WREXHAM UNITARY DEVELOPMENT PLAN : PROPOSED FURTHER MODIFICATIONS : REPRESENTATIONS AND RESPONSES
Table A
Ref
FM1
Further Proposed
Modification
Number
1A and 1B
VALID REPRESENTATIONS
Policy
Representor
Paragraph 11.1:
Background to Mineral
Working and New Policy
: Mineral Prohibition
Orders
Carter Jonas
for Grosvenor
Estate
Council’s Response
Representation Summary
Objects on the following grounds:(i)
Sites classified as dormant
under the Environment Act
1995 and Interim
Development Order
legislation cannot be reactivated until a new scheme
of conditions has been
submitted to and approved
by the Mineral Planning
Authority. This provides
control over the extraction
operations and allows for
working, restoration and
environmental issues to be
fully addressed in the
application, via
Environmental Impact
Assessment, and the final
consent. Therefore,
Prohibition Orders, designed
to ensure that no further
extraction takes place
without a further planning
consent are unnecessary.
(i)
Disagree. Prohibition Orders
enable local planning authorities to
deal with the special problems
arising from the cessation of
mineral operations on a site before
working is exhausted. This power
is particularly apposite in situations
where no mineral extraction has
taken place for many years and
where site restoration conditions
are either absent or ineffective. The
Council considers that mineral
working at the sites identified in
the proposed modification has
permanently ceased and that, in
these circumstances, the issuing of
prohibition orders is the
appropriate procedure to apply.
This action accords with paragraph
19 of Minerals Planning policy
Wales which stresses that inactive
minerals sites should be identified
in the development plan and should
be the subject of a suitable future
land use strategy.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
Procedural Considerations
Prohibition Order procedures
have safeguards in that there are a
number of steps which need to be
followed in connection with the
making of an Order including the
need for confirmation of the
Order by the National Assembly
for Wales. The confirmation
procedure may include the
holding of a public inquiry to
enable objections to be
considered. On balance therefore
the public interest is best served
by proceeding to adopt the UDP
now rather than having a further
public local inquiry.
(ii)
The Mineral Planning
Authority should seek to
reach agreement with
operators and owners
regarding the future of
inactive/dormant sites within
the framework of the
Environment Act 1995 and
Interim Development Order
legislation, rather than
prohibit working under an
Order. It is understood that
no discussions have taken
place with those who have
interests in the sites listed in
the proposed modification
with regard to the current
status and future plans for
those sites. Such a list is
therefore premature and
should be deleted at this
stage.
(ii)
Noted. With a view to reaching
agreement on modern schemes of
working, the Council is always
willing to participate in discussions
with owners and potential operators
of sites registered under the
Environment Act and Interim
Development Order. This course of
action is not precluded by the
inclusion of a policy in the Unitary
Development Plan to make
prohibition orders. The list of sites
attached to the policy is not
therefore premature. As stated
above, these are sites where
mineral working has permanently
ceased. This action accords with
paragraph 19 of Minerals Planning
Policy Wales which stresses that
inactive minerals sites should be
identified in the development plan
and should be the subject of a
suitable future land use strategy.
(iii)
The use of Prohibition
Orders to control mineral
working may give rise to
unnecessary and costly legal
challenges, which could be
avoided if the procedures set
out by the Environment Act
1995 and Interim
Development Order
legislation were followed.
(iii) Disagree. See response to points (i)
and (ii) above. The ability to make
prohibition orders has been given
to local authorities in order to deal
with problems that previous
legislation did not address. This
procedure is, of course, totally
separate from the UDP preparation
process, and has its own
accompanying legal procedures &
rights to object. Options for legal
challenge apply to many areas of
local authority responsibility and
should not deter councils from
using powers which have been
made available for a specific
purpose.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
(iv)
FM2
1A
Paragraph 11.1:
Background to Mineral
Working
Smiths Gore
for Tarmac
Central
Limited
Further clarification is not
required to contribute to a
more accurate and realistic
assessment of mineral
landbanks, as
dormant/inactive sites are
taken account of in the
Regional Aggregates
Working Party’s assessment
of reserves and landbank
calculations.
Objects to the text of paragraph 11.1
and suggests the following
amendments:(i)
Sentence 3 should read “The
Plan therefore encourages
the recycling of minerals
and the use of secondary
aggregates wherever
possible in order to foster
the aims of sustainable
development by reducing
reliance on primary
aggregates”. Sentence 4
(“This will contribute
towards sustainable
development by reducing the
need to work new reserves”)
should then be deleted. The
amended wording is
proposed because there is no
conclusive evidence that the
greater use of recycled and
secondary aggregates will
necessarily reduce the need
to work new reserves.
(iv) Disagree. Assessments of mineral
reserves containing estimates for
sites unlikely ever to be worked are
unrealistic. Prohibition orders will
enable these sites to be removed
from any landbank calculations
carried out by the Regional
Aggregates Working Party.
(ii)
(ii)
The final sentence should
read “In these
circumstances, the Council
(i)
Partly agree. The suggested
rewording of sentence 3 is accepted
since it stresses the need to promote
sustainable development. However,
the Council does not consider that
the reference to reducing the need
to work new reserves should be
deleted. The sentence will therefore
be amended as follows:“The Plan therefore encourages the
recycling of minerals and the use of
secondary aggregates wherever possible
in order to foster the aims of
sustainable development by reducing:(a) reliance on primary aggregates,
and
(b) the need to work new reserves”.
Agree. The additional wording will
indicate that other methods of
surrendering planning permissions
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
The differences between the
positions of the Local Planning
Authority and the objector are not
great and resolution of the
differences are not going to be
materially assisted by holding a
further public local inquiry.
On balance therefore the public
interest is best served by
proceeding to adopt the UDP now
rather than having a further public
local inquiry
FM3
1A
Paragraph 11.1:
Background to Mineral
Working
Sesswick
Community
Council
FM4
1A
Mrs D Pearson
Rossett
FM5
1A
Paragraph 11.1:
Background to Mineral
Working
Paragraph 11.1:
Background to Mineral
Working
FM6
1A
Paragraph 11.1:
Background to Mineral
Working
FM7
1B
New Policy : Mineral
Prohibition Orders
Klaus
Armstrong
Braun :
Flintshire
Green Party
Welsh
Assembly
Government
Smiths Gore
for Tarmac
Central
will, where appropriate,
seek to impose prohibition
orders to prevent mineral
working from
recommencing”. The
amendment is proposed
because, whilst the proposal
is only “to seek” Prohibition
Orders, paragraph 49 of the
Welsh Assembly
Government’s Aggregates
Technical Advice Note
indicates that the surrender
of permissions at such sites
may also be secured by
planning agreements.
The Council supports this
modification and considers that the
recycling of minerals will greatly
reduce the tonnage of materials
currently disposed of in landfill sites.
No objections to proposed further
modifications
are available in certain cases.
However, in the case of the five
sites identified in proposed
modification 1B, the very
considerable length of time that has
elapsed since these sites were last
worked justifies the
implementation of the prohibition
order procedures.
Noted.
Noted.
No objection to proposed
modification.
Noted.
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
Objects to the text of the new policy
and suggests that the first part should
read:-
Noted.
Disagree. The intention of the proposed
new policy is to make it clear that the
statutory powers available to issue
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
Similar considerations apply to
those set out in relation to
objection FM1 above and in the
Limited
FM8
1B
New Policy : Mineral
Prohibition Orders
Sesswick
Community
Council
FM9
1B
New Policy : Mineral
Prohibition Orders
FM10
1B
FM11
1B
New Policy : Mineral
Prohibition Orders
New Policy : Mineral
Prohibition Orders
Klaus
Armstrong
Braun :
Flintshire
Green Party
Mrs D Pearson
Rossett
Welsh
Assembly
Government
“Appropriate legal agreements or,
where necessary, Prohibition Orders,
designed to ensure that no further
extraction takes place without a
further planning consent will be
sought for the following sites:
1. Bwlchgwyn : Bwlchgwyn Quarry
(north)
2. Bwlchgwyn : Bwlchgwyn Quarry
(south)
3. Froncysyllte : Pen Y Graig
4. Rhos : Llwyneinion
5. Wern : Tir Celyn”
The amendment reflects the
reasoning set out in Tarmac’s
representation on modification 1A
above (i.e. that the surrender of
permissions can be secured by
planning agreements).
The maps relating to individual
quarries do not contain details of the
minerals obtained there and this
information would be helpful.
prohibition orders will be actively used
in the case of the five identified sites.
The Council appreciates that in the case
of other sites, legal agreements as
referred to in the Aggregates Technical
Advice Note, might be appropriate.
However, it is considered unnecessary to
include these in a policy which
specifically covers prohibition orders.
same way on balance it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
having a further public inquiry.
Disagree. It is unnecessary to identify the
actual mineral which was once extracted
from the sites where it is proposed to
impose prohibition orders. To do so
would unnecessarily complicate the
Unitary Development Plan Proposals
Maps for no apparent policy benefit.
It is submitted that this point is
not significant enough to justify
the holding of a further public
local inquiry and on balance it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
having a further public local
inquiry.
No objection to proposed
modification.
Noted.
No objections to proposed further
modifications
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
Noted.
Noted.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
FM12
1C
New Policy : Buffer
Zones and Minerals Sites
Carter Jonas
for Grosvenor
Estate
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
Objects on the following grounds:(i)
Buffer zones, as proposed,
have the effect of limiting
mineral development thus
potentially sterilising
important reserves of
minerals for the future. They
should take into account
potential future extensions
and not just mirror existing
planning boundaries.
(i)
Disagree. In accordance with
paragraph 71 of the Aggregates
Technical Advice Note, the
purpose of a buffer zone is “to
protect land uses that are most
sensitive to the impact of mineral
operations by establishing a
separation distance between
potentially conflicting uses.”
Accordingly, it is appropriate to
use the existing permitted areas for
mineral working as the basis for
defining the buffer zones shown on
the plans accompanying the further
proposed modifications. The
Technical Advice Note indicates
that buffer zones “should be
defined from the outer edge where
extraction and processing
operations will take place” and,
where feasible, the proposed zones
take this guidance into account. In
the case of older sites, the
permission and extraction areas are
contiguous and the buffer zones
have therefore been measured from
the permission boundary. It would,
however, be inappropriate for the
buffer zones to include potential
future extensions to a mineral
working site when the area of any
extension has not yet been agreed
in detail. In the event of planning
permission being granted for an
extension to a mineral working the
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
The Local Planning Authority
proposes to change its position
somewhat in relation to ground of
objection (i) by an addition to the
policy. Therefore there has been
some acknowledgement of this
ground of objection. The
remaining grounds of
objection turn on the
interpretation of national policy
upon which there is very clear
guidance from the Welsh
Assembly Government in the
Policy documents mentioned. It
is acknowledged that not holding
a further public local inquiry
means the issues will not be
debated before an inspector,
nevertheless in view of the clear
terms of the policy and the Welsh
Assembly Government’s advice
as to how to interpret it, in reality
the benefits of having a debate
before the Inspector are slight and
in the view of the Local Planning
Authority are outweighed by the
desirability of adopting the UDP
now. On balance therefore it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
having a further public local
inquiry.
application of the buffer zone
policy could be adjusted as
necessary. However, in order to
clarify this approach, the following
addition to para 11.12 will be
made:“In view of the extensive landbank of
permitted reserves, further permissions
for extraction are unlikely within the
Plan period. However, where, subject to
compliance with other policies,
planning permission is granted to
extend a mineral working site, the
buffer zone policy will be applied to a
revised area taking into account the
minimum distances recommended in
national guidance. In the case of any
new mineral workings which might be
permitted, the distances recommended
in national guidance will be used as the
basis for defining an appropriate zone
in which this policy will be applied.”
(ii)
Existing legislation controls
the environmental impact of
noise and dust from the
mineral extraction and
processing, and vibration
from blasting. Therefore
additional controls such as
buffer zones are not
necessary.
(ii)
Disagree. The establishment of
buffer zones conforms with
national policy guidance as
contained in paragraph 40 of
Minerals Planning Policy Wales
and paragraph 70 of Minerals
Planning Policy (Wales) Tan 1:
Aggregates. While controls are
available to regulate noise , dust
and vibration levels from mineral
working, a buffer zone policy can
be applied to other new
development, which might
adversely affect a mineral
operation.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
(iii)
FM13
1C
New Policy : Buffer
Zones and Minerals Sites
Smiths Gore
for Tarmac
Central
Limited
Buffer zones should only be
used as a last resort where
existing legislation cannot
be used to protect sensitive
properties from the
environmental effects of
mineral working. They
should not be used
indiscriminately, but only
where exceptional
circumstances exist and
dictate.
Objects to the text of the new policy.
(i)
While Tarmac supports the
principle of buffer zones,
the effect of resisting new
mineral development within
such zones could be
interpreted as automatically
preventing lateral extensions
to existing permitted sites.
The possibility of this
interpretation should be
eliminated since the purpose
of buffer zones should be
to:- (a) Prevent new
sensitive development being
permitted in an area where it
may suffer loss of amenity
due to its proximity to
existing (or allocated)
mineral development; (b)
Prevent the lawful/efficient
(iii) Disagree. Paragraph 40 of Minerals
Planning Policy Wales states that
buffer zones should be included in
Unitary Development Plans “to
ensure there is unequivocal
guidance on the proximity of
mineral operations to sensitive land
uses, and that the potential impact
of existing and future mineral
workings is recognised and planned
for in the area around the mineral
operations.” While conditions to
control the effects of mineral
working can be attached to specific
permissions, the designation of
buffer zones will clarify the
planning policy position around
mineral working sites and thereby
help to prevent conflicts between
potentially conflicting land uses.
(i)
Disagree. The buffer zone policy is
not intended to automatically
prevent lateral extensions to
permitted mineral working sites.
Any proposals for such extensions
will be considered on their merits
having regard to all the relevant
Unitary Development Plan policies.
The additional sentence which will
be attached to the buffer zone
policy (see response to
representation FM12) will make
the position clear. Also it should
be noted that the Welsh Assembly
Government is content with the
minor amendment proposed as it,
in their opinion, accords with
national policy.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
The Local Planning Authority
proposes to change its position
somewhat in relation to ground of
objection (i) by an addition to the
Policy (see response to FM12(i)
above). Therefore, there has been
some acknowledgement of this
ground of objection.
operation of the approved
(or allocated) mineral
operation being prejudiced
by the presence of such
development; (c) Ensure that
proposals to extend existing
mineral development do not
erode the amenity of
existing (or allocated)
adjacent sensitive
development.
(ii)
The buffer zone policy
should thus be applied as a
development control
mechanism after the
principal strategic
judgement on whether any
particular mineral or nonmineral development is
justified or acceptable on
strategic, national, regional
or local policy grounds is
reached. UDP Policy MW2,
which addresses the issue of
future sand and gravel
extraction, would be
particularly relevant. Buffer
zones should relate solely to
the mutual protection of
mineral and non-mineral
development and should not
be used as part of the
strategic judgement.
(ii)
Noted. The buffer zones defined
on the plans attached to this
policy relate to sites (both active
and inactive) which have been
granted planning permission.
The policy has thus been
applied after the principal
judgement on whether mineral
working is acceptable has been
made. This accords with the
view expressed in this
representation. In the event of a
proposal coming forward to
extend a mineral working site,
the additional sentence referred
to above makes it clear that the
buffer zone would need to be
revised assuming the
development is acceptable on
other policy grounds.
(iii)
Tarmac’s view is rooted in
the guidance contained in
paragraph 40 of Minerals
Planning Policy Wales and
(iii) Noted. See responses above.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
In respect of grounds of objection
(ii) to (vi) it appears that the
objector and the Council are
largely in agreement and one of
the main thrusts of the objections
turns on the interpretation of
national policy upon which there
is very clear guidance from the
Welsh Assembly Government in
the relevant policy documents.
Whereas it is acknowledged that
not holding a further public local
inquiry means the issues will not
be debated before an inspector,
nevertheless in view of the clear
terms of the policy and the Welsh
Assembly Government's advice as
to how to interpret it, in reality the
benefits of having a debate before
the inspector are slight and in the
view of the Local Planning
Authority are outweighed by the
desirability of adopting the UDP
now
paragraphs 70 and 71of
Minerals Technical Advice
Note 1 : Aggregates.
Paragraph 40 opens with a
statement about the potential
for conflict between mineral
and other types of
development by reason of
possible adverse
environmental effects and
refers to the established
practice of using buffer
zones to provide areas of
protection where new
sensitive development
should be resisted. The
reference to mineral
development not being
permitted within a buffer
zone should be related to
point (c) in section (I)
above. In Tarmac’s opinion,
the guidance was not
intended to have the effect
of preventing lateral
extensions of existing
mineral operations into and
through a buffer zone where
no sensitive development
requiring protection actually
exists at the time of the
mineral application. The
only possible exception to
this may be where adjacent
land is
identified/safeguarded in the
UDP for sensitive
development in the future.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
(iv)
The interpretation of
paragraphs 70 and 71in the
Aggregates Technical
Advice Note must be
consistent with Mineral
Planning Policy Wales.
Accordingly, these
paragraphs cannot be taken
to preclude absolutely any
mineral development within
buffer zones. While the final
sentence of the proposed
modification acknowledges
that mineral development in
buffer zones should only be
resisted where it is necessary
to protect existing adjacent
non-mineral development,
this should be stated more
explicitly in the new policy.
(iv) Agreed. The proposed additional
sentence contained in the response
to representation FM12 addresses
this point.
(v)
In order to comply with the
Aggregates Technical
Advice Note, proposed
modification 1C proposes
that resources of sand and
gravel will be safeguarded
from non-mineral
development. However,
where the resource to be
safeguarded is located
within land adjacent to an
existing extraction
operation, the application of
the buffer zone policy to
prevent the lateral extension
of mineral extraction within
the buffer zone would defeat
the object of the
safeguarding policy. Such a
contradiction is absurd and
(v)
Noted. See above responses.
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
unreasonable.
(vi)
(vii)
The explanation to the
policy could also make clear
that buffer zones should be
defined precisely from the
extraction/operational
boundary of the mineral
extraction site rather than
the boundary of the planning
permission unless the two
coincide. This would be
consistent with paragraph 71
of the Aggregates Technical
Advice Note.
(vi) Noted. The buffer zones shown on
the plans attached to the proposed
policy are based on the guidance
contained in paragraph 71 of the
Aggregates Technical Advice Note.
In the case of older quarries, the
extraction and permission areas are
contiguous and it has not therefore
been possible to follow the Advice
Note guidance. However, the
proposed additional sentence to the
policy (see response to
representation FM12 above) makes
it clear that the Advice Note
recommendations will be followed
in respect of any new buffer zones
or amendments top existing zones.
The following amendments
to the proposed new policy
and its explanatory
paragraph are therefore
proposed:-
(vii) Partly agree. The Council agrees
that the wording of the policy as set
out in the proposed further
modification needs to be amended
to make it clear that extensions to
existing mineral working sites
would not be precluded. This will
achieve consistency with the
provisions of Policy MW2.
However, it is considered that the
additional sentence which will be
attached to the buffer zone policy
(see response to representation
FM12) will adequately address this
issue in a more compact form. The
Aggregates Technical Advice Note
provides detailed guidance on the
implementation of buffer zones,
including recommended widths and
the circumstance in which zones
need to be defined. In these
“Open buffer zones around
the following existing
mineral extraction sites (and
any allocated/safeguarded
mineral sites/areas) will be
established for the mutual
protection both of those sites
and of existing or allocated
non-mineral development
within which new mineral or
non-mineral development
will be resisted:
Inactive Sites
1.
Bwlchgwyn :
Bwlchgwyn Quarry
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
.
The difference between the
objector and the Council in
respect of ground of objection
(vii) is not one of intent but of
detailed wording. The Council is
content to refer to advice in the
TAN whereas the objector wants
to repeat the advice in the UDP.
It is submitted that this point is
not significant enough to justify
the holding of a further public
local inquiry.
(north)
2.
Bwlchgwyn :
Bwlchgwyn Quarry
(south)
3.
Froncysyllte : Pen
y Graig
4.
Rhos : Llwyneinion
5.
Wern : Tir Celyn
Active Sites
6.
Bronington : Fenns
Bank/Whixall
Mosses
7.
Gresford : Caia
Farm
8.
Johnstown : Hafod
9.
Llay : Ballswood
10.
Llay : Llay Main
Tip
11.
Minera : Minera
Quarry
12.
Wrexham : Borras
Airfield
The existence of buffer zones
will not preclude the
extension of existing
quarries where such
extension otherwise meets
national, regional and local
policies on mineral
extraction. Buffer zones
shall be no less than 100
metres and 200 metres for
sand/gravel and crushed
rock respectively unless
there are clear and
justifiable reasons for
reducing the distance.”
circumstances, it is considered
unnecessary to include such details
in the Unitary Development Plan
policy and its supporting
paragraph.
The explanation for the
policy should then read:
“There is often conflict
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
between mineral workings
and other land uses resulting
from the environmental
impact of noise, dust and
vibration from mineral
extraction on the one hand
and the ability of the mineral
operation to operate
efficiently on the other.
Establishing and retaining
open buffer zones around
both inactive and active
mineral sites will provide
mutual protection against
such conflicts. New, nonminerals development (e.g.
housing, schools, etc.) which
would be sensitive to any
adverse impact of existing
(or allocated/safeguarded)
minerals extraction or
development, or new mineral
extraction that would
significantly and
detrimentally affect existing
(or allocated) adjacent nonmineral development will
therefore be resisted within
such zones. Narrower buffer
zones may be acceptable
where it can be established
that, as a result of other
means of control, the impact
from the mineral extraction
site is acceptable by
reference to prevailing
environmental standards
and guidance.
Buffer zones should be
defined from the outer edge
of the area where extraction
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Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
and processing operations
will take place, including
site haul roads, rather than
the site boundary, as there
may be land within site
boundaries where mineral
activities are limited or no
operations are proposed so
that the impact of the
proximity of such land is
negligible.”
(viii)
FM14
1C
New Policy : Buffer
Zones and Minerals Sites
RMC (UK) for
RMC
Northern
(i)
Although the UDP does not
contain any mineral
allocation or safeguarded
areas, reference in the above
submission to such areas is
made in order to be even
handed in relation to the
protection of any nonmineral development which
may be allocated in the UDP
- i.e. applications for nonallocated mineral
development in buffer zones
should not be resisted by
virtue of this policy on the
grounds that it is necessary
to protect potential nonmineral development which
is also not allocated or does
not enjoy favourable policy
presumption.
Objects to the proposed new
policy because the wording
effectively prohibits any
extensions to the identified
quarries. This is in direct
conflict with Policy MW2 of
the Unitary Development
Plan which, in exceptional
(viii)
Noted.
It is also submitted that ground of
objection (viii) is not significant
enough to justify the holding of a
further pubic local inquiry.
On balance, therefore, so far as
objection FM13 is concerned, it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
holding a further public local
inquiry.
(i)
Disagree. The buffer zone
policy has been put forward to
comply with national guidance.
It protects existing mineral sites
from being affected by new
sensitive development in
addition to safeguarding
adjoining areas from any
20
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
Similar considerations apply to
those mentioned under objection
FM13 above. So far as ground of
objection (ii) is concerned this
would not be resolved at a further
UDP inquiry because it relates to
a current planning application and
whether or not planning
circumstances in order to
meet a landbank deficit,
allows extensions to
extensions to existing sand
and gravel workings. Under
other circumstances, Policy
MW2 prohibits new sites. It
is considered that the policy
regarding buffer zones is too
restrictive. If a proposed
extension to a quarry
complies with all of the
other policies contained
within the Unitary
Development Plan in terms
of protecting amenity and
environment, then the site
should be granted planning
permission and
environmental issues
covered by planning
conditions.
(ii)
The proposed buffer zone
around Ballswood Quarry
would effectively sterilise
approximately 2.5 hectares
of the proposed extension
area which is subject to a
current planning application.
This is where the mineral is
deepest. In addition, the
extension would become
more detached from the
quarry and would no longer
be adjacent to the existing
workings. The policy as it
stands effectively prohibits
joining the sites by a haul
road as this would be sited
within the buffer zone.
potentially adverse impacts due
to mineral working. The policy
would not prevent extensions to
sand and gravel workings where
these might be justified under
the provisions of Policy MW2.
The additional sentence which
the Council proposes to attach
to the policy (see Response to
representation FM12 ) will
clarify this point.
(ii)
Disagree. The current planning
application for sand and gravel
extraction on land near
Ballswood Quarry will be
determined on its merits having
regard to all the relevant
Unitary Development Plan
policies. The existence of a
buffer zone around the existing
quarry will not prejudice the
consideration of any new
proposals for mineral extraction
in the vicinity. At this stage, it
would be inappropriate to
extend the buffer zone as it is
not known whether planning
permission for the current
application will be granted.
21
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
permission is granted will be
determined as part of that process.
This head of objection is therefore
related to an individual planning
application and it is not
appropriate for a UDP inquiry to
consider individual planning
applications. On balance therefore
it is concluded that the public
interest is best served by
proceeding to adopt the UDP now
rather than having a further public
local inquiry.
(iii)
FM15
1C
New Policy : Buffer
Zones and Minerals Sites
Welsh
Assembly
Government
It is therefore suggested that
the policy be amended as
follows:
“In order to minimise the
impact of minerals
development, buffer zones of
an appropriate distance will
be required between the
development and the
following:
(a)Existing or permitted
dwellings in a town, village
or settlement, consisting of
20 or more closely grouped
dwellings;
(b) Other sensitive land
uses;
(c) An area allocated within
the UDP for residential or
other sensitive land uses.
The width of the buffer zone
will be determined having
regard to the potential
impact of the development
and the nature of the site or
the existence of physical
features capable of reducing
the impact of the
development.
In addition, buffer zones will
be required around existing
mineral sites to prohibit the
siting of new sensitive nonmineral development
adjacent to existing mineral
sites.”
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
(iii)
Disagree. The Council
considers that the policy
wording put forward in the
proposed further modification
(as amended by the additional
sentence referred to in the
response to representation
FM12) would more precisely
define the scope and purpose of
the buffer zones. The
Aggregates Technical Advice
Note provides further guidance
on this matter and the inclusion
of further details relating to the
size of settlements and the
width of buffer zones is
considered unnecessary.
Noted.
22
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
FM16
1C
New Policy : Buffer
Zones and Minerals Sites
Sesswick
Community
Council
FM17
1C
New Policy : Buffer
Zones and Minerals Sites
Klaus
Armstrong
Braun :
Flintshire
Green Party
FM18
1C
FM19
2A
New Policy : Buffer
Zones and Minerals Sites
Paragraph 11.13
Waste Management
Mrs D Pearson
Rossett
Sesswick
Community
Council
FM20
2A
Paragraph 11.13
Welsh
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
The maps relating to individual
quarries do not contain details of the
minerals obtained there and this
information would be helpful.
Disagree. It is unnecessary to identify
each mineral extracted from the sites
where it is proposed to apply the buffer
zone policy. To do so would
unnecessarily complicate the Unitary
Development Plan Proposals Maps for
no apparent policy benefit.
It is submitted that this point is
not significant enough to justify
the holding of a further public
local inquiry and on balance it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
having a further public local
inquiry.
Objects to the inclusion of a buffer
zone at Borras Airfield in the list of
active sites. The site should be
included in the list of inactive sites
Disagree. Borras Airfield is still an active
site. The objector appears to have
confused the site’s location with adjacent
land (formerly part of Borras Farm and
previously subject to sand and gravel
extraction) which has now been restored
following completion of mineral
extraction. It is therefore appropriate to
apply the buffer zone policy to Borras
Airfield.
This objection raises a purely
factual issue in terms of location
which has been explained to the
objector.
The holding of an inquiry to
consider a factual issue of this
sort is not deemed appropriate.
On balance therefore the public
interest is best served by
proceeding to adopt the UDP now
rather than having a further public
local inquiry.
No objections to proposed further
modifications
The Council welcomes moves
towards a more sustainable approach
to waste management and the
reduction of landfill. However, it is
concerned that the European
Directives should be considered
mandatory and not merely advisory
when future policy decisions are
made.
The lack of a policy or text dealing
Noted.
Noted.
Partly agree. There have been
23
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
Waste Management
FM21
2A
FM22
2B
Paragraph 11.13
Waste Management
Policy MW12 : Waste
Management Facilities
Assembly
Government
Mrs D Pearson
Rossett
Smiths Gore
for Tarmac
Central
Limited
with special waste was referred to in
the Assembly’s previous objections
and the Environment Agency has
noted that this does not appear to be
covered in the proposed
modifications. The plan text does
refer in paragraph 11.13 to the
objective being “to provide a
planning framework which enables
adequate provision to be made
for…….the particular needs in
respect of hazardous and other
wastes which require special
treatment.” It is considered that the
reasoned justification, at least should
make some further reference as to
how planning for this type of waste
will be handled.
No objections to proposed further
modifications
Objects to the proposed modification
of Policy MW12. It is considered
important that the location of mineral
extraction sites should not be
overlooked or discounted as
appropriate for the sorting and
recycling of waste, particularly
construction and demolition waste
and development arisings. Such
locations are often remote from
incompatible land uses, well served
by existing operational and transport
infrastructure (such as weighbridges
and crushing/screening plant) and can
be used as sites for the beneficial use
and disposal (as restoration material)
of the residual materials generated
from the recycling process.
discussions with the objector and the
following wording, as an addition to
paragraph 11.15 (the supporting
justification for the Unitary Development
Plan’s Waste Management Policy):has been agreed to resolve the objection:
“The Welsh Assembly Government
stated in May 2004 that an early review
of the Regional Waste Plans, in relation
to the land use provision of sites for
managing hazardous waste, will be
undertaken as a matter of urgency to
provide a sound basis for local planning
authorities in preparing their Unitary
Development Plans and determining
planning applications. However, until
this review is completed, it would not be
appropriate for the Unitary
Development Plan to set out further
detailed guidance on this issue.”
Noted
Disagree. The wording of the supporting
paragraph as set out in the proposed
further modification does not preclude
the use of mineral working sites for
waste management purposes. The
paragraph indicates that the most
appropriate locations for sorting,
transferring and processing waste are
those on industrial estates. However, it
also makes clear that certain types of
waste management facilities are unsuited
to an industrial estate location by reason
of space requirements, incompatibility
with adjoining uses and inconvenience to
communities. Sites for these facilities
will therefore be permitted outside
industrial estates. Subject to complying
with the Plan’s waste management,
24
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
The objection does not raise a
difference of principle but a
difference of emphasis in wording
of the UDP. Any potential benefit
to be gained from holding a
further inquiry is slight when
weighed against the desirability of
having an adopted UDP. On
balance therefore the public
interest is best served by
proceeding to adopt the UDP now
rather than having a further public
local inquiry.
FM23
2B
Policy MW12 : Waste
Management Facilities
Welsh
Assembly
Government
FM24
2B
Policy MW12 : Waste
Management Facilities
Sesswick
Community
Council
FM25
2B
FM26
2C
Policy MW12 : Waste
Management Facilities
Paragraph 11.11
Mrs D Pearson
Rossett
Sesswick
Accordingly, it is considered that
some flexibility should be built into
the policy wording and into the
supporting paragraph to permit the
use of such locations for waste
management.
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
In view of the emergence of the
North Wales Regional Waste Plan, a
wider explanation of the phrases “the
proximity principle” and “regional
self-sufficiency” is required within
the Unitary Development Plan. This
would help to address the
considerable public concern that once
a major waste disposal facility has
been established by a local authority
it would be used to dispose of waste
produced outside that authority’s
boundaries. These sites should be
distributed as evenly as possible
throughout North Wales. The Council
therefore considers that the inclusion
of a sentence ruling out the
possibility of the importation of
cross-border waste would be
beneficial.
No objections to proposed further
modifications
(i)
The Council generally
waste disposal and other relevant
policies, a mineral working site might
therefore be suitable for waste
management in accordance with the
objectors point.
Noted.
Partly agree. An explanation of the
meaning of the proximity principle has
already been included in the supporting
paragraph to Policy MW12. However,
the following sentence will will be added
to explain the term regional self
sufficiency:“Regional self sufficiency requires that
most waste should be treated or
disposed of within the region where it is
generated.”
It would be inappropriate to include in
the Plan a blanket presumption against
cross-border treatment of waste. There
may, for example, be circumstances
where it would be preferable for a
specialised facility for treating certain
types of waste treatment to be
established in a central location serving a
wider area than one local authority.
Each planning application would need to
be considered on its merits having regard
to the other policies in the Plan.
Noted.
(i)
Noted.
25
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
As with objection FM22 this
objection does not give rise to a
difference of principle but rather a
difference of emphasis. Again
therefore any potential benefit to
be gained by holding a further
inquiry is slight when weighed
against the desirability of having
an adopted UDP. On balance
therefore the public interest is
best served by proceeding to
adopt the UDP now rather than
having a further public local
inquiry.
Community
Council
welcomes the revised
wording as an improvement
to the policy, but considers
that it comments with regard
to further modification 2B
on the relationship between
the North Wales Regional
Waste Plan and the Unitary
Development Plan apply to
this modification as well.
(ii)
FM27
2C
Paragraph 11.11
Welsh
Assembly
Government
FM28
2D
Paragraph 11.1
Sesswick
Community
The Council objects to the
assumption that a waste
disposal facility can be built
on any general use industrial
estate. Consideration must
be given to the processes
already in existence and the
problems that will arise from
the combination of different
types of pollutants. The
Council objects to the
principle of allowing the
construction of a waste
disposal facility on an
industrial estate where there
are already a number of
businesses in food
manufacturing or food
processing.
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
The Council supports the proposed
further modification.
(ii)
Disagree. Paragraph 11.1
indicates that the most
appropriate locations for
sorting, transferring and
processing wastes are on
general industrial estates. This
is because the operations
involved are similar to many
industrial processes. However,
any proposals for waste
management facilities will need
to comply with other policies in
the Plan and the effects upon
adjoining development would
be a material consideration in
determining a planning
application.
Noted.
Noted.
26
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
The same considerations and
conclusions apply as set out in
respect of objection FM24.
FM29
2D
Paragraph 11.1
FM30
2D
Paragraph 11.1
FM31
3A
Policy MW9 :
Protection of Mineral
Resources
Council
Welsh
Assembly
Government
Mrs D Pearson
Rossett
Carter Jonas
for Grosvenor
Estate
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
No objections to proposed further
modifications
Objects to Policy MW9 on the
following grounds:(i)
Safeguarded areas should
not be limited to sand and
gravel and clay. Other
minerals, such as limestone
and silica sandstone, should
be safeguarded from nonmineral development in
order to prevent the
sterilisation of future
resources. As a minimum,
existing planning consents
and potential future
extensions to these sites
should be safeguarded by
the plan.
Noted.
Noted
(i)
Disagree. The areas of sand and
gravel and clay reserves to be
safeguarded in the Plan reflect
the advice contained in Mineral
Planning Policy Wales. This
relates to mineral deposits
which society may need.
However, in the case of other
minerals, the Council considers
that there is no clear
requirement to safeguard
reserves during the plan period.
In particular, paragraph 11.4 in
the Unitary Development Plan
makes it clear that, given the
extent of crushed rock reserves
elsewhere in North Wales and
the likely severe detrimental
environmental impact of
quarrying locally, it is
unnecessary and undesirable to
provide for further crushed rock
quarrying in the County
Borough during the Plan period.
In addition (see further
modification 1B) the Council
proposes to issue prohibition
27
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
The point raised by this objection
has essentially been covered by
the Inspector at the UDP inquiry
already held. The issue of whether
minerals should be safeguarded
was considered at paragraphs
11.62 – 11.68 of the Inspector’s
report. Therefore no benefit
would be derived from reiterating
what has already been said by
holding a further inquiry.
orders preventing the
resumption of mineral working
at specified silica sand and
limestone sites which are
subject to existing planning
consents. In these
circumstances, it would now be
inappropriate to include such
sites in a safeguarding area.
(ii)
FM32
3A
Policy MW9 : Protection
of Mineral Resources
Smiths Gore
for Tarmac
Central
Limited
(i)
A proven reserve of
limestone at Park Farm,
Minera, which was the
subject of a planning
application in 1993 and
subsequently withdrawn in
September 1996, should be
included in the plan as a
safeguarded area in order to
prevent sterilisation in the
future.
Objects to the proposed
modification of Policy
MW9. The second sentence
should read:- “The
identification of mineral
resource areas gives no
presumption in favour of
mineral development. Within
such areas, non-mineral
development will be strongly
resisted unless a resource
assessment (or other
information) is provided to
demonstrate that no
exploitable resources exist
within the development
site.”
(ii)
See response to FM3(i) above.
(i)
Agree. The proposed rewording
will clarify the intention of the
Policy and the amendment will
therefore be made as suggested.
i.e. to the third sentence delete
“In practice, proposed
development…”. and add
“Within such areas non
mineral development…”
28
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
(ii)
The proposed modification
makes no attempt to identify
any such safeguarded areas.
It is, however, suggested
that where information
already exists concerning
the nature, quality and
extent of mineral resources
evidenced by its
incorporation into a formal
application for planning
permission for their
extraction, those resources
should be identified in the
UDP under this policy for
the sake of transparency and
certainty. Such an area
comprises the land known as
Holt Estate (adjacent to
Tarmac’s Borras Quarry)
which is the subject of a
current application to extract
some 14 million tonnes of
mineral. This proposal is
accompanied by a full
geological report and
environmental statement.
(ii)
Disagree. The map attached to
the proposed further
modifications shows the sand
and gravel safeguarding area to
which Policy MW9 will apply.
It is based upon published
research information and
includes the land at Holt Estate,
together with other areas which
have been the subject of
previous planning applications.
The objector’s concerns are
therefore met. In these
circumstances, no further
changes to the defined
safeguarding area are
considered necessary.
(iii)
It is noted and accepted that
the identification of
safeguarding areas carries
no presumption of
permission, but equally it
would protect the resource
from sterilisation by
potential non-mineral
sensitive development (as
referred to in the new buffer
zone policy contained in
proposed modification 1C).
This is consistent with
(iii)
Noted.
29
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
This objection raises an issue of
fact which can be resolved by
looking at the relevant map and
consequently the holding of a
further inquiry could not be
justified.
FM33
3A
Policy MW9 : Protection
of Mineral Resources
Welsh
Assembly
Government
FM34
3A
Policy MW9 : Protection
of Mineral Resources
Sesswick
Community
Council
FM35
3A
Policy MW9 : Protection
of Mineral Resources
Salisbury Park
Action Group
Tarmac’s view that buffer
zones are intended primarily
for the site-specific mutual
protection of existing and
proposed mineral and nonmineral development and
not for making judgements
on strategic policy principles
such as whether a lateral
extension to an existing
mineral operation should be
permitted.
The Welsh Assembly Government is
satisfied that its earlier objections
have been duly taken into account
and that further modifications have
been brought forward which meet
fundamental concerns. The previous
objections are withdrawn and the
modifications currently proposed are
supported.
It is considered that the map showing
the proposed minerals safeguarding
area should contain details of the
minerals obtained. In addition, it
would be beneficial if a statement of
the likelihood of an increased need
for these minerals was included in the
Unitary Development Plan.
Objects to the proposed further
modification. The map indicating the
proposed minerals safeguarding areas
is inaccurate. It shows minerals (e.g.
clay, peat, limestone etc) other than
only the sand and gravel deposits
allegedly indicated. Furthermore, the
map shows insufficient detail
between the close association
between settlement limits and known
Noted.
Disagree. It is unnecessary to show
details of individual mineral working
sites on the Unitary Development Plan
Proposals Map. The purpose of the
proposed modification to the policy is to
define safeguarding area for the future.
It is submitted that this point is
not significant enough to justify
the holding of a further public
local inquiry and on balance it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
holding a further public local
inquiry.
Noted. The map accompanying the
proposed modification to Policy MW9 is
derived from published national survey
information. While the areas identified
include a range of minerals, the purpose
of the plan is to identify safeguarding
areas for the key reserves which society
may need. Should the proposed further
modification to Policy MW9 be
approved, the safeguarding areas will be
As mentioned in the response the
proposed modification is derived
from published national survey
information. The objection has
been noted and the safeguarding
areas will be defined at a larger
scale as stated. The objection is
not therefore considered to be
significant enough to justify the
holding of a further public local
30
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
FM36
3A
Policy MW9 : Protection
of Mineral Resources
Mrs D Pearson
Rossett
Table B
Ref
OR1
Further Proposed
Modification Number
Not Applicable
OR2
Not Applicable
minerals deposits and is therefore
difficult to interpret. A larger scale
map is needed or the existing map
should be superimposed on the
Unitary Development Plan Proposals
Map(s).
defined at a larger scale on the main
Proposals Map and on the relevant
Insets.
No objections to proposed further
modifications
Noted
inquiry and on balance it is
concluded that the public interest
is best served by proceeding to
adopt the UDP now rather than
holding a further public local
inquiry.
INVALID REPRESENTATIONS
Policy
Representor
Representation Summary
Council’s Response
This is not a valid objection. At this stage of
the UDP process, objections must relate to the
Further Proposed Modifications as placed on
deposit by the Council from June 4 until July
16, 2004. The objection to the inclusion of the
land in question within the settlement
boundary of Cross Lanes was carefully
considered by the UDP inquiry inspector, and
he recommended that no modification be
made to the settlement boundary of Cross
Lanes as a result of the objection. The Council
agreed in June 2003 to agree with the
Inspector’s recommendation. It would not be
appropriate for the Council to re-open the
issue at this stage. The Council has fully
complied with statutory procedures in respect
of this issue.
This is not a valid objection. At this stage of
the UDP process, objections must relate to
the Further Proposed Modifications as
placed on deposit by the Council from June
4 until July 16, 2004. This objection relates to
Approved Policy
PS1 :
Land at Cross
Lanes
Mr R While
Cross Lanes
Strongly objects to the way in which the consultation
Procedure is conducted. There have been dramatic
Changes in developments since the public inquiry.
The Council should review its decision to extend the
settlement limit of Cross Lanes to include the land
fronting Bedwell Road to the north of Bedwell
Crescent. The Council should, even at this late stage,
ignore the Inspector’s recommendation and use its
powers to reverse its decision. Unless present
procedures are changed the whole consultative
process will be seen by many as an expensive waste
of time and public funds.
Approved Policies
PS1 and H1 :
Land at Quarry
Road, Glynceiriog
Balfours for
Mrs E Taylor
Objects to deletion of housing allocation and deletion
of site from settlement limits:
 The site was considered by the Council to be
suitable for housing in the past;
31
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
 There has been no strategic or other change that
would cause the site to be considered unsuitable for
housing since the Glyndwr Local Plan or the first
version of the UDP;
 The appeal inspector made no comments on the
strategic land use issue;
 The only reason the appeal inspector gave for
refusing consent was the proposed access. There was
no adverse comment about the suitability of the site
to accommodate a house.
It is not necessary to allocate the site for housing .
If the development boundary were to remain as
shown in the Glyndwr Local Plan and as originally
envisaged in the UDP, the site would be located
within the development boundary, and could be
regarded as a windfall site if suitable access to the
land could be obtained.
The Council wishes to know the reason for the
deletion of the Quarry Road site from the Unitary
Development Plan
OR3
Not Applicable
Approved Policies
PS1 and H1 :
Land at Quarry
Road, Glynceiriog
Llansantffraid
Glynceiriog
Community
Council
OR4
Not Applicable
Mrs J Creed
Rossett
Supports the decision to remove the housing land
allocation at Alyn Drive, Rossett and exclude the site
from the settlement limit.
OR5
Not Applicable
Approved Policies
PS1: Settlement
Limits, EC1 :
Green Barriers
and EC5 : Special
Landscape Areas
Approved Policy
EC2 :
Agricultural Land
Welsh Assembly
Government
Notwithstanding the Inspector’s findings, it would be
Preferable if there could be a minor amendment to
clarify the policy wording to make it more consistent
with the reasoned justification and with Planning
Policy Wales. This could avoid problems associated
with different interpretations of the relevant policies
in the future.
a Proposed Modification to the UDP, as
placed on deposit by the Council between
July 30 and September 12, 2003. Objections
to Proposed Modifications have already
been considered by the Council, and the
Council’s response has been formally agreed.
The land was excluded from the settlement
limit because it was considered unsuitable for
development because of access and
topographical constraints. No objections were
received to the deletion of the site and a
subsequent appeal against the refusal of
planning permission for residential
development was dismissed.
Noted. However, this representation concerns
a matter which has already been resolved at a
previous stage of the preparation of the
Unitary Development Plan.
This is not a valid objection. At this stage of
the UDP process, objections must relate to
the Further Proposed Modifications as
placed on deposit by the Council from June
4 until July 16, 2004.
This objection relates to a Proposed
Modification to the UDP, as placed on
deposit by the Council between July 30 and
September 12, 2003. Objections to Proposed
Modifications have already been considered
32
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004
OR6
Not Applicable
Approved Policy
CLF5 : Open
Space within
Residential
Developments
Maelor South
Community
Council
Concerned that insufficient public open space is
being provided within the proposed residential
development on part of the former Penley Hospital.
OR7
Not Applicable
Approved Policy
T6 :
Primary and Core
Highway Network
Salisbury Park
Action Group
Objects to Council rebuttal regarding the
timing/legitimacy of objection for the following
reasons:
 Objection was heard at the inquiry, and it is
therefore legitimate for continuation;
 The fact that the Council’s inquiry representative,
the Inspector, and the Inspector’s report all “concur
that it would be helpful if road numbers were put on
the Proposals Map” indicate agreement, and
therefore the need to make an Inspector’s report
modification recommendation is unnecessary;
 Such inclusion would clarify requisite highway
implications in relation to planning considerations
(e.g. visibility splays, highway management etc)
Amend accordingly.
by the Council, and the Council’s response
has been formally agreed.
The Plan contains a policy (CLF5) requiring
all new housing developments to provide
public open space (including playing fields
and children’s play areas) to the specified
Council standards. The outline planning
permission for the former hospital site
includes an appropriate condition to ensure
that these standards are met.
This is not a valid objection. At this stage of
the UDP process, objections must relate to
the Further Proposed Modifications as
placed on deposit by the Council from June
4 until July 16, 2004. This objection relates to
a Proposed Modification to the UDP, as
placed on deposit by the Council between
July 30 and September 12, 2003. Objections
to Proposed Modifications have already
been considered by the Council, and the
Council’s response has been formally agreed.
33
Wrexham Unitary Development Plan : Proposed Further Modifications : Representations and Responses : November 2004