INSP017R 02/09/19 Local Development Plan Examination in Public - Council’s response to document INSP017

Introduction and Background

On 18th September 2019 the Council received a note from the Inspectors (INSP017) which contained the Inspectors’ initial reflections on the first week of the hearing sessions and their implications for the Plan. This statement has been prepared to address the concerns raised in that note.

For the avoidance of doubt, the reference in INSP017 to the revised objectives not having been agreed by the delegated Members group is incorrect. This action point, together with others that arose from Matters 1-4, have been agreed with the Members group, subject to consultation in due course as part of the Matters Arising Changes (MACs) where appropriate, unless they relate to the action points from Matter 3 which are included in the Council’s response M3.01R.

The other bullet points in INSP017 have been numbered and the rest of this paper addresses each one in turn.

1. Large proportion of windfall sites in the housing requirement

1.1 This has been addressed at Paragraphs 4.1 - 4.11 and Table 3 in the Council’s response to Matter 3 (M3.01R)

1.2 The key points in relation to windfall within the housing requirement are as follows:

a) Table 3 of M3.01R identifies that the windfall allowance (small and large sites) for the remaining Plan period makes up 18% of the housing requirement. By comparison, allocations make up 40%, sites with Planning permission (both Section 106 and committed deliverable large sites) 24% and completed sites (2013 - 2019) 19%. This shows that the windfall allowance does not make up the largest proportion of the housing requirement or a disproportionate one; the allocations make up a considerably larger proportion as would be expected.

b) Over the last 17 years windfall sites delivered an average of 285 units per annum. The allowance in the Plan (195 units per annum) has already been discounted by 32% in recognition of the fact that such sites, due to their nature, are largely unknown and that there is a diminishing supply of brownfield land in the County Borough (WCBC Urban Capacity Study, 2007 EBH01). The windfall allowance for large sites has been discounted by 25%, which is consistent with the approach outlined in Table 18 of Development Plans Manual, consultation draft, June 2019 (DPM31).

1.3 The Council does not believe that there is an overreliance on windfall sites within the housing supply. The position identified in the Plan is based on evidence and is conservative and realistic given the remaining Plan period. Further evidence in

1 OPEGD003 Draft Development Plans Manual (Edition 3 ) June 2019 https://wrexham- consult.objective.co.uk/portal/ldp_ebsd 1

INSP017R 02/09/19 relation to windfall sites is included in Section 3, below, in relation to settlement limits boundaries.

2. Tightly drawn settlement limit boundaries

2.1 Precisely defined settlement boundaries are an effective policy tool used to direct development to the most appropriate locations. Development within settlement limits is more appropriate than outside in the open countryside. Settlement limits therefore play an important role in promoting sustainable development, protecting open countryside and encouraging the reuse of land within urban areas, particularly brownfield sites.

2.2 Paragraph 5.20 of DPM3 states that ‘The settlement boundary must be appropriately drawn; taking into account the aims of the overall strategy and the amount and type of development that is attributed to each tier of the settlement hierarchy.’ Paragraph 5.21 of the same document further states that ‘Tightly drawn boundaries will not allow for infill or rounding off of windfall opportunities within settlements...’. The Council believe that the settlement limits have been adjusted accordingly in the Plan making process to allow for appropriate allocations and for windfall opportunities to come forward in accordance with the spatial strategy.

2.3 The Council has undertaken a review of settlement boundaries set out in the Wrexham Unitary Development Plan (UDP) 1996 - 2011 as evidenced in Background Paper (BP) 09: Settlement Boundary Review (January 2018 (BP092). Where appropriate, it has amended the boundaries to allow for the allocations identified in the Plan in accordance with the Plan’s Spatial Strategy, as shown on the Proposals Maps. In addition, settlement boundaries have been amended to allow for additional windfall sites to come forward over the Plan period, as also evidenced in BP09.

2.4 The changes to the boundaries have been grouped according to the following circumstances (see Appendix 1 of BP09 and the maps of the changes in Appendix 2 of BP09): 1. Minor amendments/corrections: to follow a defined feature on the ground 2. Planning Permission: where extant permissions exist on land adjoining the settlement limit 3. Development sites: to reflect the allocations in the Plan and to ‘include previously unidentified sites suitable for development of 10 or less dwellings’ (Page 6, Appendix 1, BP09) 4. Employment areas: those previously shown within settlement limits are shown separately as areas of protected employment land under Policy EM1 5. Schools; where schools are located on the edge of settlement limits, the school building and hardstanding are included within and the playing fields located outside settlement limits.

2.5 BP09 provides background to evidence the ‘known’ windfall sites as a result of changes to the settlement boundaries through the review, to help justify the figures

2 BP09 Settlement Boundary Review January 2018 https://wrexham-consult.objective.co.uk/portal/ldp_ebsd 2

INSP017R 02/09/19 identified in the Plan. Other sources of evidence include the site register (KPD07). These sources relate largely to the justification for the small sites (fewer than 10 dwellings) windfall contribution (75 units per annum) as any known large sites that are deliverable have been allocated in the Plan in accordance with the site assessment methodology set out in Background Paper 04: Site Assessment Methodology (BP043).

2.6 The ‘known’ windfall sites are identified in Tables 1, 2 and 3 below. The majority are urban capacity sites (UCS), some are candidate sites (CS) and some are officer sites (OS). They total a potential of 284 units which are accounted for in the assumptions in relation to the windfall allowance in the Plan. As can be seen, 8% of the known windfalls are in Tier 1 (24 units), 65% in Tier 2 (184 units), 12% in Tier 3 (34 units) and 15% in Tier 4 (42 units). This spread is reflective of the allocations for housing in the Plan, which for the purposes of comparison are detailed in Table 4 below.

2.7 The majority of the sites are small sites as can be seen from Table 1, but there are some large sites which have not been allocated as the Council is not confident that they will be delivered over the Plan period. However, these have the potential to contribute to the housing provision over the Plan period as windfall sites. Specifically in relation to these large sites: WXT074NUCS: Powell Road, Wrexham: This is an UCS identified since the initial study in 2007 (EBH01). It is pending the signing of a Section 106 agreement for 14 units and will be monitored through the housing land availability process. The property currently on the site is let to students, so the site is not readily available and deliverable for the Council to allocate with enough certainty that it will come forward over the Plan period. CHIR007UCS: B5070 Land South of Grogen, : This is an UCS that is currently occupied, but that has the potential to come forward during the Plan period. Communication with the landowner was unsuccessful so the Council cannot be certain that it could be delivered over the Plan period. GWE02CS: Livery Stables, Little Mountain, Summerhill: This is a CS submitted during the call for sites in 2012 and has been assessed in accordance with the site assessment methodology identified in BP04. It is a brownfield site adjoining the existing settlement of and is in employment use. Permission has been granted, but not implemented, for 14 units and has lapsed. The Highway Authority supports a development of up to 24 units subject to improvements to the visibility splays, road widening and construction of footways on Moss Road and Summerhill Road. Other constraints (contaminated land, education capacity and minerals resource) would need to be addressed along with other general development management considerations (set out in Policy DM1). Communication about the delivery of the site was not forthcoming for the Council to be confident that it could be delivered over the Plan period, in particular in light of the lapsed permission. Should it become available over the Plan period it could contribute to the windfall allowance in the Plan.

3 https://wrexham-consult.objective.co.uk/portal/ldp_ebsd 3

INSP017R 02/09/19 BRO08CS: Pats Coaches Depot, Sothsea Road, New Broughton: This is a CS submitted during the call for sites in 2012 and has been assessed in accordance with the site assessment methodology in BP04. The site is partly greenfield and partly brownfield with the brownfield part being within the settlement limit. The greenfield part is a county wildlife site with significant mature tree coverage and without access other than through the brownfield part of the site. The brownfield part is used as a bus depot and whilst in principle development could take place on there this would be subject to overcoming a number of constraints in relation to highways and access, contaminated land, education capacity, known incidents of public sewerage flooding in the vicinity and satisfying other general development management considerations. Given that the site is not currently available, the Council was not willing to allocate it where it is not possible to evidence its deliverability. Should it become available over the Plan period the brownfield part of the site would contribute to the windfall allowance in the Plan. MA05OS: Adjacent to Cottage, Marchwiel: This is a OS and was assessed during the call for sites process in 2012. It was included in the LDP1 portfolio of sites that were reassessed as part of the current Plan. The site has also been assessed in accordance with the methodology set out in BP04. The Council is aware of discussions on the development on the site, but cannot fully evidence its delivery over the Plan period. This site is included within the settlement limit as a Focussed Change (FC36) and is included on Page 42 and 43 of KPD21. JOHN001UCS: South of Culfan, Johnstown: This is a UCS that has been assessed in accordance with the site assessment methodology in BP04. An outline application for residential development has since expired on the site and no further applications have been submitted. The Council cannot fully evidence its delivery over the Plan period with enough certainty, but given its brownfield nature within the settlement limit and the Planning history it could contribute to the windfall allowance in the Plan. JOHN014UCS: Aberderfyn Works, Aberderfyn, Rhos: This is a UCS with an existing use. It is constrained, in particular in relation to great Crested Newts, archaeology and contamination, but provided these issues could be mitigated there is potential for the site to be developed. Communication with the landowner has identified that there is currently no intention to develop the site so the Council cannot be certain that it could be delivered over the Plan period. JOHN029UCS: High Street, Johnstown: This is a UCS that has previously had Planning permission that has lapsed. The owner has indicated that they wish to develop the site within the next 10 years, but has no firm intentions. On this basis the Council cannot demonstrate that an allocation would be deliverable over the Plan period but there is potential for a windfall.

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INSP017R 02/09/19 Table 1: Known sources of windfall supply (source BP09 (January 2018) and site register (KPD07).

Site Ref Tier No. units WXT074NUCS 1 14 WXT012UCS 1 2 WXT070NUCS 1 8 CEFN005UCS 2 3 CEFN009UCS 2 5 CEFN013NUCS 2 4 CHIR004UCS 2 6 CHIR007UCS 2 30 CHIR013UCS 2 3 CH01CS 2 6 GRES006UCS 2 4 GRES008UCS 2 2 GWE02CS 2 24 GWE09CS 2 4 JOHN001UCS 2 10 JOHN014UCS 2 28 JOHN016UCS 2 4 JOHN029NUCS 2 16 JOHN003UCS 2 6 JOHN006UCS 2 3 JOHN007UCS 2 9 JOHN009UCS 2 4 JOHN015UCS 2 3 JOHN023UCS 2 2 JOHN026NUCS 2 8 BROU002UCS 3 3 BRO08CS 3 20 BRYM001UCS 3 5 GLYN004UCS 3 4 RHOS004UCS 3 2 BW02CS 4 7 BWLC001UCS 4 1 BWLC002UCS 4 2 HANM003UCS 4 3 HANM03CS 4 1 SOUT001UCS 4 4 TREV002UCS 4 3 TREV003UCS 4 5 MA05OS 4 12 MA01CS 4 4 Total 284

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INSP017R 02/09/19 Table 2: Summary by settlement of known windfalls from the Site Assessment Process (source Appendix A, BP08b)

Settlement Tier Large Small Total Wrexham 1 14 10 24 / Mawr 12 12 Chirk 30 15 45 Gresford/ 6 6 2 Gwersyllt 24 4 28 0 0 Rhos/Johnstown 54 39 93 Broughton 20 3 23 5 5 3 4 4 0 0 2 2 10 10 Hanmer 4 4 Marchwiel 4 12 4 16 Southsea 4 4 Trevor 8 8 Total 154 130 284

Table 3 Summary by Tier of known Windfalls from Site Assessment Process

Tier Large Small Total 1 14 10 24 2 108 76 184 3 20 14 34 4 12 30 42 Total 154 130 284

2.8 The settlement limits have been drawn too tightly. A settlement boundary review has been undertaken (BP09) and this, along with the site register (KPD07) and site assessment process (BP04) have allowed the Council to evidence the ‘known’ sources of windfall supply that could come forward over the Plan period, both in relation to small and large sites as a result of changes to the settlement limits in Tiers 1-3. This approach is in accordance with Paragraphs 5.20 and 5.21 of DPM3. In addition, minor changes to the settlement limits in Tier 4 will allow some small-scale infill schemes to come forward and the settlement boundary in Tier 5 is deliberately drawn tightly to ensure, in line with the spatial strategy, that their contribution to housing provision is limited.

2.9 In addition, this assessment of known windfall sites further evidences the appropriateness of the windfall allowance in the housing provision, as discussed in Section 1 above.

3. Lack of allocations in the higher tier settlements and in proximity to all employment centres

3.1 Policy SP2 sets out the location of development. The table included in Paragraph 5.27 of the Plan demonstrates the relationship between the housing allocations (and 6

INSP017R 02/09/19 other components of housing supply: windfall and sites with Planning permission) and employment provision in a way that reflects the Plan’s Spatial Strategy. As stated in the Matters 5 and 9 hearing sessions in relation to the economy, the Council is seeking to achieve a balance between the supply of housing and jobs/economy within the County Borough. This accords with national planning policy (paragraph 3.38, Planning Policy Edition 10(PPW10)) and is reflective of the economic aspiration set out in national and regional policies and strategies whilst also being realistic about the prospect of delivering housing over the Plan period. Furthermore, ensuring a balance between the provision of homes and jobs is referenced in paragraph 5.25 of DPM3 which states that ‘whilst there is not always a direct correlation between jobs and homes, they need to be considered collectively when assessing growth levels and a sustainable strategy; the aim being to achieve a balance between homes and jobs thereby reducing the need for commuting’.

3.2 Table 4, below, shows the housing allocations and the employment provision associated with each tier of the settlement hierarchy. It shows that there is not a lack of allocations in the higher tier settlements and neither is there is a lack of housing allocations in proximity to employment areas.

3.3 As stated in the Matters 5 and 9 sessions, the Plan makes one employment allocation on Wrexham Industrial Estate (WIE) (Key Strategic Site 3 (KSS3) of 28ha) and protects the remaining employment areas (Policy EM1) in the County Borough, in particular where there are planned housing allocations (Policy H1).

3.4 The employment provision for Tier 1 comprises 28ha of allocated land at KSS3 and the remainder (51ha) is protected under Policy EM1 (as updated by the Wrexham Employment Land Availability and Monitoring, April 2019 (MRE064). The total employment provision in Tier 1 is 79ha, as is shown in Table 4 below. Table 4:Housing and Employment by Settlement Tier

Settlement Housing Units (allocated Employment (ha) (protected under policy Tier under policy H1) and (%) EM1 and allocated under policy KSS3) and (%) 1 2180 (65%) 79 (86%) 2 748 (22%) 4 (5%) 3 359(11%) 8 (9%) 4 79 (2%) 0.31(0.34%) 5 0 0 Other 0 0 TOTAL 3366 units 92ha

3.5 65% of the housing allocations in the Plan are directed to Tier 1(including KSS1, KSS2 and a number of smaller, non-strategic, allocations identified in Policy H1). This is appropriate given the key role of Wrexham Town in the County Borough and region. Wrexham is a nationally important settlement in the Wales Spatial Plan and the primary town in the County Borough with provision for retail, service, employment and transport.

4 https://wrexham-consult.objective.co.uk/portal/ldp_ebsd 7

INSP017R 02/09/19 3.6 Similarly, the employment focus in the Plan is on WIE via KSS3. 86% of the employment provision is in Tier 1 and whilst the proportion of employment land provision seems considerably higher than the housing allocations, this can be explained by the fact that there are a number of other employment sites in and around Wrexham Town (protected by Policy EM1) which, when taken with the allocation at WIE, skew the overall employment provision in Tier 1.

3.7 When the allocation of land on the WIE alone is considered (KSS3, 28ha) this is 35% of the employment provision in Tier 1 (79ha).

3.8 The above demonstrates that the greatest proportion of housing and employment allocations are directed to Tier 1 and that the Plan has taken a pragmatic view of the need to balance housing and employment land in accessible locations to ensure sustainable and deliverable growth. The proximity and accessibility of KSS2 to the WIE/KSS3 ensures that housing and jobs are closely aligned. KSS2 is within 2km of WIE with a direct cycle path already linking the sites. KSS1 is directly opposite the remaining employment land on the ‘western gateway’ (a protected employment site in Policy EM1), while Wrexham hospital, Wrexham Technology Park and Wrexham Town Centre are all within a 2km walk of the site.

3.9 The provision of housing allocations in Tier 2 is 22%, with 5% of the employment provision (there are no employment allocations here, but sites protected for employment use under policy EM1). Although in this instance the housing allocations are much higher, there are 4 settlements (, Gresford, Rhos and ) in this tier where allocations are not proposed, as discussed further in paragraphs 3.12 and 3.13 below. The lower proportion of employment provision in Tier 2 compared to housing is reflective of the lower amount of remaining employment land within settlements in this tier. Expanding the employment offer within these settlements is not a realistic option since the only demand for employment land is on the WIE as evidenced in the ELR (EBE01). Furthermore, there is limited potential for expansion of these employment areas as set out in the Employment Area Assessments contained in Appendix 10 of the ELR. The new employment opportunities identified on WIE and other protected employment areas in Tier 1 are accessible from Tier 2 settlements by a range of means of transport.

3.10 For Tier 3 settlements, there is less of a difference between housing allocations and employment opportunities, but this is dependent upon the retention of 8ha of employment land in Brymbo, which is currently being objected to through the Examination process. Similar to some settlements in Tier 2, there are settlements in Tier 3 where housing allocations are not proposed (Bangor, Penycae and Rhostyllen) and this is discussed further in paragraphs 3.12 - 3.13 below.

3.11 For those settlements in Tiers 2 and 3 where no allocations are proposed, it is not to say that they will have no development over the Plan period. Looking at other sources of supply (commitments and completions) it is evident that these settlements will receive some development. Table 5, below, demonstrates this point. In addition, the known windfalls for each settlement and tier are identified in Tables 1, 2 and 3

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INSP017R 02/09/19 and Paragraph 2.6 and 2.7, above, also provide further analysis of the windfall distribution within each tier.

3.12 No site allocations are being promoted in Coedpoeth, Gresford, Rhos and Ruabon in Tier 2 and Bangor, Penycae and Rhostyllen in Tier 3 due to the lack of constraint- free, deliverable sites. This is evidenced in BP10 and in the Site Register KPD07.

3.13 The Site Register (KPD07) contains a summary of the candidate site assessment detailing why sites have been rejected, but the summary does not distinguish between the constraints which are fundamental (unsafe access, flood risk etc.) and those that would be considered in the round as part of the Planning balance (green wedge, best and most versatile land, etc). This has led to some confusion as to why sites have been rejected and why some settlements don’t have allocations. To resolve this, the Council has returned in this document to the site assessment work undertaken during preparation of the Plan to extract the key reasons behind a site’s rejection. The full assessment of sites, stakeholder consultation responses, constraint identification, site analysis and officer summary is contained in the Council’s internal database, but for each settlement that doesn’t have allocations, the reason why sites have been rejected is contained in Appendices 1 and 2 of this document. Appendix 2 also contains a schedule of sites submitted during the preparation of the Plan and categorises them according to the criteria in Table 6, below. To provide greater clarity for the Examination, additional information and the fundamental reason for rejection is also included. Table 5: Housing allocations, commitments and completions for the settlements in Tiers 1-3 of the Plan

Settlement Allocations Commitment - Commitment - Completions Total Large Sites Small Sites Tier 1 Wrexham 2180 50 126 694 3050 Tier 2 Acrefair/Cefn 51 262 36 69 418 Chirk 180 24 15 15 234 Coedpoeth 15 17 32 Gresford 37 7 51 95 Gwersyllt 104 66 16 66 252 Llay 413 18 13 10 454 Rhos 48 44 70 162 Ruabon 372 12 40 414 Tier 2 Total 748 827 158 338 2061 Tier 3 Bangor 2 3 5 Broughton 137 8 19 172 336 Brymbo 87 25 87 199 Glyn Ceiriog 3 1 4 Holt 35 24 17 18 94 Overton 40 7 15 62 Penley 15 29 39 83 Penycae 7 17 24 Rhostyllen 223 5 20 248

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INSP017R 02/09/19 132 10 11 26 179 Tier 3 Total 359 352 125 398 1224 Overall total 6335

Table 6: Categorisation criterion for sites in Appendix 2

Category Criteria Not Available Built out Has Planning permission Duplicate site Proposed alternative uses to residential Fundamental constraints that Sites in the open countryside unrelated to any cannot be mitigated settlement in the settlement hierarchy Flood risk C1 C2 Highway safety and access Significant impact on natural and built conservation (trees, ecology, built environment etc.) Incompatible land use - adjoining employment uses Windfall Potential Small site within settlement limit Small site within settlement limit, but constrained - an applicant would need to demonstrate constraints can be overcome Allocated Allocated in the Plan Deliverability Viability Infrastructure constrains delivery Ownership and legal issues Existing use prevents development Other More sustainable options (e.g. brownfield precedence over greenfield, access to services, loss of BMVL) Illogical settlement extension (e.g. ribbon development, poorly related to settlement, lack of defensible boundaries)

3.14 To conclude, there is not a lack, or skewed distribution, of housing allocations in the higher tiers of the settlement hierarchy or a lack of housing allocations in proximity to employment opportunities. The relationship between housing and employment/jobs has been considered throughout the development of the Plan and the Plan makes a clear link between the housing and employment allocations, in particular in Tier 1, reflective of the aspiration for Wrexham Town and WIE in the WSP and emerging NDF. The relationship between housing and employment in lower tiers is also evidenced; Tier 2 has fewer housing allocations than Tier 3, but Tier 2 has more housing commitments and windfall potential than Tier 3. The Council have also evidenced why some settlements in Tiers 2 and 3 do not have any housing allocations, which is down to the lack of available and deliverable sites in the settlements, as identified in Paragraph 3.13 above and Appendix 1 and 2.

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INSP017R 02/09/19 4. Reduction in housing numbers between Preferred Strategy and Deposit Plan

4.1 The Preferred Strategy (February 2016) does not form part of the required submission documentation under Regulation 22 of the Town and Country Planning (Local Development Plan) (Wales) Regulations, 2005, as amended.

4.2 The Preferred Strategy report of findings (KPD13), officer responses to the representations (KPD14) and the initial consultation report (KPD12) have been submitted (as required by the regulations) and set out the changes to the Plan as a result of pre-deposit consultation and changes in key pieces of evidence (including population and household projections and changes to national planning policy and guidance).

4.3 The Preferred Strategy was consulted on in February 2016. Table 7, below, was included in that document, with Option B (11,715 new homes to deliver a requirement of 10,650, 7550 new jobs and 53ha of employment land) being the Council’s preferred level of growth based on the relevant evidence at the time. The justification and reasoning for the preferred option, again based on the evidence, is contained in Background Paper 01a Population and Household Projections with Dwelling and Employment Impacts (February 2016) (BP01a5)

4.4 As is explained in Section 5 of BP01a, the chosen option for the Preferred Strategy (Option B) was a migration-led projection and was reflective of the concerns of stakeholders during the issues and options consultation (March 2015) about the scale and delivery of the employment-led projection (Option A) and the need to remain ambitious in economic terms – something which stakeholders did not feel was achievable with the 2011-based 5 year projection (Option C).

4.5 The preferred option looked at migration rates into the County Borough, the working age profile of the population and the contextual evidence in the Wales Spatial Plan and other regional plans and strategies (see paragraphs 3.42 – 3.46 of the Plan) in order to derive a housing requirement which sought to achieve the right balance between economic ambition and the realistic delivery of housing. Past build rates for housing, the take up of employment land, the availability of sites (KPD07 and BP04) and the settlement hierarchy were factored into the consideration in shaping the preferred spatial strategy that is set out in the Plan.

4.6 The Preferred Strategy was developed in the context of DPM2 and PPW9 and was consulted upon in February 2016 in accordance with statutory requirements. Since then, the publication of PPW10 and DPM3 has reiterated the emphasis on the realistic delivery of allocations identified in the Plan.

4.7 Paragraph 4.2 above identifies the documents which explain the results of the pre- deposit consultation which have, along with other significant changes in evidence since the publication of the Preferred Strategy, informed the revised figures in the Plan. This is discussed further in Section 6 below.

5 Background Paper 01a: Population and Household Projections with Dwelling and Employment Impacts (February 2016) https://wrexham-consult.objective.co.uk/portal/ldp_ebsd 11

INSP017R 02/09/19

Table 7 Growth options identified in the LDP Preferred Strategy (source: Table 1, Wrexham Local Development Plan Preferred Strategy, February 2016, page 23)

Option Level of housing and Evidence for option employment growth A About 13,010 new homes (870 Employment Land Review (2014) Employment dwellings a year) figure adjusted for Plan Period - led Approximately 8700 jobs and Projection 61ha of employment land B: About 11,715 new homes (781 Background Paper 01a: Population Migration- dwellings a year) and Household Projections with led Approximately 7550 jobs and Dwelling and Employment Impacts Projection 53ha of employment land (February 2016).6 C About 11,030 new homes (740 2011 based WG 5 year migration Migration- dwellings a year) (principal) household projection7 led Approximately 6900 jobs and Projection 48ha of employment land D About 10,100 new homes (670 2011 based WG household (10 year Migration- dwellings a year) migration) projection8 led Approximately 6050 jobs and Projection 42ha of employment land

5. Reasons for the reduction in housing numbers

5.1 Following consultation on the Preferred Strategy and upon assessing the representations received, it was apparent that there was concern from a number of stakeholders about the high level of growth that was being promoted (see documents identified in Paragraph 4.2 above), the ability of the development industry to deliver the identified housing requirement and the impact on the environment and infrastructure within the County Borough. Furthermore, the publication of the 2014- based population and household projections in September 2016 and March 2017 respectively represented a significant change in evidence which the Council needed to assess prior to the publication of the Deposit Plan. Had the Council proceeded without considering the most up to date evidence, there would have been justifiably significant questions raised about the soundness of the Plan.

5.2 This change in evidence, coupled with the concerns raised at the Preferred Strategy consultation resulted in the Council reassessing the appropriateness of the figures in the Preferred Strategy, in particular in light of the emphasis in national policy and guidance on the viability and deliverability of housing in the Plan; something which was raised by the Welsh Government (WG) in their response to the preferred strategy (see Appendix 3 of this report). The approach taken by the Council to reassess the most up to date evidence is in line with the relevant national policy requirements in PPW10, in particular Paragraph 4.2.6 which states “the latest Welsh Government projections will form a fundamental part of the evidence base for

6 Background Paper 1: Population and Household Projections with Dwelling and Employment Impacts (February 2016) – https://wrexham-consult.objective.co.uk/portal/ldp_ebsd 7 http://wales.gov.uk/docs/statistics/2014/140227-household-projections-2011-based-en.pdf 8 http://wales.gov.uk/docs/statistics/2014/140227-household-projections-2011-based-en.pdf 12

INSP017R 02/09/19 development plans”. Section 2 of BP01b (January 2018) sets out in further detail the chronology of the changes in housing numbers from Plan conception to deposit.

5.3 The 2014-based projections identified a significant reduction in the population in the County Borough compared to previous iterations. Table 2.1 of BP01b shows a reduction of 27% (10 year migration trend) and 42% (5 year migration trend) compared to the Preferred Strategy figures.

5.4 Looking at past build rates (Paragraph 3.22 of BP01), it is clear that the 781 dwellings per year required under Option B would be very difficult to deliver. The Council has only ever seen one year in the past 15 where the build rates have been significantly above this level (2007/08 when 945 were completed as a result of a number of apartments on the Brymbo steelworks site). Indeed, the remaining Plan period annual requirement of 516 per annum remains ambitions given the past 13 year average build rates of 420 per annum. However, although this is an increase over past trends, the Council is confident that the 516 per annum is deliverable given that the Plan includes a range and choice of sites in terms of scale and location. Additionally, all of the housing allocation sites either have developers lined up or developer interest to deliver over the Plan period, something which has been key in informing the trajectory contained in Appendix 5 of the Council’s response to matter 3 (M3.01R).

5.5 The Council is also aware that the 2017 base population and household projections are due to be released during autumn 2019. Estimations of the projections indicate a significantly lower housing requirement than that set out in the Plan. However, consideration of these new figures would be a significant change for the Plan which would be at odds with the economic aspirations in the Plan.

5.6 To conclude, the reduction in housing numbers between the Preferred Strategy and the Deposit Plan is fully justified having regard to the significant change in evidence presented by the release of the 2014 base population and household projections compared to the 2011 figures. Additionally, the continued emphasis on the delivery of allocations in the Plan, as set out in national policy, the assessment of past completion data and feedback from the Preferred Strategy consultation were also weighed in the Planning balance in reducing the housing requirement.

5.7 Despite the reduction, the annual remaining requirement of 516 dwellings per annum is ambitious in the context of past completion rates and the Plan’s economic aspirations.

6. The potentially unrealistic delivery forecasts for allocated sites

6.1 The site allocations and the accompanying trajectory can be found in Appendix 5 of the Council’s response to Matter 3 (M3.01R). The trajectory is based on extensive discussions with the promoters of the allocated sites, as detailed in the Statements of Common Ground (SoCG) contained in Appendix D of BP08B and in Paragraph 5.3 of the Councils response to matter 3 (M3.01R)

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INSP017R 02/09/19 6.2 The Council can only provide information in the trajectory that has been obtained from those with an active interest in the site allocations given that it is they and not the Council who will deliver the units on site. The Council is confident that the rates of delivery identified in the trajectory, based on extensive discussions with the relevant parties, can be achieved.

7. CONCLUSION

This paper has set out how the Plan has been prepared on the basis of robust and credible evidence, fully justifying the windfall assumptions in the plan, the settlement limits and the relationship between the housing and employment allocations within the context of the spatial strategy. It also addresses concerns raised about the overall housing numbers within the context of ensuring that the Plan can deliver sustainable growth as set out in the housing trajectory (Appendix 5 of M3.01R), along with addressing the reduction in the housing provision from the preferred strategy to the deposit plan.

The Council maintain that the Plan is sound in accordance with the three soundness tests and believe that the additional clarity provided by this note confirms this to be case.

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INSP017R 02/09/19 Appendix 1: Details of settlements in Tiers 2 and 3 without housing allocations Tier 2 Settlements Coedpoeth 1. The table in Appendix 2 shows the following breakdown of sites considered in Coedpoeth: Site Category: - Not Available (4) - Fundamental Constraints (13) - Deliverability (1)

2. Within the fundamental constraint category, highway safety (9 sites) is the key constraint. Issues arise with either providing access into a site or traffic is likely to flow onto the A525 via sub-standard junctions.

3. Prior to submission there was a capacity constraint at Junction 4 of the A483/A525 which is the principal route to Coedpoeth. This is a fundamental constrain that prevented additional development in the village. After submission of the Plan, further evidence from Welsh Government (SoCG004)9, demonstrates that capacity will be addressed earlier in the plan period than anticipated. Nonetheless, the Spatial Strategy was informed by the evidence known at the time.

4. During consultation on the Deposit Plan representations were made on 4 sites supporting their allocation, these sites had previously been proposed during the pre- deposit stages. These sites are considered in more detail below, none of which are suitable for allocation. Detailed Assessment of Sites presented at Deposit 5. NSP005 LAND EAST OF HEOL OFFA ROAD, COEDPOETH (previously CO001AS) - Principal reasons for rejection: highway safety at junction between Heol Offa and the A525; Offas Dyke Scheduled Ancient Monument runs along the western boundary of the site – CPAT state development would impact on setting and would prefer development not to occur and at least require a setting impact statement and further engagement with CPAT (not provided); potential setting issues with adjacent listed building. Other considerations: capacity of A483 junction with the A525, overhead power lines cross the site limiting developable area and landscape impacts.

6. Conclusion, it would seem unlikely the highway issues at the Ruthin Road, Heol Offa junction could be resolved as the land adjoining this junction forms the boundaries to third party properties. Furthermore, the creation of a suitable access into the site would have an impact upon the Listed Building and Offa’s Dyke. The site is not therefore considered suitable for allocation.

9 https://wrexham-consult.objective.co.uk/file/5480853 15

INSP017R 02/09/19 7. NSP006 LAND ADJACENT T0 ADWY GRANGE, TANLLAN LANE, COEDPOETH, WREXHAM (previously CO04CS) - Development on this site does not accord with the search sequence for new sites identified in Paragraphs 3.39-40 of PPW10 given that it is a greenfield site in the open countryside with poor accessibility to facilities in Coedpoeth. For this reason, the site should not be assessed further.

8. NSP034 LAND ADJACENT TO A525 RUTHIN ROAD, , WREXHAM (previously CO02CS) - The site is immediately adjacent an existing employment site occupied by a range of industrial and commercial operators including Tomlinsons Dairies which operates during anti-social hours. No supporting information has been supplied to demonstrate that the two uses are compatible, especially with regards to noise and odour.

9. NSP057 Field fronting Tyn Y Coed, Tallarn Lane, Coedpoeth (previously CO01CS) - Development on this site does not accord with the search sequence for new sites identified in paragraphs 3.39-40 of PPW (edition 10, 2018) given that it is a Greenfield site in the open countryside. Gresford 10. From Appendix 2 we can see the following breakdown for sites considered in Gresford Site Category: - Fundamental Constraints (22) - Not Available (5) - Windfall Potential (3) - Other (2)

11. Within the fundamental constraints category, highway safety (access and local highways) are the main fundamental constraints to development (15 sites). These sites add traffic onto highways of insufficient width/design to accommodate traffic flows, the highways lack pavements for extended lengths and have poor visibility. Additional growth using this network is possible, but the sites suggested have not provided sufficient evidence to demonstrate safe access/highways. Highway safety is the fundamental reason why the Council does not support development of the sites proposed at Deposit for Gresford (NSP22/36/37/38). 12. There are two sites (GRE09CS and GRE11CS) adjacent to Marford that are constrained by proximity to a conservation area and listed buildings, prominent location, green wedge and a third (GRE15CS) that is constrained by highways, that are on the Council’s reserve list. 13. During consultation on the Deposit Plan representation were made on 5 sites supporting their allocation. These sites had previously been proposed during the pre- deposit stages. These sites are considered in more detail below, but none is suitable for allocation.

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INSP017R 02/09/19 Detailed Assessment of Sites presented at Deposit 14. NSP009 HILLOCK LANE / VICARAGE LANE, GRESFORD, WREXHAM (previously GRE004AS) - The highways network, especially Vicarage Lane and Hillock Lane, serving this development is considered by the Highway Authority to be of insufficient width/design to serve developments of this size/nature. Hillock Lane suffers from inadequate carriageway width and lack of footways. 15. The transport statement submitted with the proposal at Deposit stage (Rep. LDP1187) does not consider the local highway network capacity, safety, constraints or traffic movements. There is insufficient information provided with the proposal to conclude that a development of around 300 houses on a constrained highway could be safely accommodated on this site. 16. A smaller scale of development (around 5-10) is the most appropriate scale of development and has been proposed in the Council’s reserve list. 17. NSP022 LAND TO SOUTH OF VICARAGE LANE AND EAST OF OLD WREXHAM ROAD, GRESFORD, WREXHAM (previously GRE15CS) - A Planning application (P/2018/1063) on a portion of this site has been refused (29/07/19) for non- compliance with UDP policies for the location of development and green wedge, the lack of a continuous footpath along Vicarage lane and highway safety. While there has been a refusal, UDP policies are not relevant to LDP allocations, the green wedge has been removed and mitigation may be possible for the highways concerns. The Council has therefore identified the site on its reserve list of LDP sites, but flagged it as amber (constrained). 18. NSP036 MARFORD HALL FARM, LAND OFF ROAD, MARFORD, WREXHAM (previously GRE002AS) - The site was rejected as an illogical extension to the settlement and harmful to the adjacent conservation area. 19. NSP037 OLD WREXHAM ROAD, GRESFORD, WREXHAM (previously GRE006AS) - Development on this site does not accord with the search sequence for new sites identified in paragraphs 3.39-40 of PPW10 given that it is a greenfield site in the open countryside. 20. NSP038 LAND ADJOINING TREETOPS, PIKEY LANE, GRESFORD, WREXHAM (previously GRE14CS) - Junction capacity at Pikey Lane/Chester Road may not be able to support any additional vehicles entering/leaving the site. 21. From Appendix 2 we can see the following breakdown for sites considered in Rhos. Site Category: - Not Available (8) - Fundamental Constraints (23) - Windfall Potential (11) - Deliverability (1)

22. While Rhos does not have allocations there are still 162 units in the supply, excluding future windfalls, which will provide a very useful contribution to local housing needs.

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INSP017R 02/09/19 23. Analysis of the candidate site assessment summaries in Appendix 2, confirms that options for allocations were limited by sites with fundamental constraints (highways and ecology - 17 sites) and 8 sites are not available (built out etc.). 24. The village has evolved from its historic mining past with a sporadic settlement pattern and highway network that does not meet modern standards. Additional growth using this network is possible, but the sites suggested have not provided sufficient evidence to demonstrate safe access/highways. The village is also unusual in having a SAC (Great Crested Newts) within an urban context and the management plan identifies pressure from development as a major threat to its condition. Consequently, several sites are constrained by ecology. 25. There are 11 sites within the settlement that have been identified as having constraints. If these could be overcome in principle these could come forward as windfall. 26. A large site was proposed (RH05CS), but this relates poorly to the settlement and is essentially a development in the open countryside, contrary to PPW10. 27. No representations were made on the Deposit Plan proposing sites for allocation in Rhos. Ruabon 28. From Appendix 2 we can see the following breakdown for sites considered in Ruabon Site Category: - Not Available (6) - Fundamental Constraints (11)

29. There are no proposed allocations in Ruabon, but there is Planning permission at Ruabon Business Park for 319 units in the LDP commitments. Infrastructure works needed to deliver an Aldi (opened) have been completed, thereby opening up the site for residential development. Combined with small site commitments and completions, 414 units are planned for Ruabon which is a significant level of growth for the village. Analysis of the site assessment database confirms that there is a lack of sites available (6) or have fundamental constraints (11), the majority of which are in the open countryside (6). Highway constraints account for an additional 3.

30. During consultation on the Deposit Plan representations were made on 5 sites supporting their allocation. These sites had previously been proposed during the pre- deposit stages

Detailed Assessment of Sites presented at Deposit 31. NSP001 LAND AT MAES‐Y‐LAN. RUABON (previously RU01CS) - Long, narrow site with a pinch point in the middle. Access would have to be off the currently un- adopted Blackbrook drive which is not suitable to accommodate any further residential development. There may be scope to develop about 3 houses on the site off this access but the remainder is too narrow to achieve adequate separation

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INSP017R 02/09/19 distances and is constrained in access terms. Likely to be reptiles present on the site but due to it’s configuration it would be difficult to achieve any meaningful mitigation. If constraints could be overcome the site is mainly within the settlement limit and could come forward as a windfall.

32. NSP039 VICARAGE FARM GARDENS, VICARAGE FIELDS, RUABON, WREXHAM (Previously RU04CS) - NSP040 LAND BETWEEN TWINING HILL AND VICARAGE FIELDS, RUABON, WREXHAM (Previously RU06CS) - NSP055 VICARAGE FIELDS, RUABON (Previously RU04/06CS) - These sites all lie in the open countryside. Site RU04CS is constrained on highway grounds due to the inability of the site to provide a suitable means of access and on arboricultural grounds due to the potential impact upon mature trees located on the highway verge. NSP040/55 - Adequate highway visibility could not be achieved along this section of the road and the site does not accord with the search sequence for land allocation in paras 3.39-40 of PPW (2012).

Tier 3 Settlements Bangor 33. From Appendix 2 we can see the following breakdown for sites considered in Bangor. Site Category: - Not Available (1) - Fundamental Constraints (6)

34. 7 sites were submitted for consideration, one of which is not available while all others have fundamental constraints. The village is within the flood plain for the River Dee; while the village has defences the flood plain limits development opportunities. 35. During consultation on the Deposit Plan a representation was made on 1 site supporting its allocation; this site had previously been proposed during the pre- deposit stages; Detailed Assessment of Sites presented at Deposit 36. NSP025 LAND ADJOINING MOUNTFIELDS BANGOR IS Y COED, WREXHAM (Previously BA02CS) - The sole means of access presented for the site is entirely within flood zone C1 as such the TAN15 justification test applies, the proposal has not demonstrated compliance with criteria i) (necessary to sustain the village) and does not comply with criteria iii) (previously developed land) therefore fails the justification test irrespective of a consequences assessment and proposed mitigation. It is appropriate for the Local Authority to prioritise sites without flood risk, while Bangor is a tier 3 settlement a case has not been made that development in a flood zone is necessary to sustain the village.

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INSP017R 02/09/19 Brymbo 37. While there aren’t allocations in Brymbo, there are just under 200 units to be delivered during the Plan period, the third highest in Tier 3. Furthermore, Brymbo has delivered significant growth during the UDP Plan period. Between April 2006 and March 2013, 526 dwellings were completed (from the 2011 census there were 1457 dwellings). From the original size of Brymbo pre 2006 there has been an approximate 50% increase in dwellings in the village. While there has been a significant growth in housing there has been no provision for supporting infrastructure (education, employment, retail).

38. From Appendix 2 we can see the following breakdown for sites considered in Brymbo. Site Category: - Not Available (11) - Fundamental Constraints (17) - Windfall Potential (2) - Other (2) BRY10CS/15CS – see below - Deliverability (1)

39. The majority of sites in Brymbo have fundamental constraints or are not available. However within the settlement limit there is a significant brownfield regeneration opportunity, the former Brymbo steelworks. 40. In preparing the Plan, 3 candidate sites were submitted by BDL, one greenfield site outside the settlement limit (BRY09CS) and two within the settlement limit on the former steelworks site (BRY10CS and BRY15CS). 41. BRY09CS - This is a greenfield site. With sequentially more preferable and sustainable previously developed sites within the Brymbo settlement limit the site was rejected. 42. BRY10CS and BRY15CS were both covered by Planning permission P/2014/0166. The application was the last in a long line of renewals of the original outline permission for redevelopment of the steelworks site, for B1, B2, B8 and D1 uses. The permission includes all of BRY10CS and BRY15CS as well as a rectangular plot of land to the south of BRY15CS that extended up to the northern edge of the extant residential development. The period for reserved matters submission expired in 2017 and the 5 year period for implementation expired in April 2019, though at the time of submission the site still had permission and, with no changes in policy an application to extend reserved matters would have been supported. 43. There is an extant outline permission for a school on approximately half of BRY10CS, the deadline for submission of reserved matters being March 2020. The Council’s Education department is actively pursuing this and keen to get a reserved matters application submitted. 44. Site BRY15CS was proposed by BDL in February 2013 for retail use which was subsequently granted Planning permission in 2014 (P/2012/0816). At the time of Plan

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INSP017R 02/09/19 submission there was a retail development permission on the site. Therefore, in the preparation of the Deposit Plan this site was not available for housing. 45. In summary, BRY15CS was not proposed for residential, BRY10CS has an extant permission for a school which is actively being pursued and there was a history of employment permissions elsewhere on BRY10CS. 46. In light of the past and planned significant housing growth for Brymbo and the planning history of the sites proposed, the Plan’s regeneration focus for the village is around delivery of supporting infrastructure. Policy EM1 safeguards an area for employment uses which overlaps with BRY10CS and would be consistent with the provision of a school. 47. While delivery of infrastructure is the priority for the village there is still a significant undeveloped remaining area within the settlement limit on the former steelworks site. Prior to Deposit this has not been proposed for development in the Plan by BDL and was not assessed as an allocation. However, development within the settlement limit is supported in principle by the Plan and national policy. If it came forward it would contribute towards the Council’s windfall provision. 48. However, there is a significant infrastructure constraint in Brymbo. At the time that the Plan was submitted development was limited by highway capacity constraints at Junction 4 of the A483. With a significant threat to deliverability, residential allocations (BRY10CS/15CS) have not been made in Brymbo. Though, since submission, WG has indicated that capacity will be addressed sooner than planned this will still constrain development until the upgrades to Junction 4 have been delivered (as with KSS1). 49. During consultation on the Deposit Plan representations were made on 4 sites supporting allocation; two had previously been proposed during the pre-deposit stages, but 2 have not previously been proposed. Detailed Assessment of Sites presented at Deposit 50. NSP029 FORMER OLD SLAUGHTERHOUSE, GLAS FFRWD PARK, FURNACE ROAD, FFRWD, WREXHAM (previously BRY16CS) - This site does not accord with the search sequence for new sites identified in paragraphs 3.39-40 of PPW10 given that it is a site in the open countryside. 51. NSP053 CEFN ROAD, LODGE, WREXHAM (previously BRY01CS) – This site raised objections during the candidate site assessment process on highway grounds as the site is unable to provide a safe means of vehicular access with sufficient visibility. 52. NSP030 FORMER STEELWORKS SITE, OFF PHOENIX DRIVE, BRYMBO, WREXHAM and NSP056 FORMER STEELWORKS SITE - The first time the entire area identified by NSP030 and NSP056 were presented to the Council for the LDP was at Deposit. As such the Council have not assessed the sites nor has the site proposer provided a candidate site assessment, SA, HRA or other supporting information (see paragraph 5.3.4.3, DPM2 and para 3.59 and 3.109 of DPM3 consultation draft).

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INSP017R 02/09/19 Glyn Ceiriog 53. From Appendix 2 we can see the following breakdown for sites considered in Glyn Ceiriog. Site Category: - Not Available (3) - Fundamental Constraints (7)

54. The main constraint to development in Glyn Ceiriog is highway safety with proposals attempting to access narrow roads with poor visibility without footpath provision and steep topography. Despite being a Tier 3 settlement, deliverable sites have not been identified. At Deposit a representation was received supporting an employment site that had previously been rejected. Detailed Assessment of Sites presented at Deposit 55. NSP035 LAND TO SOUTH EAST OF OLD ROAD, GLYN CEIRIOG, WREXHAM (previously GC05CS) Employment - A greenfield site that lies outside and detached from the settlement limit of Glyn Ceiriog. Objections have been raised on highway grounds due to the inability of the site to provide a safe means of vehicular access. Furthermore, given the location near to the SAC, whilst it may be possible to mitigate some effects of development in this location, the maintenance of surface water management systems and ecological buffer strips will have a large land take. Whilst such a use may be supported by national planning policy, it would not contribute to the strategic employment land supply and would not justify allocation. However, if the issues identified above can be addressed, a Planning application for rural employment development may be supported by the Plan policies. Penycae 56. From Appendix 2 we can see the following breakdown for sites considered in Penycae Site Category: - Not Available (3) - Fundamental Constraints (13) - Windfall Potential (1)

57. The majority of sites in Penycae have been rejected, following consultation with the Highway Authority, for reasons of highway safety arising from access points and additional traffic through a highway network of narrow roads, poor visibility and footway provision. 58. No representations promoting specific sites in Penycae were made on the Deposit Plan. Rhostyllen 59. While there aren’t any allocations in Rhostyllen there is a significant commitment from the National Trust site delivering 223 units over the Plan period, the second highest in a Tier 3 settlement. 22

INSP017R 02/09/19 60. From Appendix 2 we can see the following breakdown for sites considered in Rhostyllen Site Category: - Not Available (2) - Fundamental Constraints (6) - Windfall Potential (1)

61. After the candidate site assessment process constraint free sites have not been identified for Rhostyllen. The main proposal for the village, and only rep at Deposit, is a coal spoil tip with no realistic prospect for delivery in the plan period, see below. Detailed Assessment of Sites presented at Deposit 62. NSP015 LAND AT PLAS GRONO ROAD, RHOSTYLLEN, WREXHAM (previously RT03CS) - There is a Planning permission on the site (P/2008/0226) for reclamation of the colliery spoil. An application to extend the time limit for implementation was granted on 10/05/18 to allow a further 5 years (P/2015/0337). The permission has an extensive range of pre-commencement conditions that have yet to be discharged. With a significant amount of material on the site that needs to be cleared it is extremely unlikely that development will be delivered during the Plan period. Furthermore, even if the material was removed the permission includes a restoration condition, so there is no need for a site-specific restoration policy in the Plan.

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Appendix 2: Site details for sites in tiers 2 and 3 that have not been allocated. Coedpoeth Site Ref Site Category Fundamental Constraints Other Constraints CO001AS Fundamental Principle reasons for rejection; highway safety at junction Other constraints to development significantly Constraint that between Heol Offa and the A525; reduce site potential: Offas Dyke Scheduled Cannot be Ancient Monument runs along the eastern Mitigated boundary of the site; Overhead power lines cross the site; capacity of J4 A483 CO002AS There is currently no adequate access into any part of the Capacity of J4 A483 site; although it may be possible to establish a signal controlled access directly on to Ruthin Road just west of the football fields. A site which combined CO03 and CO02 would probably require a second access in to the site. It is difficult to see how this can be established in land under their ownership. CO003AS Not Available Proposed for Employment CO01CS Fundamental Within Open Countryside, allocation contrary to PPW Further, if an access could be provided this Constraint that would be onto the A525 and the lack of Cannot be capacity at the junction of the A525 and A483 Mitigated would be a further constraint. CO01OS Highway safety at junction between Heol Offa and the A525; The twin constraint of Offa's Dyke (with ancient and protected hedgerow) and overhead power cables limit developable area and potential access. CO02CS Compatibility issues with the adjoining industrial estate Coalescence between Coedpoeth and the housing development in the north CO02OS Development here would not be a natural extension to the Further, if an access could be provided this settlement limit and the site is designated as a local wildlife would be onto the A525 and the lack of site. capacity at the junction of the A525 and A483 would be a further constraint. CO03CS Objections have been raised on highway grounds given the Further, if an access could be provided this inability of the site to provide a safe means of vehicular would be onto the A525 and the lack of access and the inadequacy of the surrounding highway capacity at the junction of the A525 and A483 network. would be a further constraint.

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CO03OS Fundamental Access is the principle issue here and the site has not been Further, if an access could be provided this Constraint that allocated primarily due to concern that a suitable, would be onto the A525 and the lack of Cannot be acceptable access not possible. capacity at the junction of the A525 and A483 Mitigated would be a further constraint. CO04CS Within Open Countryside, allocation contrary to PPW CO05CS Substandard highway network serving the estate and sub- Further, if an access could be provided this standard junctions joining A525 would be onto the A525 and the lack of capacity at the junction of the A525 and A483 would be a further constraint. This site, along with CO06CS and CO07CS sit outside the settlement limit of Coedpoeh which is currently drawn tightly alongside Tallwrn Road. There is a defined urban edge along this boundary and all these sites across the road are so clearly rural in their context that it is difficult to see how development could be accommodated in this location without adversely impacting on the rural setting. Any development on these sites would not represent a logical pattern of settlement expansion in this location and despite being edge of settlement CO06CS Substandard highway network serving the estate and sub- Further, if an access could be provided this standard junctions joining A525 would be onto the A525 and the lack of capacity at the junction of the A525 and A483 would be a further constraint. This site, along with CO05CS and CO07CS sit outside the settlement limit of Coedpoeh which is currently drawn tightly alongside Tallwrn Road. There is a defined urban edge along this boundary and all these sites across the road are so clearly rural in their context that it is difficult to see how development could be accommodated in this location without adversely impacting on the rural setting. Any development on these sites would not represent a logical pattern of

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settlement expansion in this location and despite being edge of settlement CO07CS Fundamental Substandard highway network serving the estate and sub- Further, if an access could be provided this Constraint that standard junctions joining A525 would be onto the A525 and the lack of Cannot be capacity at the junction of the A525 and A483 Mitigated would be a further constraint. This site, along with CO06CS and CO05CS sit outside the settlement limit of Coedpoeh which is currently drawn tightly alongside Tallwrn Road. There is a defined urban edge along this boundary and all these sites across the road are so clearly rural in their context that it is difficult to see how development could be accommodated in this location without adversely impacting on the rural setting. Any development on these sites would not represent a logical pattern of settlement expansion in this location and despite being edge of settlement CO08CS Not Available Proposed for Employment CO09CS Fundamental The site can not be accessed and the existing access is not Constraint that up to standard and can not be improved due to land Cannot be ownership issues. Mitigated COED002UCS Not Available Built Out COED003UCS Deliverability Development of northern section dependent upon intentions of owners of Cwm Pennant. Could potentially yield 5 units on an area of 0.17ha, a net of 4, but considered unlikely. COED004NUCS Not Available Has Planning Permission

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Gresford Site Ref Site Category Fundamental Constraints Other Constraints GR01OS Fundamental The highways network, especially Vicarage Lane and Constraint that Hillock Lane, serving this development is considered by Cannot be Mitigated our Highways section to be of insufficient width / design to serve developments of this size / nature. Hillock Lane suffers from inadequate carriageway width and lack of footways. Narrow pinch point on Hillock Lane not within ownership to manage this, ghost island needed on Chester Road to serve development but no scope to provide one, Wynnstay Lane single lane width and is the most direct access route to Wrexham Industrial Estate, highway safety concerns with more traffic on this route. GR02OS The site is a former quarry that has been substantially naturalised and restored as a community nature reserve. It has ecological links to the nearby SSSI. GRE001AS The Highway Officer would not wish to support development of this size in this location given the inadequate carriageway width, lack of footway provision and lack of visibility at Marfod Hill/Hoseley Lane junction. GRE002AS It is considered to be too detached and divorced from the Concerns have been raised by settlement limit to represent a logical extension for Conservation Officers about the harm that development may be caused to the setting of the adjacent listed buildings and the distinct character and appearance of the adjoining Conservation Area. GRE003AS Objections have been raised on highway grounds due to The majority of the hedgerow along Old the lack of footway provision into Gresford and the Wrexham Road would need to be inability to improve this. removed to provide the required visibility splays. It is further stated that the development of this site would not accord with paragraph 3.4 of TAN18.

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GRE004AS Fundamental The highways network, especially Vicarage Lane and Constraint that Hillock Lane, serving this development is considered by Cannot be Mitigated our Highways section to be of insufficient width / design to serve developments of this size / nature. Hillock Lane suffers from inadequate carriageway width and lack of footways. Narrow pinch point on Hillock Lane not within ownership to manage this, ghost island needed on Chester Road to serve development but no scope to provide one, Wynnstay Lane single lane width and is the most direct access route to Wrexham Industrial Estate, highway safety concerns with more traffic on this route. GRE005AS Inadequate carriageway width (Cox Lane & Hoseley A wildlife site and group TPO adjoins the Lane), lack of footway provision and inadequate visibility south west corner together with a CADW at the Marford Hill / Hoseley Lane junction, I would not Registered Grade II Park and Garden - wish to support a development of this size / nature. Horsley Hall. Trees are present on the east and west boundaries. GRE006AS Within Open Countryside, allocation contrary to PPW GRE01CS Within Open Countryside, allocation contrary to PPW. Is subject to an area TPO and also forms part of a local wildlife site with protected species of birds present. GRE02CS Objections have been raised on highway grounds due to the inability of the site to provide a safe means of vehicular access or utilise the existing access which serves village walks. GRE03CS Extending the settlement limit in this location would not represent a logical extension to the settlement boundary. Furthermore objections have been raised on highway grounds given the inadequate carriageway width and the lack of footway provision along Old Wrexham Road GRE04CS Extending the settlement limit in this location would not represent a logical extension to the settlement boundary. Furthermore objections have been raised on highway grounds given the inadequate carriageway width and the lack of footway provision along Old Wrexham Road

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GRE05CS Fundamental The narrow width of the lanes, the lack of pedestrian Constraint that access and the visibility at the junction of both lanes does Cannot be Mitigated not make the site suitable for any further residential development GRE06CS Within Open Countryside, allocation contrary to PPW. GRE07CS The geometry of the junction at Chester Road / Pikey Badgers and newts are known to use the Lane is substandard in the north easterly direction and site (badger sett in Bryn y Groes) and highways would not be able to support development on appropriate mitigation measures would be this site as land in third party ownership would be required to ensure that these species required to upgrade the junction. could adequately be accommodated through any development scheme. GRE08CS Visibility is substandard in the south easterly direction The site is covered in TPO trees and there is a lack of footway provision to link the site to services and public transport available in the village. GRE09CS Other Constrained (adjacent to a conservation area and listed buildings, prominent location, green wedge) GRE10CS Constrained (adjacent to a conservation area and listed buildings, prominent location, green wedge) GRE11CS Windfall Potential Access constraints in terms of access and adjacent conservation area, would therefore be too small to allocate but could be a potential windfall site. GRE12CS Fundamental Objections have been raised from a conservation point of Constraint that view with regard to the potential impact upon Marford Cannot be Mitigated Hall a grade II listed building. GRE13CS Within Open Countryside, allocation contrary to PPW. GRE14CS Junction capacity at Pikey Lane/Chester Road not be Site is in an area known to support GCN able to support any additional vehicles entering/leaving and surveys would be required, as would the site. the retention of hedgerows to maintain connectivity. GRE15CS A planning application (P/2018/1063) on a portion of this site has been refused (29/7/2019) one relevant reasons is the lack of a continuous footpath along Vicarage lane and highway safety.

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GRES001UCS Not Available Sub-station GRES002UCS Has Planning Permission GRES004UCS Now a Supermarket GRES005UCS Fundamental Site occupied by flats and mature tree coverage. Constraint that Planning permission refused (CB00428) highway safety / Cannot be Mitigated access grounds. Objections raised on highways grounds GRES006UCS Windfall Potential Too small for allocation but within S/L GRES007UCS Fundamental Tree coverage, Restricted access, land levels. Access Constraint that issues would prevent the development of this site. Cannot be Mitigated Highway objections received. GRES008UCS Windfall Potential Too small for allocation but within S/L GRES009NUCS Not Available Retail Unit GRES010NUCS Has Planning Permission

Rhosllanerchrugog Site Ref Site Category Fundamental Constraints Other Constraints RHO001AS Fundamental Highway objections have been raised due to the unsuitability of the private Constraint that Cannot access road which serves the site. Not considered suitable for allocation as be Mitigated it would represent an illogical extension into the countryside RHO002AS Not Available Has Planning Permission JOHN001UCS Windfall Potential Deliverability concerns but within S/L JOHN002UCS The site incorporates a number of trees, and access may be difficult. Having regard to this, the site may be too small to be allocated but there may be potential to come forward as a windfall site if issues can be resolved JOHN003UCS Small site JOHN004UCS Fundamental Unsuitable access JOHN005UCS Constraint that Cannot A previous application included the demolition of Hafod ty but was be Mitigated withdrawn due to irresolvable highways issues. Objections have been raised on highway grounds and the site is therefore not currently considered suitable. JOHN006UCS Windfall Potential Small site JOHN007UCS Small site Ecology - SAC

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JOHN008UCS Not Available Has Planning Permission JOHN009UCS Windfall Potential Small site JOHN010UCS Not Available Has Planning Permission JOHN011UCS Has Planning Permission JOHN013UCS Fundamental Ecology constraints - GCN network for adjacent SAC JOHN014UCS Constraint that Cannot Ecology constraints - GCN network for adjacent SAC, windfall if mitigation be Mitigated possible JOHN015UCS Windfall Potential Has previously had planning permission JOHN016UCS Has previously had planning permission JOHN017UCS Fundamental Highways have objected on visibility grounds. Constraint that Cannot be Mitigated JOHN018UCS Not Available Built Out JOHN019UCS Fundamental Highways have objected on visibility grounds. JOHN020UCS Constraint that Cannot Highways have objected on visibility grounds. be Mitigated JOHN021UCS Windfall Potential Small site JOHN023UCS Small site JOHN024UCS Fundamental NRW have raised objections due to the impact upon the adjoining SAC JOHN025UCS Constraint that Cannot Site constrained by trees and a brook be Mitigated JOHN026NUCS Windfall Potential Small site JOHN027NUCS Fundamental Substandard access and ecological issues. Constraint that Cannot be Mitigated JOHN028NUCS Not Available Has Planning Permission JOHN029NUCS Deliverability Current employment use JOHN030NUCS Not Available Has Planning Permission

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RHO01CS Fundamental The site falls within the buffer of the Johnstown Newt Site SAC and is Constraint that Cannot located along a key green corridor which connects the SAC to the wider be Mitigated countryside. As such this site is inappropriate for development as the mitigation required to off-set potential impacts to the SAC would be undeliverable. In terms of highway issues, the site is located off an unadopted highway (The Haven) which is below current design standards with the main route out of the site via the Stanley Road /Fennant Road junction, where visibility is substandard The site is not therefore considered suitable for development RHO01OS The site is not a natural extension to the settlement limit with a detrimental impact on rural character. Poor highway network serving the site. RHO02CS Objections have been raised on highway grounds due to the inadequacy of the surrounding road network. RHO02OS The site is not a natural extension to the settlement limit with a detrimental impact on rural character. Poor highway network serving the site. RHO03CS Too narrow in it's own right to accommodate an appropriate form of Public sewerage development. system flooding, minerals exploration, the substandard highway network, contamination RHO03OS Site Crossed by National Grid pylons with easement rights RHO04CS The site falls within the buffer of the Johnstown Newt Site SAC and is Significantly erode the located along a key green corridor which connects the SAC to the wider open countryside countryside. As such this site is inappropriate for development as the separation between mitigation required to off-set potential impacts to the SAC would be and Pentre undeliverable Bychan, the rural setting and sense of place to these settlements RHO04OS Site Crossed by National Grid pylons with easement rights RHO05CS Within Open Countryside, allocation contrary to PPW Poorly related to settlement limit and services, ecology and landscape impacts

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INSP017R 02/09/19

RHO06CS Fundamental Due to presence of mine shafts development would not provide a form and Green Barrier Constraint that Cannot layout which unifies the development with the pattern of development found be Mitigated in the locality. RHO07CS The site does not have a frontage with any adopted highway. It may be Green Barrier possible to provide access off Pant Hill in land opposite the property known as Embank. It is unlikely that the access would be suitable for any more than a limited development. Pant Hill and the roads in the site vicinity are unsuitable to cater for any significant sized further residential development. RHO08CS The site is covered in trees, some of which are subject to TPO and a Given the location of planning application for development was withdrawn in 2008 due to the lack the existing access of information submitted in respect of the trees. The site also forms part of onto gutter hill, in close the stryt las SSSI and SAC and there are ecological objections to the proximity to access to allocation of this site as it is considered that any development here would the New Foundry be harmful to the integrity of the SAC. Buildings to the east, only a couple of dwellings could be supported on this site. RHO09CS Not Available Site has Planning Permission

Ruabon Site Ref Site Category Fundamental Constraints Other Constraints RU01CS Fundamental Access would have to be off the currently un-adopted Blackbrook drive Constraint that Cannot which is not suitable to accommodate any further residential development. be Mitigated There may be scope to develop about 3 houses on the site off this access but the remainder is too narrow to achieve adequate separation distances and is constrained in access terms. Likely to be reptiles present on the site but due to it’s configuration it would be difficult to achieve any meaningful mitigation. If constraints could be overcome the site is mainly within the settlement limit and could come forward as a windfall. RU01OS Site is a children’s playground RU02CS Access to the site is unlikely to be achieved as there can be no direct access off the A483 and the footpath to the south is of insufficient width to provide a suitable access.

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INSP017R 02/09/19

RU02OS Fundamental The site does not have direct access, this can only be achieved by Constraint that demolishing Braeside to the south or Rivers View to the north, there is no Cannot be Mitigated indication that demolition has been considered by the property owners. The site is constrained by the Afon Eitha to the east and mature trees around the site limiting development opportunities. RU03CS Within Open Countryside, allocation contrary to PPW RU04CS Within Open Countryside, allocation contrary to PPW RU04CS is constrained on highway grounds due to the inability of the site to provide a suitable means of access and on arboricultural grounds due to the potential impact upon mature trees located on the highway verge. RU05CS Not Available Granted Planning Permission RU06CS Fundamental Within Open Countryside, allocation contrary to PPW Adequate highway Constraint that visibility could not be Cannot be Mitigated achieved along this section of the road RU07CS Not Available Duplicate of RU05CS RU08CS Fundamental Within Open Countryside, allocation contrary to PPW RU09CS Constraint that Mostly covered in trees and has high potential to support bats, which could Cannot be Mitigated most likely be mitigated. Harmful impact on adjacent Listed gateway RU10CS Within Open Countryside, allocation contrary to PPW The site is also located within the grade 1 registered historic park and garden of Wynnstay, which is in itself a grade II* listed building. Scale of development with adjacent business park.

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INSP017R 02/09/19

RU11CS Fundamental Within Open Countryside, allocation contrary to PPW Constraint that Cannot be Mitigated RU12CS Not Available Granted Planning Permission RUAB001UCS Granted Planning Permission RUAB002UCS Built Out RUAB003NUCS Built Out

Bangor Site Ref Site Category Fundamental Constraints Other Constraints BAOO1AS Fundamental Within Open Countryside, allocation contrary to PPW Constraint that Cannot be Mitigated BA002AS Not Available Proposed for Mineral Development Not demonstrated a need, environmental, flooding, ecology, transport, BMVAL BA01CS Fundamental Within Open Countryside, allocation contrary to PPW Landscape, access, Constraint that built conservation BA01OS Cannot be Mitigated Entire site is C1 Flood risk and Highway access Ecology BA02CS / Access in C1 flood zone fails TAN15 justification test Landscape, built NSP025 conservation BA03CS 75% of site in zone C1, fails TAN15 justification test, safe access may not be BMV grade 3a, achievable conservation, landscape, ecology and trees BA04CS Prominent elevated position above the village, harmful to setting of Bangor, illogical settlement extension

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INSP017R 02/09/19

Brymbo Site Ref Site Category Fundamental Constraints Other Constraints BRY001AS Fundamental An outline application for 50 dwellings was refused in June 2015 for a Constraint that number of reasons including land stability, inappropriate means of vehicular Cannot be Mitigated access, loss of trees, ecological impact, and archaeological impact. BRY002AS Within Open Countryside, allocation contrary to PPW Small site, highways constraints BRY01CS The site is unable to provide a safe means of vehicular access with sufficient Green Wedge visibility BRY02CS The site is unable to provide a safe means of vehicular access with sufficient visibility BRY03CS The site is unable to provide a safe means of vehicular access with sufficient visibility BRY04CS The site is unable to provide a safe means of vehicular access with sufficient visibility BRY05CS Illogical Extension and the site is unable to provide a safe means of vehicular access with sufficient visibility BRY06CS The site is unable to provide a safe means of vehicular access with sufficient visibility BRY07CS Within Open Countryside, allocation contrary to PPW BRY08CS Inadequate highway width, access and lack of public footpath BRY09CS Other More sustainable sites proposed BRY10CS Not Available Has past consents for B1/B2/B8 development.LDP policy EM1 protection for employment uses BRY11CS Has Planning Permission BRY12CS Has Planning Permission BRY13CS Has Planning Permission BRY14CS Fundamental Illogical pattern of development that would be created Constraint that Cannot be Mitigated BRY15CS Other BRY16CS Fundamental Within Open Countryside, allocation contrary to PPW Constraint that Cannot be Mitigated

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INSP017R 02/09/19

BRYMOO1UCS Windfall Potential Small site BRYM002UCS Not Available Has Planning Permission BRYM003UCS Has Planning Permission BRYM005UCS Fundamental The site is unable to provide a safe means of vehicular access with sufficient Constraint that visibility BRYM006UCS Cannot be Mitigated The site is unable to provide a safe means of vehicular access with sufficient Trees and ecology visibility BRYM007UCS Deliverability Existing School use BRYM008UCS Not Available Built Out BRYM009UCS Fundamental The site is unable to provide a safe means of vehicular access with sufficient Constraint that visibility Cannot be Mitigated BRYM010UCS Not Available Built Out BRYM020UCS Built Out BRYM022UCS Fundamental Sewer easement rights Constraint that Cannot be Mitigated BRYM023UCS Windfall Potential If constraints (trees, ecology, land stability) can be overcome potential for small scale development BRYM024NUCS Not Available Has Planning Permission BRYM025NUCS Has Planning Permission

Glyn Ceiriog Site Ref Site Category Fundamental Constraints Other Constraints GC01CS Fundamental Substandard access roads and pedestrian links Constraint that Cannot be Mitigated GC02CS Not Available Proposed for Employment Planning appeal refused on the site; Inadequate access visibility GC03CS Fundamental Planning appeal refused on the site; Inadequate Constraint that access visibility Cannot be Mitigated GC04CS Not Available Proposed for G&T use Planning appeal refused on the site; Inadequate access visibility

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INSP017R 02/09/19

GC05CS Not Available Proposed for Employment GC06CS Fundamental The site is unable to provide a safe means of Constraint that vehicular access with sufficient visibility GC07CS Cannot be Mitigated Within Open Countryside, allocation contrary to PPW GC08CS Within Open Countryside, allocation contrary to PPW GC09CS Substandard access roads and pedestrian links Loss of hedgerows to deliver access, prominent hillside location GLYN001AS An application (P/2015/0902) for 2 dwellings on this site was dismissed at appeal on 11th August 20016 on the basis that there would be significant harm to the SLA and the rural setting of the village.

Penycae Site Ref Site Category Fundamental Constraints Other Constraints PEN001AS Fundamental Sub-standard road network not suitable for the scale Given the need to protect the TPO’s to the Constraint that of development proposed west and the wooded area in the north of the Cannot be Mitigated site, any development would appear detached and would not form a logical extension to the settlement boundary. PEN002AS Site not considered suitable for allocation due to the lack of highway capacity PEN01CS Not Available Proposed for School use PEN02CS Fundamental Sub-standard road network PEN03CS Constraint that Within Open Countryside, allocation contrary to PPW Cannot be Mitigated PEN04CS Fundamental Highways have objected on the basis that the Development within the site would Constraint that surrounding road network is not sufficient to fundamentally change the form and character Cannot be Mitigated accommodate further development of the village and significantly erode the sense of place, rural connection and outlook. PEN05CS Not Available Has Planning Permission PEN06CS Fundamental The site does not have a frontage with any adopted Ecology -within SAC Buffer Constraint that highway but there is an unadopted road, accessed off Cannot be Mitigated Pant Hill which leads to the site. Pant Hill has inadequate visibility and as such, from a highway

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INSP017R 02/09/19

perspective the site is not considered suitable for development. PEN07CS Fundamental Within Open Countryside, allocation contrary to PPW PEN08CS Constraint that Adequate access onto an adopted highway is not Loss of trees Cannot be Mitigated possible and for this reason, the site is not considered suitable for development. PEN09CS Within Open Countryside, allocation contrary to PPW PEN10CS C2 flood zone and sub-standard highway access PEN11CS Not Available Has planning permission for school use PENY001UCS Windfall Potential Highway constraints but windfall (within S/L) if overcome PENY002UCS Fundamental Sub-standard road network, landscape PENY01OS Constraint that Access cannot be achieved (lease) PENY02OS Cannot be Mitigated The site lies with flood zone C2, areas of flood plain without significant defence and would not pass the TAN15 justification test - its not a brownfield site and its unlikely the consequences of flood can be mitigated (most of the site is in C2, the remainder is not developable as its mature woodland).

Rhostyllen Site Ref Site Category Fundamental Constraints Other Constraints RHOS001AS Fundamental Within Open Countryside, allocation contrary to PPW Constraint that RHOS001UCS Cannot be Mitigated On POS and small size RHOS002UCS Not Available Built Out RHOS003UCS Fundamental Access not possible without demolishing existing Constraint that housing. Also given the configuration of the site it Cannot be Mitigated would not be possible to develop more than 4 units without adversely affecting residential amenity. There would therefore be no net gain in terms of the number of units developed. RHOS004UCS Windfall Potential Too small to allocate but windfall potential RHOS005NUCS Not Available Has Planning Permission

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INSP017R 02/09/19

RT01CS Fundamental Within Open Countryside, allocation contrary to PPW RT02CS Constraint that Safe access and visibility cannot be achieved Green Wedge with Wrexham RT03CS Cannot be Mitigated Deliverability, current coal tip Ecology, trees, landscape, heritage

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INSP017R 02/09/19 Appendix 3: WG response to the Preferred Strategy:

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