local opposition or support for a proposal is not, on its own, a reasonable ground for rejecting a site; objections, or support must be based on valid planning reasons.

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6.0 Alternative Site Submissions – Proposed as a result of the Preferred Strategy Consultation

6.1 The Town and Country Planning (Local Development Plan) (Wales) (Amendment) Regulations 2015 came into force on 28th August 2015 which removed the alternative sites submission stage from the Local Development Plan process. Subsequently, Alternative Candidate Sites can now be submitted during the Preferred Strategy consultation period.

6.2 A total of 68 Alternative Candidate Sites were proposed through representations to the Preferred Strategy, these are located across the County Borough mainly for housing development but some are for employment, retail and mixed use.

6.3 An assessment of their suitability for development and their compatibility with the Preferred Strategy has been carried out by Planning Officers in line with the Council’s Background Paper 4: Candidate Site Assessments (February 2016). The outcome of these sites is reported in the updated Site Register KPD07a.

7.0 Unduly made Representations

7.1 In total, 15 representors submitted representations that were not duly made as they were submitted outside of the statutory consultation period.

8.0 Conclusion

8.1 The public consultation generated a wide range of opinions and it was unsurprising that not all of these opinions were compatible with each other. These comments have been given consideration when determining the content of the LDP.

8.2 In order to ensure a sound plan going forward the main key issues that can be drawn from the public consultation are;

 The Deposit LDP should clearly set out the components of the housing supply and demonstrate that they are viable and deliverable over the plan period.  A framework for the delivery of the Key Strategic Sites  Consideration of Wrexham’s role in the wider sub region.  The approach to employment across the whole of the County Borough.  Ongoing engagement with key infrastructure delivery partners will continue throughout the LDP process.

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 Representations received during the site register consultation will be considered and taken into account as part of the non-strategic site selection process for the Deposit Plan.

8.3 In accordance with the LDP regulations, there is a statutory requirement for all representations received as part of the consultation process to be made publically available, in full. These are all available on the WCBC consultation portal www.wrexham.gov.uk/ldp.

8.4 Item 16 of Appendix D in the Initial Consultation Report KPD12, summarises how the LDP has addressed the key issues raised and KPD14 Preferred Strategy Consultation Comments and Officer Responses (Jan 2018) summarises all of the comments received on the Preferred Strategy along with WCBC Officer responses to these.

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