West Water Supplies Project – Transfer United Utilities plc

Planning, Design and Access Statement

Revision | 1

24 March 2016

Planning, Design and Access Statement

West Cumbria Water Supplies – Thirlmere Transfer

Project no: B2707061 Document title: Planning, Design and Access Statement Revision: 1 Date: 24 March, 2016 Client name: United Utilities plc

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Contents Executive Summary ...... vii 1. Background and Approach ...... 1 1.1 Introduction ...... 1 1.2 Need for the Scheme ...... 1 1.3 Alte rnatives / Evolution of the scheme ...... 2 1.4 The Scheme ...... 2 1.4.1 The Main Elements...... 2 1.4.2 Decommissioning ...... 3 1.4.3 Other Scheme Elements ...... 4 1.5 Environmental Mitigation ...... 5 1.5.1 Approach to Mitigation ...... 5 1.5.2 Construction Code of Practice ...... 6 1.6 Consultation ...... 6 1.7 Planning Policy Context ...... 6 1.7.1 Development Plans ...... 6 1.7.2 National Planning Policy Framework (NPPF) ...... 7 1.7.3 Planning Practice Guidance (PPG) ...... 8 1.8 Statement Structure...... 8 2. The National Park ...... 9 2.1 Sch eme Description ...... 9 2.2 Planning Applications along the Route ...... 16 2.3 Planning Policy Assessment ...... 16 2.3.1 Context ...... 16 2.3.2 Lake District National Park - World Heritage Site Application ...... 17 2.3.3 Development Plan ...... 17 2.3.4 Supplementary Planning Documents (SPDs) ...... 17 2.3.5 National Park Management Plan ...... 18 2.4 The English National Parks and the Broads: UK Government Vision and Circular 2010...... 18 2.5 Major Development within the National Park ...... 18 2.6 Allocations / Designations ...... 21 2.7 Planning Assessment ...... 23 2.7.1 Introduction ...... 23 2.7.2 Landdscape and Visual Assessment ...... 24 2.7.3 Arboriculture ...... 25 2.7.4 Water Environment ...... 27 2.7.5 Flood Risk ...... 27 2.7.6 Eco logy and Nature Conservation ...... 28 2.7.7 Cultural Heritage ...... 29 2.7.8 Soils Geology and Hydrogeology ...... 30 2.7.9 Mateerials and Waste ...... 31

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2.7.10 Public Access and Recreation ...... 32 2.7.11 Socio Economic ...... 32 2.7.12 Agriculture and Sporting Land Use ...... 33 2.7.13 Traffic and Trans port...... 34 2.7.14 Noise and Vibration ...... 35 2.7.15 Air Quality and Odour ...... 36 2.7.16 Summary of Consultation in the Lake District National Park ...... 37 2.8 Design and Access ...... 38 2.8.1 Bridge End WTW - Connection Works ...... 38 2.8.2 RWA and Associated Infrastructure ...... 38 2.9 Summary ...... 39 3. Allerdale Borough Council ...... 40 3.1 Sch eme Description ...... 40 3.2 Planning Applications along the Route ...... 49 3.3 Planning Policy Assessment ...... 49 3.3.1 Planning Policy Context ...... 49 3.4 Allocations / Designations ...... 49 3.5 Planning Assessment ...... 50 3.5.1 Landdscape and Visual ...... 50 3.5.2 Arboriculture ...... 51 3.5.3 Water Environment ...... 53 3.5.4 Flood Risk ...... 54 3.5.5 Eco logy and Nature Conservation ...... 54 3.5.6 Cultural Heritage ...... 55 3.5.7 Soils, Geology and Hydrogeology ...... 56 3.5.8 Mateerials and Waste ...... 57 3.5.9 Public Access and Recreation ...... 58 3.5.10 Socio Economics ...... 59 3.5.11 Agriculture and Sporting Land Use ...... 59 3.5.12 Traffic and Trans port...... 60 3.5.13 Noise and Vibration ...... 61 3.5.14 Air Quality and Odour ...... 62 3.6 Consultation ...... 63 3.7 Design and Access ...... 64 3.7.1 New Water Treatment Works Site (WTW) ...... 64 3.7.2 New Service Reservoir – Moota Hill ...... 69 3.7.3 New Pumping Station Site – Harrot Hill...... 70 3.8 Summary ...... 71 4. Copeland Borough Council ...... 72 4.1 Sch eme Description ...... 72 4.2 Planning Applications along the Route ...... 76

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4.3 Planning Policy Assessment ...... 76 4.3.1 Planning Policy Context ...... 76 4.3.2 Allocations / Designations ...... 76 4.4 Planning Assessment ...... 77 4.4.1 Landdscape and Visual Assessment ...... 78 4.4.2 Arboriculture ...... 79 4.4.3 Water Environment ...... 80 4.4.4 Flood Risk ...... 81 4.4.5 Eco logy and Nature Conservation ...... 82 4.4.6 Cultural Heritage ...... 83 4.4.7 Soils, Geology and Hydrogeology ...... 84 4.4.8 Mateerials and Waste ...... 84 4.4.9 Public Access and Recreation ...... 85 4.4.10 Socio Economics ...... 86 4.4.11 Agriculture and Sporting Land Use ...... 86 4.4.12 Traffic and Trans port...... 87 4.4.13 Noise and Vibration ...... 88 4.4.14 Air Quality and Odour ...... 89 4.5 Consultation ...... 90 4.6 Design and Access ...... 91 4.6.1 High Leys Service Reservoir and Pumping Station...... 91 4.7 Summary ...... 92 5. Sustainability Summary ...... 93 5.1 Background...... 93 5.2 Landdscape ...... 94 5.3 Water Resources ...... 94 5.4 Eco logy and Nature Conservation ...... 94 5.5 Built and Historic Environment ...... 94 5.6 Waste Management...... 94 5.7 Socio-Economic ...... 95 5.8 Community Impacts ...... 95 5.9 Energy Manage ment...... 95 5.10 Climate Change Mitigation and Adaptation ...... 95 5.11 Sustainable Procurement ...... 96 5.12 Compensatory Tree Planting ...... 96 6. Construction and Phasing of the Scheme ...... 98 6.1 Construction Phases ...... 98 6.2 Standard Construction Techniques and Management ...... 98 6.3 Surplus Material ...... 100 7. Conclusions ...... 101

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Appendix A. Application Documentation Appendix B. Unilateral Undertaking – Heads of Terms

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Executive Summary Planning, Design and Access Statement 1) This combined Planning Statement and Design and Access Statement (PDAS) has been prepared to accompany the submission of full planning applications for the proposed West Cumbria Water Supplies Project – Thirlmere Transfer. 2) The Proposed Scheme comprises various sections of pipeline and associated water supply infrastructure that extend over a distance of approximately 100 km from Thirlmere Reservoir, in the Lake District National Park, into the boroughs of Allerdale and Copeland. Planning applications are being submitted to each of the three authorities through which the scheme passes. 3) The need for the Proposed Scheme is based on addressing the loss of current water sources in West Cumbria, to enable the Ennerdale abstraction licence to be revoked by 2022, and to ensure an adequate supply-demand balance to reduce the risk of loss of supply and provide a resilient water supply for the future. Following an Examination in Public of United Utilities’ Water Resources Management Plan in September 2014, the Secretary of State concluded that transferring water to West Cumbria from Thirlmere Reservoir was the most sustainable option. 4) Community involvement and stakeholder engagement has been central to the development of the water supply strategy for West Cumbria. In line with United Utilities’ commitment to community involvement, local people and stakeholders have been encouraged to have their say on the plans. A summary of the stakeholder engagement undertaken is provided for each local authority. 5) The PDAS forms an integral part of the application submission and should be read in conjunction with the other plans and documentation that together form the complete planning application submission, including the Environmental Statement and Statement of Community Involvement. It is not intended to duplicate the content of the other documents and focuses instead on assessing the scheme against relevant planning policies. It also discusses the design approach taken in the development of the proposed scheme. 6) The environmental impacts of the proposed scheme components have been assessed against the detailed planning objectives of the NPPF and the relevant policies of the respective Local Plans. The PDAS recognises that although the construction of a project of this scale in an area such as West Cumbria and the Lake District National Park would involve a degree of disruption to both people and the environment, the development of the scheme along with the mitigation and compensation proposals ensure that the impacts would be largely temporary and acceptable in planning policy terms. The proposals provide for a resilient, sustainable water supply to serve the needs of West Cumbria. Scheme Selection and Consultation 7) United Utilities has a statutory duty to provide adequate water supplies for its region including West Cumbria. The Water Resources Management Plan (March 2015) describes the assessment that was undertaken of the available water supplies and the demand for water over the 2015 – 2040 period. The plan also sets out the proposed strategy for water resources and demand management to ensure that an adequate water supply is available to serve the region. 8) Due to the revocation of the Ennerdale Water abstraction licence as a result of the EC Habitats Directive, and a requirement to protect ’s largest population of freshwater mussels (in the River Ehen below the lake), United Utilities needs to provide an alternative water source for West Cumbria to enable the licence to be revoked by 2025. 9) A high level, strategic optioneering process to address the supply/demand deficit in West Cumbria concluded that the existing Thirlmere reservoir was the most appropriate preferred supply solution for this area. This was confirmed following an Examination in Public which took place in September 2014. Since then the Proposed Scheme has been subject to an options appraisal and selection process, which was influenced by an extensive consultation process and a Planning Performance Agreement group with all the local authorities involved, and key consultees - the Environment Agency, Natural England and Cumbria County Council. This iterative consultation process has helped shape the proposal that is currently the subject of the planning applications (one for each LPA concerned).

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The Proposed Scheme 10) For the purposes of the PDAS and the ES, the scheme has been divided into 20 sections to enable a clearer understanding of the project components, and to facilitate reviewing the project’s environmental effects at particular locations. 11) The West Cumbria Water Supplies project commences with a new connection point at the existing Bridge End water treatment works (WTW) below Thirlmere Reservoir in the Lake District National Park. The raw water is then piped along a Raw Water Aqueduct to a proposed WTW near Hags Wood in Allerdale. From the WTW a new network main extend northwards to connect into the existing distribution network at Quarry Hill via a new service reservoir at Moota Hill. The route extends southwards, via a new pumping station at Harrot Hill and new service reservoir at High Leys, to the existing Summergrove and Kelton Fell Service Reservoirs in Copeland. The route also extends westwards to the existing Stainburn Service Reservoir and eastwards to the existing distribution network at Cornhow, where the existing mains are reused where possible through slip-lining (a new smaller pipe inside the existing larger pipe) rather than laying a new main. 12) Some of the existing facilities would be used as part of the new water supply scheme whilst others would be decommissioned. Consultation 13) A Statement of Community Involvement (SCI) has been prepared to support the planning applications. The SCI explains how the applicant has consulted extensively with key stakeholders and the local community from option development to the final scheme for which planning permission is now sought. 14) The Proposed Scheme has developed in conjunction with extensive stakeholder and community consultation. Regular liaison has taken place with the local planning authorities and statutory consultees Three phases of public consultation have been held involving public exhibitions, displays at agricultural shows, meetings with parish councils and other key stakeholders. 15) Both the SCI and the ES explain how feedback from the consultations with both statutory and non-statutory stakeholders has been considered and incorporated into the environmental assessment and scheme design process. Environmental Effects 16) A scheme of this scale and nature would inevitably have impacts on the surrounding environment and an Environment Impact Assessment (EIA) has been undertaken to accompany the planning applications in the form of an Environmental Statement (ES). The EIA has addressed the following topic areas:  Landscape - The Landscape and Visual Impact Assessment has recognised that significant effects would result from both the construction and operation of the Proposed Scheme, through the introduction of new infrastructure into mainly rural landscapes. However, a series of measures has been identified to ensure that the impact of the Proposed Scheme on local landscapes is minimised, and enhanced where possible, during both construction and operation  Arboriculture – The Proposed Scheme has been designed to avoid environmental constraints where practicable, but both individual trees and woodlands would be affected. Some of these trees have been categorised as veterans, others form examples of ancient woodland or are located in Conservation Areas. Other specimens covered by Tree Preservation Orders would not be affected. Mitigation planting within the planning application boundary and compensation planting at a designated location in the Ennerdale valley would serve to mitigate or offset these tree losses  Water resources – The ES identifies a series of mitigation measures to ensure that the impacts of the Proposed Scheme on water resources, the water environment and flood risks are minimised during both construction and operation  Ecology – The ES identifies a series of measures, recommended as a result of the impacts of the Proposed Scheme, which all contribute to maintaining biodiversity within Cumbria, during both construction and operation. United Utilities has therefore established a framework of requirements into an Environmental Masterplan to ensure that appropriate actions to protect and conserve biodiversity are delivered by the contractors for the Proposed Scheme  Cultural Heritage – United Utilities has developed a clear framework of mitigation measures and contractual requirements within the Cultural Heritage assessment to protect cultural and historic

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features and mitigate unavoidable losses. It has already commissioned archaeological surveys which have identified a programme of appropriate mitigation, including archaeological investigations and watching briefs. These actions are included in the Environmental Masterplan for the contractors to implement during construction of the Proposed Scheme.  Materials and Waste Management – The design process has incorporated measures that would implement the waste hierarchy, reducing waste generation and enhancing material reuse, as well as ensuring legislative compliance. Impacts from waste are expected to be greater during construction than operation. Appropriate mitigation measures have been defined in the Environmental Masterplan that would be implemented in the Proposed Scheme  Soils, Geology and Hydrogeology – The environmental assessment has highlighted the significance of protecting soil resources along the construction corridor, and appraises the impacts of the scheme on geological and hydrogeological resources. Recommendations from this part of the EIA have been carried over into the Environmental Masterplan, including the sustainable use and handling of soil resources  Socio-economics – Jobs would be created/safeguarded during the construction of the new network, but overall the employment impact of the Proposed Scheme is considered negligible, as they would be such a small percentage change across the whole of Cumbria. The socio-economics study examines supply and demand for workers’ accommodation, and also the potential effects of severance on local communities  Agriculture and Sporting Land Use - The ES examines the operational requirements of the local farming community, and assesses how the Proposed Scheme may impact on farm businesses, especially during the construction phase  Community impacts – The Construction Code of Practice and Environmental Masterplan make provision for managing the potential adverse effects of the scheme on local communities, such as noise and air quality controls, and the co-ordination of closures and diversions of local public rights of way. There is a clear framework of appropriate actions and a well-defined approach for addressing complaints should they arise  Traffic and Transport – The Proposed Scheme would inevitably give rise to additional movements of light and heavy goods vehicles on the local road network. Ongoing consultations with the relevant highways bodies would enable a co-ordinated approach to agreeing matters important to local communities such as vehicle delivery routes to the construction corridor, the design and implementation of temporary diversions, and safe working practices at road crossings  Energy management - United Utilities has defined a clear framework of expectations and measures to enable it to quantify and minimise energy use and maximise opportunities for renewable energy use. Tools are available to contractors to enable them to determine the carbon impacts of their work and to take action to reduce carbon  Climate change mitigation and adaptation - The Proposed Scheme has considered climate change mitigation adaptation throughout its design, including the aim to implement a wholly gravity-fed RWA, re-use existing assets where practicable and building in resilience to extreme weather events  Sustainable procurement - United Utilities has procedures in place to ensure that its contractors and its supply chain would meet relevant legislative standards and report ongoing performance. Principles of Environmental Mitigation 17) The West Cumbria Water Supplies Scheme has been through a rigorous and ongoing programme of optioneering, scheme selection and detailed design, taking account of technical, environmental, community and economic factors. While the Proposed Scheme has been optimised from an environmental and community perspective, taking account of engineering and economic constraints, the planning application boundary is unavoidably located within sensitive locations including designated areas, such as within the boundary of the candidate Lake District World Heritage Site, a United Nations designation, and many of the watercourses and river catchments are European Designated habitats. 18) Overall, it is important to the note that the development of the mitigation strategy for the proposed scheme has evolved in consultation with both statutory and non-statutory stakeholders, and the adoption of good practice design and construction techniques which United Utilities and its contractors applies to all of its infrastructure projects. 19) To address the adverse effects, the ES examines an extensive variety of carefully considered mitigation measures and controls in each topic area which aim to avoid, reduce or offset the significant environmental

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effects of the scheme. The mitigation proposals are summarised in planning policy terms in this PDAS, and considered in greater detail in the ES. 20) An over-arching Construction Code of Practice would provide the framework for the delivery and monitoring of mitigation proposals and environmental controls during the course of the construction contract and into the commissioning and operational phases of the scheme. To support the decision-making process an Environmental Masterplan has been developed to illustrate on large scale drawings the nature and scope of key mitigation proposals along the route corridor and at the locations of permanent assets such as the Bridge End Connection and the WTW.

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1. Background and Approach

1.1 Introduction 1) This combined Plannin g Statement and Design and Access Statement (PDAS) has been prepared to accompany the submission of the full planning application for the proposed West Cumbria Water Supplies Project – Thirlmere Transfer. 2) The Proposed Scheme comprises various secti ons of pipeli ne and associated water supply infrastructure that extend over a distance of approximately 100 km from Thirlmere Reservoir, in the Lake District National Park, into the boroughs of Allerdale an d Copeland. Planning applications are being submitted to each of the authorities through which the scheme passes:  Copeland Borough Council (Copeland)  Allerdale Borough Council (Allerdale)  The Lake District National Park Authority (LDNPA). 3) The purpose of this PDAS is to:  Describe the various elements of the proposals within each of the three local planning authorit ies  Highlight how the scheme relates to planning policies for these areas and explain the design considerations  Provide a summary of the impacts of the scheme (positive or negative) and refer, as appropriate, to the accompanying Environmental Statement (ES). 4) The PDAS forms an integral part of the application submiss ion and should be read in conjunction with the other plans and documentation that together form t he complete planning application submission (see Appendix A for the full list of documentatio n).

1.2 Need for the Scheme 5) United Utilities has a statutory duty to produce a Water Resources Management Plan under the Water Act 2003. The Final Water Resources Management Plan was published in March 2015, which is an update to the 2013 revised draft plan following an Examination in Public in September 2014. The plan describes in detail an assessm ent of the available wate r supplies and the demand for water over the 2015 – 2040 period. The pla n also sets out the proposed strategy for water resources and demand manageme nt to ensure that an adequate water supply is available to serve the region. 6) As part of the Water Resource Management Plan process supply-dema nd balances were completed for all four Water Resou rce Zones within the United Utilities region. The forecast West Cumbria resource zone supply-demand balance showed a deficit of over 33 ML/day (million litres/day). This forecast deficit arose due to the proposed revocation of United Utilities Ennerdale Water abstraction licence, through the EC Habitats Directive, to protect a significant colony of freshwater mussels (in the River Ehen below th e lake). 7) The revocation of licences for other water sources in West Cumbria (Crummock Water, Chapel House and Overwater) has also been agreed with the Environment Age ncy and Nat ural England as part of a compensatory measures package - due to on-going abstraction until revocation of the Ennerdale Water licence can be im plemented. 8) This proposed new water supply scheme therefore allows United Utilities to address the loss of the Ennerdale Water abstraction licence, and facilit ates the compensatory measures pa ckage. It is considered to represent the best long-term solution for customers and the environment. 9) If a new water source is not delivered in advance of the lice nce revocation in 2025 there would be no legally available abstraction to provide public water supply to the population currently supplied

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by Ennerdale Water. United Utilities would therefore be in breach of its obligations under the Water Industry Act 1991 to maintain a water supply system.

1.3 Alternatives / Evolution of the scheme 10) The draft Water Resou rces Management Plan i dentified a supply deficit in the West Cumbria Resource Zone with the future revocation of the Ennerdale Water abstraction licence. To address this supply-demand deficit, consideration was given to the alternative me ans by which to supply West Cum bria with a resilient water supply. Ultimately, the revised draft Water Resources Management Plan was the subject to an Examination in Public called for by the Sec retary of State. The Exami nation in Public confirmed that the preferred plan – the Thirlmere Transfe r – was the right solution to supply water in the West Cumbria Resource Zone over the next 25 years, and is included in the final version of the Water Resources Management Plan published in March 2015. 11) The selection of the preferred scheme has been based upon a three-stage options appraisal:  Stage 1 – Strategic Optioneering: To address the supply/demand deficit in the Resource Zone an options appraisal and selection process was undertaken from which three opt ions were considered feasible: the lowest-cost plan (local sources) , the preferred plan (West Cumbria Water Supplies Project – Thirlmere Transfer), and the alternative pla n (transfer from Kielder reservo ir). Each option was assessed as part of the Water Resources Management Plan process. This high level review concluded that the existing Thirlmere reservoir was the most appropriate preferred supply sol ution for West Cumbria  Stage 2 – Outline development of the Thirlmm ere Solution : Identification of preliminary options to provide water to West Cumbria from Thirlmere. The main criteria used for considering these different options included, engineering considerations (i.e. length of pipe, hydraul ics including gravity vs pumping, head loss, amount of additional infrastructure required, operational considerations and constructabi lity); environment and sustainability considerations (i.e. ecolog y, landscape and visual, archaeology); cost and socio-economics considerations (i.e. customer impact and traffic and transport)  Stage 3 – Detailed development of the Thirlmere Solution – Route and Site Selection: Consideration and selection of different route options for the pipelines and of different sites for the associated infrastructure (water treatment works, service reservoirs and pum ping stations), using the same criteria as discussed for Stage 2. 12) Further details relating to specific s ections are i ncluded, as appropriate, in each of the corresponding sections in the following Local P lanning Authority Chapters.

1.4 The Scheme

1.4.1 The Main Elements 13) For the purposes of the PDAS and ES the Proposed Scheme is divided into a number of sections based upo n the proposed arrangement and fun ction of pipelines. Whils t the scheme predomina ntly comprises underground pipelines, there are specific ‘sections’ where other associated infrastructure is required such as a water treatment works, service reservoirs and pumping stations (see drawing B2707061/S0/01- Overall Scheme Layout Plan Sections). 14) The sections and associated infrastructure features of the scheme are listed in Table 1.1. The first section is a twin main Raw Water Aqueduct (RWA), which starts at a new connectio n point at the northern end of Thirlmere Reservoir, in the Lake District National Park, and runs to a new water treatment works (WTW) near Hags Wood in Allerdale. From here a pipeline runs generally northwards to a new Service Reservoir (SR) at Moota Hill and then on into the existi ng distribution network at Quarry Hill. 15) A new water mains also extend southwards via a new pumping station at Harrot Hill and a new service reservoir and p umping stati on at High L eys into the existing network at Summergrove and Kelton Fell Service Reservoirs in Copeland. Existing mains pipes that run westwards to the

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existing Stainburn Service Reservoir and eastwards to the existing service reservoir at Cornhow would be re-used by slip-lining (a new smaller pipe is inserted through an existing la rger pipe).

Table 1.1 Sections and components of the West Cumbria new water supply

Section/Facility Name Local Planning Authority 1 Bridge End Connection, Thirlmere (at Bridge End WTWW) Lake District National Park 2 Raw Water Aqueduct from- Bridge End to A66 Slip road Lake District National Park 3 Raw Water Aqueduct around Keswick and under the River Greta Lake District National Park 4 Raw Water Aqueduct – Crosthwaite to Castle Inn Lake District National Park 5 Raw Water Aqueduct – Castle Inn to new WTW site Lake District National Park 6 New Water Treatment Works Site (WTW) near Hags Wood. Allerdale BC 7 Netwo rk Main – F rom new WT W to Quarry Hill, including the Allerdale BC/Lake District decom missioning of the existing WTW at Quarry Hill National Park* 8 New Service Reservoir – Moota Hill Allerdale BC 9 Netwo rk Main – F rom new WTW site to new Pumping Station at Allerdale BC Harrot Hill 10 New Pumping Station – Harrot Hill Allerdale BC 11 Network Main – F rom Harrot Hill to Ullock Allerdale BC 12 Network Main – F rom Ullock to High Leys Service Ress ervoir (SR) Copeland BC 13 Network Main – High Leys to Kelton Fell Copeland BC 14 High Leys SR and Pumping S tation Site Copeland BC 15 Network Main – High Leys to Summergrove Copeland BC 16 Network Main – P apcastle to Broughton Cross Allerdale BC 17 Network Main – B roughton Cross to Stainburn Allerdale BC 18 Network Main - to Southwaite Farm Allerdale BC 19 Netwo rk Main - Southwaite Farm to Cornhow, including the Lake District National Park Decom missioning of the existing WTW at Cornhow 20 Decommissioning of the existing infrastructure (see table 1.2 below) Lake District National Park

* - Section extends across the boundaries of the Local Planning Authorities 16) Current estimates put the most likely completion date as 2022 (refer to Chapter 6 regarding the Construction Programme), although United Utilities would work to implement the Proposed Scheme as soon as practically possible in order to address the needs of the Habitats Directive.

1.4.2 Decommissioning 17) The decommissioning of existing assets would involve turning off the current water supply and removing various items of plant and machinery from buildings. In situ water supply valves and similar items of plant would be clos ed and made safe. Items of above ground plant and machinery in buildings would be removed from the existing Quarry Hill WTW, Corn how and the Ennerdale WTW. Table 1.2 highli ghts the plant and machinery that would typically be removed:

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Table 1.2 Typical Plant and Machinery for Removal during Decommissioning

Location Plant/ Machinery Material Quarry Hill Process tanks Steel

Pumps and other mech anical Steel components

Chemical tanks Fibreglas s coated steel, plastic, steel

Walkways Galvanised steel; GRP

Filter media Sand

Cornhow/ Ennerdale Process tanks Fibreglass coated steel

DAF Unit Package plant – to be removed from site whole

Pumps and other mech anical Steel components

Chemical tanks Fibreglass coated steel, plastic

Walkways Galvanised steel, GRP

Membranes Plastic

Microstainers Steel

1.4.3 Other Schem e Elements 18) There is also associated plant and machinery, together with temporary works along the route that would need to be provided and therefore are included within the application:  Gates and fencing  Air valves, washout chambers, sluice valves including branch valves and line valves, a small number of which require associated control kiosks  Temporary accesses would be required along the full scheme to allow for deliveries of pipe and access for construction vehicles  Temporary compounds and temporary laydown areas  Permanent accesses would be required for the WTW, SRs and PSs. 19) Washout pipes are also likely to be required along the lengt h of the pipelines to allow for release of water to a receiving watercourse fo r maintenance or emergency reasons. The need to use washout facilities unde r emergency conditions or for maintenance would arise very infrequently. The exact nature and location of the washout pipes and out fall to the receiving watercourse can only be identified during the detaile d design by the construction contractor. For this reason, United Utilities does not seek consent for the washout pipes ,as part of the planning application for the Proposed Scheme, rather a separate planning application will be submitted for this infrastructur e once detailed design requirements are confirmed (for further information in the environmental implication please refer to Chapter 4 of the ES).

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1.5 Environmental Mitigation

1.5.1 Approach to Mitigation 20) The West Cumbria Wa ter Supplies Scheme has been through a rigorous and ongoing programme of optioneering, schem e selection and detailed design, taking account of technical, environmental, community and economic factors. While the Proposed Scheme has been optimised from an environme ntal and community perspective, taki ng account of engineering and economic constraints, the planning application boundary i s unavoidably located within sensitive locations including designated areas, such as within the boundary of the candidate Lake District World Heritage S ite, a United Nations designation, and many of the watercourses and river catchments are European Designated habitats. 21) The specific impacts of the scheme include environmental effects, especially during the construction phase, for example through tree loss, soil stripping, hedgerow removal, watercourse crossings, vehicle movements and noise emiss ions, but also during the operational phase through the introduction of new elements into the landscape. Additionally, in the absence of proper controls, there is a risk that avoidable issues, such as pollution incidents, could arise. 22) Overall, it is important to note that the development of the mitigation strategy for the proposed scheme has evolved in consultation with both statutory and non-statutory stakeholders, and the adoption of good practice design and construction techniques which United Utilities and its contractors applies to all of its infrastructure projects. 23) To address the adverse effects, the Environmental Statement (ES) examines an extensive variety of carefully considered mitigation measures and controls in each topic area which ai m to avoid, reduce or offset the significant environmental effects of the scheme. The mitigation proposals are summarised and assessed in planning policy terms later in this PDAS and also in the ES. This has not only resulted in an environmentally optimised detailed design, which avoids many key constraints, but also minimises effects through responsible construction techniques, for example measures incorporated include reducing the working width of the pipeline at hedgerows and river crossings, identifying root protection areas for vulnerable trees, adopting construction strategies with appropriate checks and controls, developing vegetation reinstatement techniques to reduce landscape and visual effects, and programming construction works to avoid seasonal constraints posed by protected species such as bats, salmon and nesting birds. 24) In addition, sites of archaeological interest have been either avoided thro ugh embedded (design ­ led) mitigation, or would be subject to watching briefs and investigative works, and farming interests and agricultural land quality would be maintained t hrough the construction phase through consultations with farmers and the implementation of construction strategies and management plans directly targeting agricultural resources. 25) Noise and air quality impacts in local communities would also be controlled in consultation with local people, local auth orities and the adoption of noise and dust control measures. Construction effects at a key biodiversity resource affected by the Raw Water Aqueduct, Shoulthwaite Moss, a county wildlife site, would be mitigated through the creation of additional moss habitat within the application boundary. The unavoidable loss of mature trees would be mitigated through replaceme nt planting e ither within t he working width of the pipeline, or through offsetting tree loss by woodland planting outside the application boundary in the Ennerdale valley. 26) It is anticipated that mitigation proposals would in many cases be incorporated within planning conditions which in turn United Utilities’ contractors would d eploy through adoption of the Construction Code of Practice (CCoP). 27) A key feature of the proposed sche me is the level of embedded mitigation which has been incorporated into shapi ng the location and design of the pipelines and associated infrastructure. Embedded mitigation refers to the avoidance of environmental constraints, existing infrastructure or local communities taking account of technical and economic factors. The exhaus tive optioneering studies, field surveys and stakeholder consultations undertaken by United Utilities have contributed to an environmentally optimised design which avoids many of the potential environme ntal constrai nts found along the proposed schem e. Further consideration of how

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embedded mitigation h as been successfully delivered in the West Cumbria Water Supplies scheme can be found in Chapter 3 of the accompanying ES. 28) Although embedded m itigation has served to significantly reduce the potential environmental effects of the scheme, some adverse effects would inevitab ly arise during both the construction and operation phases. The accompanying ES, including the CCoP (see paragraph 1.5.2 below), describes the nature and scope of the mitigation which is proposed to reduce or offset these environme ntal effects. The following section of this PDAS summarises t he findings and conclusions drawn from the assess ment of envi ronmental effects in the ES, and the broad scope of mitigation which has been proposed for each topic area.

1.5.2 Construction Code of Practice 29) The ES presents an outline CCoP. The CCoP describes the way in whi ch elements of the proposed scheme would be built sustainably, taking account of technical constraints, environme ntal legislation, good pra ctice and United Utilities’ established construction procedures. The CCoP comprises a series of Construction Strategies which, for example, present details of pipe-laying under open cut, directional drilling a nd slip-lining methods, working in floodplains, the sustainable management of soil resources and the delivery of construction solutions at specific locations s uch as the River Keekle crossing and Wood Beck. In addition to the Construction Strategies the CCoP presents a Schedule of Mitigation and an Environmental Masterplan. The Schedule of Mitigation comprises a summary of all the mitigation proposals presented in each of the technical chapters of the ES. The intention is that the Schedule of Mitigation can assist in the development of planning conditions should the proposed scheme be granted permission. The Environmental Masterplan is intended to complement the Schedule of Mitigation and presents a series of 1:2,500 scale drawings which illustrate graphically the nature, scope and location of proposed mitigation so lutions along the development corridor. The Environmental Masterplan annotates where mitigation proposals are planned, enabling the reader to understand the nature, scope and location mitigation that is required to avoid or reduce the environmental effects of the scheme.

1.6 Consultation 30) A Statement of Community Involvement (SCI) has been prepared to support the planning application s. The SCI explains how the applicant has consulted extensively with key stakeholders and the local community from optio n development to the final scheme for which planning permission is now sought. 31) The proposed scheme has developed in conjunction with extensive stakeholder and community consultation. Regular li aison has ta ken place with the local planning aut horities and statutory consultees. Several phases of public consultation have been completed following the EiP in September 2014 involving a series of public exhibitions, exhibitions at ag ricultural shows, meetings with parish councils and other key stakeholders. One to one meetings have also occurred with affected landowners and businesses as well as keeping local Members of Parliament informed. 32) More details of the consultation for each planning authority area are provided in the relevant local authority section.

1.7 Planning Policy Context

1.7.1 Development Plans 33) National pl anning policy states that adopted local developm ent plans hold the most material weight in the application decis ion making process, as the planning authority must have regard to section 38(6) of the Planning a nd Compulsory Purchase Act 2004, which states : ‘If regard is to be had to the development plan for the purpose of any determination to be made under the planning Acts, the determination must be made in accordance with the plan unless material considerations indicate otherwise.’

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Planning, Design and Access Statement

34) This means that the local development plans foor three planning authorities are relevant, with Cumbria County Council the upper tier local authority for All erdale and Copeland with respect to highways, minerals and waste matters. . The relevant documents which make up the development plan documents for each local planning authority are set out in their respective chap ters of this document.

1.7.2 National Planning Policy Framework (NPPF) 35) The National Planning Policy Framework (NPPF), introduced in March 2012, sets out the Governme nt’s planning policies for England and how they should be applied. The NPPF restates the position that planning law requires that applications for planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise. Notwithstanding this, the NPPF, must be taken into account in plan making and is a material consideration in planning applications decisions (NPPF paragraph 2). 36) The NPPF also places specific consideration fo r ‘sustainable development’ and has extensive reference to it: ‘…policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development means in practice for the planning system’ (paragraph 6)’.

37) The three dimensions to sustainabl e development are defined in the NPPF as economic, social and enviro nmental:  The economic role refers to building a strong, responsive, competitiv e economy, including the provision of ‘infrastructure’  The social role includes the creation of a hig h quality built environment to benefit community needs  The environmental role is the contribution to protecting and enhancing all natural , built and historic environments, improving biodiversity, using natural resources prudently, minimising waste and pollution and mitigating and adap ting to climate change, including moving to a low carbon economy. 38) Paragraphs within the NPPF, of relevance to the water supply schemes are: 39) Paragraph 94 of the NPPF, which requires loca l planning authorities to adopt proactive strategie s to mitigate and adapt to climate change, includi ng taking full account of water supply and demand considerations and Paragraph 99 requires this to be set out in Local Plans. 40) Paragraph 156 of the NPPF, which requires local planning authorities to set out the strategic priorities for the area in the Local Plan, including strategic policies to deliver the provision of infrastructure for water supply, whilst Paragraph 162 of the NPPF requires local planning authorities to work with other authorities and providers to assess the quality and capacity of water supply infrastructure. 41) As detailed in Section 1.2, the key driver for the Proposed Scheme is the protection of a significant colony of freshwater m ussels (an internationally protected species) in Ennerdale Water. Section 11 of the NPPF details the Government’s policies on conserving and en hancing the natural environme nt. Paragraph 109 states that the planning system should contribute: ‘…to the Government’ s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological ne tworks that are more resilient to current and future pressures.’

42) Of particular relevance to the parts of the Proposed Scheme within or affecting the setting of the Lake District National Park is paragraph 115 of the NPPF which states: ‘Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlifef and cultural heritage are important considerations in all these areas, and should be given great weight in National Parks and the Broads’.

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Planning, Design and Access Statement

1.7.3 Planning Practice Guidance (PPG) 43) The Departtment for Communities and Local Government (DCLG) established a web based resource s ite - Planning Practice Guidance http://planningguidance.communities.gov.uk/, which describes all current aspects of town and county planning a nd specifically addresses the various environme ntal considerations, including: air quality, climate change, conserving and enhancing the historic environment, design, environmental impact assessment, flood risk and coas tal change, health and well-being, land contamination, land stability, light pollution, natural environment, noise, planning obligations, water supply, and waste water and water quality. 44) Of particular relevance to the location of new water infrastructure, the PPG states: ‘Adequate water and wastewater infrastructure is needed to support sustainable development. A healthy water environment will also deliver multiple benefits, such as helping to enhance the natural environment generally and adapting to climate change.’…

‘In identifying sites it will be important to recognise that water and wastewater infrastructure sometimes has particular locational needs (and often consists of engineering works rather than new buildings) which mean otherwise protected areas maya exception ally have to be considered where consistent with their designa tion’ (Reference ID: 34-005-20140306).

1.8 Statement Structure 45) The following PDAS has been sub-divided into ‘local authority sections’, with each LPA having their own chapter:  2: Lake District National Park  3: Allerdale Borough Council and  4: Copeland Borough Council. 46) Each local authority section describes:  Site context - Descrribing the existing site characteristics, allocations/designation s, site features, topography with an overview of the physical, social and economic context to set the baseline for design development  Development description - Description of the elements of the development in the respective authority boundaries  Environmental mitigation proposals – Summary of the various types of proposed mitigation  Scheme assessment - Assessment of the aspects of the scheme, based on the relevant accompanying ES and other lan d use factors relevant for each local authority area  Plannin g policy review - Background and assessment of the proposed scheme against national and local planning policy  Design and access - Evaluation of the const raints and opportunities considered during the evolution of the design. Referring to the use, amount of development, the layout of the site, scale and appearan ce of the buildings, vehicular access and the approach to landscaping. 47) The PDAS then conclu des with Proposed Sche me–wide chapters on:  Sustainability  Construction and phasing  Conclusions.

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Planning, Design and Access Statement

2. The Lake District National Park

2.1 Scheme Description 48) Development of a new water supply connection from Thirlmere Reservoir to the area of West Cumbria comprising within the Lake District National Park oof:  A twin underground pipeline from Bridge End Connection, Thirlmere to land off the A595 near Blindcrake  A single underground pipeline to the north of Blindcrake between the proposed WTW near Hags Wood and Quarry Hill  The slip-lining (rene wal of existing pipeline) of a section of existing water pipeline from Southwa ite Farm, Cockermouth to Cornhow Water Treatment Works, Loweswater  The decommissioning of Cornhow Water Treatment Works and Ennerdale. 49) The development would incorporate associated kiosks, valve chambers , excavation and landscaping, temporary vehicular accesses, working areas, compounds , hard standings and other associated development along the route. 50) The detailed scheme d escriptions and locations, for each section, are listed in Table 2.1 below:

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Planning, Design and Access Statement

Table 2.1 – Lake District National Park - Sections

Scheme Section Development Description Location Description Associated Drawings

Section 1 – Bridge End This site is currently an operational WTW. Within this At the existing WTW at Bridge End, Thirlmere.  General Site Layout Plan Connection (at Bridge End WTW) site, new facilities would be constructed to B2707061/S3/LDNP/BE/01 accommodate the new RWA connection. The works  Site Sections A-A and B-B comprise: B2707061/S3/LDNP/BE/02  Two new control kiosks  Site Sections C-C and D-D  New below ground control valve house B2707061/S3/LDNP/BE/03  New below ground meter chamber  Hydrogeneration House –  A reinforced concrete channel with new v-notch weir Elevations B2707061/S3/LDNP/BE/04  New hydrogeneration house  Hydrogeneration House - Floor  New slab for emergency pumps and surge vessel Plan and Section  New emergency lagoon (the existing lagoon is to be B2707061/S3/LDNP/BE/05 filled-in to existing ground level and removal of  Control Kiosk - Roof Plan and existing mechanical and electrical equipment) Elevations  Connection for the new pipes and alterations to the B2707061/S3/LDNP/BE/06 existing compensation flow pipes.  Control Valve House - Floor Plan, In addition there would be an extension to the existing Roof Plan and Sections access road, realigned site boundary fence, and a B2707061/S3/LDNP/BE/07 contractors’ compound.  Control Valve House – Elevations B2707061/S3/LDNP/BE/08  Water Quality Control Kiosk - Roof Plan and Elevations B2707061/S3/LDNP/BE/09  Proposed temporary pumping arrangement and new meter chamber - Layout and Elevations B2707061/S3/LDNP/BE/10

Section 2 - Bridge End This section involves laying new twin 900 mm diameter  The pipeline passes northwards from the WTW and  Lake District National Park pipelines in an open cut trench (from an existing valve) crosses St John’s Beck to the west of the A591, General Layout

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Planning, Design and Access Statement

Scheme Section Development Description Location Description Associated Drawings Connection to A66 Slip Road to the A66 Keswick slip road. This section also includes around the area of Smaithwaite B2707061/S2/LDNP/1 - 6 temporary access points and contractors’ laydown  From St John’s Beck, the route continues along the areas. bottom of the valley along the southern edge of The proposed Shoulthwaite Moss ecological mitigation Shoulthwaite Moss, with the A591 Keswick Road in area is located within this section. proximity  Leaving the Shoulthwaite area, the route heads north to cross the A591 near Naddle Beck. The route continues north, with Naddle Beck to the west of the route and the fells of to the east. The route moves west to cross Naddle Beck to the north of Dalebottom Farm Camping and Caravan Park  The pipeline loops to the northeast towards the A66, with Naddle Beck to the east of the pipeline route. To the west lies the Scheduled Monument of Castlerigg Stone Circle  The route crosses the A66 to the east of Keswick and continues west, with the A66 at the southern border of the route and the River Greta to the north, for approximately 1.2 km.

Section 3 - Raw Water Aqueduct This Section consists of:  This section runs towards Keswick along the A66  Lake District National Park around Keswick and under the  Laying of new twin 900 mm diameter pipelines, towards the junction of the A66 and the A591 near General Layout River Greta predominantly using an open cut construction the Eleventrees area. On entering Keswick the B2707061/S2/LDNP/6 - 7 method with the exception of: pipeline descends from the A66 several hundred metres down Penrith Road before leaving the road in . A trenchless crossing under the A591 Chestnut the Chestnut Hill area of Keswick. It heads south Hill and then west towards the known as also . Tunnelling in front of Nether Place nursing as Chestnut Hill home  Continuing north from Chestnut Hill road the route . Tunnelling under the River Greta and Penrith runs through open fields to loop through the northern Road edge of Keswick, with Nether Place Nursing Home to . Construction of a pipe-bridge across a the east and the Regional Cycle Route 71 to the

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Planning, Design and Access Statement

Scheme Section Development Description Location Description Associated Drawings watercourse near High Keld north of the A66. north. The pipeline continues east through Keswick This section also includes temporary access points, towards the Postal Delivery office, with St Herbert’s contractors’ laydown areas and the main contractors’ Primary School to the south compound off the A66 to the north of Keswick  The pipeline crosses under the River Greta and Penrith Road in Keswick, then the route runs north west towards the A66, crossing Spooneygreen Lane before crossing the A66 near Crosthwaite Roundabout.

Section 4 - Raw Water Aqueduct This section consists of laying new twin 900 mm  Section 4 runs for approximately 10 km, through  Lake District National Park – Crosthwaite Roundabout to diameter pipelines in an open cut trench, from open countryside north of Keswick near General Layout Castle Inn Crosthwaite Roundabout up to the B5291 Castle Inn. Applethwaite to the northern tip of Bassenthwaite B2707061/S2/LDNP/7 - 14 This section also includes temporary accesses and Lake laydown areas.  On leaving Keswick, the route continues north for approximately 250 m, with the Burnside Caravan Park to the west. The route continues in a north westerly direction passing through open countryside and agricultural land before crossing the A591 near the village of Applethwaite  The pipeline continues through open countryside, with the A591 on the eastern edge of the route and the River Derwent to the west. The villages of Applethwaite and Millbeck are approximately 500 m to the east of the route  Passing Dodd Wood, the route enters the A591 in road for approximately 250 m, before passing to the west of the road at the south eastern edge of . To the east lies Skiddaw and to the west Bassenthwaite Lake. The route runs between the A591 to the east and the eastern shore of Bassenthwaite Lake, past Mirehouse and Catstocks Wood and Saint Bega’s Church  The pipeline continues towards Castle Inn along the

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Planning, Design and Access Statement

Scheme Section Development Description Location Description Associated Drawings eastern edge of Bassenthwaite Lake, crossing Collier Silk, Chapel Beck and Halls Beck. The A591 lies to the east of the route and beyond this the village of Bassenthwaite and Kilnhill to the east of the route.

Section 5 - Raw Water Aqueduct This section consists of the laying of new twin 900 mm  The final section of the RWA runs from the northern  Lake District National Park – Castle Inn to the new WTW site diameter pipelines in an open cut trench, from Castle edge of Bassenthwaite Lake towards the village of General Layout Inn to the proposed new WTW (in Allerdale BC). This Blindcrake. The section is characterised by a B2707061/S2/LDNP/14 - 20 section also includes temporary accesses, contractors’ sloping landform, forming the lower slopes of the laydown areas and a contractors’ compound. dale from the north down to the River Derwent valley  The section can be classified as a transitional landscape, between the more open moorland and the lower, more enclosed landscapes of the valley bottom. There is a patchwork of predominately pastoral fields, delineated by a series of stone walls giving way to hedges at lower levels  Passing to the west of the Castle Inn Hotel, the pipeline crosses the B5291 at the northern edge of Bassenthwaite and continues in a north westerly direction with Armathwaite Hall and the Lake District Wildlife Park to the west before crossing Coal Beck  From Bassenthwaite the route runs in a north westerly and then westerly direction, through open countryside with the River Derwent to the south and Sunderland Heads to the north  Land use in the area is improved and semi-improved pastoral farmland, which dominates the landscape to the north, with occasional clumps of trees and small woods adding variety. To the west and east dry stone walls predominate, with, extensive parkland and mainly coniferous plantations. A network of secondary roads connects local villages and farms

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Planning, Design and Access Statement

Scheme Section Development Description Location Description Associated Drawings  The pipeline continues towards the village of Blindcrake, through Isel. Isel Hall is a Grade I listed Elizabethan Range and occupies a prominent position in the area, on a steep slope and lays south of the pipeline on the northern bank of the River Derwent. The pipeline runs along the northern edge of a local road through Isel  Leaving Isel the pipeline continues west, crossing Blumer Beck beyond Isel before continuing north to Blindcrake, running through agricultural land  The route crosses Gill Beck to the south of Blindcrake village. The Gill Beck area is characterised by the presence of ancient woodland and is also classified as a Site of Special Scientific Interest (SSSI) and Geological Conservation Review Site (GCR) due to significant geological exposures  The pipeline passes to the south of Blindcrake, through agricultural land (some of which contains ridge and furrow systems) towards the A595, crossing the road between Blindcrake and Redmain. Here the route reaches the boundary of the Lake District National Park and terminates at the proposed new WTW in Allerdale district.

Section 7 (Part) - Network Main ­ This short (900 m) section comprises the new single  The section of the water pipeline heads along the  Lake District National Park WTW to Quarry Hill (this section is (500 mm) network main from the proposed WTW to the northern side of the A595 (within Allerdale), crossing General Layout predominantly located in existing Quarry Hill WTW site. the A595 into the Lake District National Park just B2707061/S2/LDNP/21 - 22 Allerdale) past the village of Blindcrake, it continues for approximately 0.9 km along the southern edge of the road past Moota Quarry, before crossing back over the A595 adjacent to the B5301 Parsonby Road junction and adjacent to the proposed Moota Hill Service Reservoir (in Allerdale). Most of Section 7

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Planning, Design and Access Statement

Scheme Section Development Description Location Description Associated Drawings lies within Allerdale district.

Section 19 - Southwaite Farm to This section of the scheme is part of the network mains,  This section commences at Hundith Hill Road and  Lake District National Park Cornhow WTW including the where a section of the existing mains would be forms part of the existing network mains, between General Layout Decommissioning of the existing upgraded using a slip-lining construction technique. Southwaite Farm and Cockermouth WTW in the B2707061/S2/LDNP/23 - 28 WTW at Cornhow Temporary launch and reception pits would be required River Cocker valley to access and facilitate the slip-lining. Excavations  The valley floor is dominated by floodplain of the would also be required on the existing fittings to connect River Cocker within the broad river route. Pasture into the new main. Certain sections of the existing fields generally run alongside the river, with mains would be abandoned as they are not required. occasional meadows and clumps of woodland There would also be temporary accesses and lay-down adjacent to the river course. It is a predominately flat areas. landscape The existing WTW at Cornhow would be  The nearby settlements consist of Low and High decommissioned as part of the works, which would Lorton, with scattered farmsteads and residential involve the removal of all plant and machinery from the properties and some caravan parks within the valley site. The current isolation valve for current public water bottom and on the adjacent low valley slopes supplies, would be turned off and capped off at the  The existing WTW north of Loweswater. WTW.

Section 20 - Decommissioning of An existing WTW is to be decommissioned. This would The existing WTW at the end of Ennerdale Water  Project Overview an existing WTW at Ennerdale involve the removal of plant and machinery from the B2707061/S0/01 site. The current isolation valve for current public water supplies would be turned off and capped off at the WTW.

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Planning, Design and Access Statement

2.2 Planning Applications along the Route 51) During the development of the scheme, United Utilities has liaised closely with the L ake District National Park Authority. Part of this process was the consideration of development proposals along the propos ed route and the need to avoid these locations where practicable. In September 2015, planning application information was requested from the three local authorities to identify both the potential land use impacts of the scheme and developments submitted/approved within the last five years within 150 m of the Proposed Scheme. 52) The data were plotted into a GIS and compared against the final planning application boundary. One hundred and twenty two applications submitted in the last five years were found within the 150 m buffer for the Lake District National Park Authority, though further research identified that only the following planning permissions were potentially directly affected by the scheme:  7/2010/ 2188, Castle Inn Hotel - Proposed new access track to hotel and extra car parking  7/2014/ 2300, Sheep Dog Field - Proposed residential development of fifty five two storey houses comprised of two, three and four bedroomed dwellings to provide a mixture of affordable and local occupancy houses  7/2015/ 2199, Castle Inn Hotel, - Proposed three storey extension providing an additional 33 en­ suite bedrooms and associated landscaping, including a wetland lake.

2.3 Planning Policy Assessment

2.3.1 Context 53) National Park Authorities are the st rategic and l ocal planning authorities for their areas. As set out in Section 5 of the Nation al Parks and Access to the Countrys ide Act 1949 (NPACA 1949) and amended by the Environment Act 1995, the statutory purposes of National Parks are:  To conserve and enhance the natural beauty, wildlife and cultural heritage of the National Park; and  To promote opportu nities for the understanding and enjoyment of the special qualities of the National Park by the public. 54) Section 11A of the NPACA 1949 m akes clear that if National Park purposes are in acute conflict, greater weight should be attached to the purpose of conserving and enhancing the natural beauty, wildlife and cultural heritage of the Lake District National Park. 55) Section 11A of the NPACA 1949 also states that National Park Authoriti es have a duty in pursuing those purposes, ‘to seek to foster the economic and social well-being of local communities within the National Park, but without incurring significant expenditure in doing so, and shall for that purpose co-operate with local authorities and public bodies whose functions include the promotion of economic or social development within the area of the National Park’. 56) Authorities and public bodies must show they have fulfilled this duty. Where their activities outside National Parks might have an impact inside them, the Government says that they should cooperate across National Park boundaries. 57) Under section 4A of the Town and Country Planning Act 1990, National Park Authorities have the sole responsibilities of a local planning authority for their areas, including minerals and waste planning and development control functions. The LDNPA is therefore responsible for maintaining the local development framework and Development Management within the bounda ry of the Lake District and where necessary has a role that extends to the setting of the National Park beyond the boundary. 58) Section 11A of the NPACA 1949 also requires all relevant authorities and public bodies, such as neighbouri ng local authorities, public bodies and statutory undertakers (including United Utilities), to

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Planning, Design and Access Statement

take National Park purposes into account when they make decisions or carry out activities which might affect the National Park: ‘In exercising or performing any functions in relation to, or so as to affect, land in a National Park, any relevant authority shall have re gard to the (National Park) purposes…and, if it ap pears that there is a conflict between those purposes, shall attach greater weight to the purpose of conserving and enhancing the natural beauty, wildlife and cultural heritage of the area comprised in the National Park’

59) Authorities and public bodies must show they have fulfilled this duty. Where their activities outside National Parks might have an impact inside them, the Government says that they should cooperate across National Park boundaries.

2.3.2 Lake District National Park - World Heritage Site Application 60) The Lake District National Park has been put forward by Government to the United Nations Educational, Scientific and Cultural Organisation (UNESCO) World Heri tage Committee as the UK’s sole World Heritage Site (WHS) nominee in 2016. A decision by the World Heritage Committee is expected in July 2017. 61) WHS are places of Outstanding Universal Value as set out in the 1972 United Nations Educational, Scientific and Cultural Organisation (UNESCO) Convention Concerning the Protection of the World Cultural and Natural Heritage (the World Heritage Convention). As a State Party to the Convention, the UK is required to protect, conserve, present and transm it its World Heritage Sites to future generation s. 62) The UNES CO World Heritage Committee requi res all World Heritage Sites to have in place a Statement of Outstanding Universal Value (SOUV). Each Statement has a brief synopsis, describing the site and its Outstanding Universal Value (OUV). The LDNPA has created a draft SOUV which comprises an introductory statement, justificat ion of criteria, and statements on the authenticity, integrity, and protection and management of this unique region. The LDNPA’s justification of OUV is predicated on four main themes: rural landscape and farming traditions; development of the picturesque aesthetic; the cradle of romanticism; and the landscape conservation movement. 63) UNESCO reports that the special s ignificance of the Lake District lies in the interaction between social, economic, cultural and environmental influences. UNESCO also states that this significance results from an alliance between the aesthetic appeal of its natural environment and unique character of its farming culture, which has inspired writers and artists to show the how the landscape appeals to and inspires visitors and local people. This culture led to the development of early conservation movements to protect what is known as a cultural landscape.

2.3.3 Development Plan 64) The Development Plan in respect of the Lake District National Park Authority is made up of:  Local P lan Part One - Core Strategy (2010)  Local P lan Part Two - Allocations of Land DPD (2013)  Local P lan Part Three – Minerals Safeguarding Areas (2 013)  Proposals Map (2010)  Saved Policies of th e Lake District National Park Local Plan (1998).

2.3.4 Supplementary Planning Documents (SPDs) 65) The Lake District National Park Authority has adopted the following SPDs:  Cumbria Wind Energy SPD  Housing Provision SPD  Historic Environment SPD 17

Planning, Design and Access Statement

 Caravans and Camping Sites SPD  Live/ W ork Units SPD  Landscape Character SPD  Campus SPD.

2.3.5 National Park Management Plan 66) National Park Authorities are required to produce a National Park Management Plan for their area and to review it at least every five years. In order to produce and update this Plan, the Lake District National Park Partners hip was formed in 2006 from 25 representatives from the public, private, community and voluntary sectors, including United Utilities. Management plans do not form part of the development plan, but may be material considerations in making dec isions on individual planning applications, where they raise relevant issues. 67) The Lake District National Park Partnership’s Plan for 2015-2020: The Management Plan has been prepared to set out how the partners work together to proactively and effectively manage the Lake District as a National P ark and as a prospective World Heritage Site. 68) The Partnership’s Plan recognises that the Lake District is a critical supply source of water for and that there are some particularly challeng ing water supply issues in West Cumbria. It identifies that United Utilities, the Environment Agency and Natural England are key partners in resolving these issues whilst safeguarding rare and protected species. This includes expanding the UK’s largest interconnected water resource zone with new pipelines to West Cumbria. The project is therefore of significant importance to the Partnership’s Plan and in principle its implementation accords with Policy SL5 (Improved water quality and resources in lakes, tarns, rivers, ground waters, and sea).

2.4 The English National Parks and the Broads: UK Government Vision and Circular 2010 69) The provis ions of this circular are a material consideration for the part of the development within the Lake District National Park and the surrounding ‘buffer zones’. It provides updated policy guidance on the English Nationa l Parks and the Broads. The circular provides a vision for English National Parks and Broads whe re by 2030:  ‘There are thriving, living, working landscapes notable for their natural beauty and cultural heritage. They inspire visitors and local communities to live within environmental limits and to tackle climate change. The wide-range of services they provide (from clean water to sustainable food) are in good condition and valued by society.  Sustainable development can be seen in action. The communities of the Parks take an active part in decisions ab out their future. They are known for having been pivotal in the transformation to a low carbon society and sustainable livviing. Renewable energy, sustainable agriculture, low carbon transport and travel and healthy, prosperous communities have long been the norm.  Wildlife flourishes and habitats are maintained, restored and expanded and linked effectively to other ecological networks. Woodland cover has increased and all woodlands are sustainably managed, with the right trees in the right places. Landscapes a nd habitats are managed to create resilience and enable adaptation.  Everyone can discover the rich variety of England’s natural and historic environment, and have the chance to value them as places for escape, adventure, enjoyment, inspiration and reflection, and a source of national pride and identity. They will be recognised as fundamental to our prosperity and well-being.’

2.5 Major Development within the National Park 70) Paragraph 116 of the NPPF contains the Government’s policy that major development should not take place in National Parks save in exceptional circumstan ces. Paragraph 116 states:

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Planning, Design and Access Statement

“Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest. Consideration of such applications should include an assessment of:  The need for the development, including in terms of any national considerations, and the imp act of permitting it, or refusing it, upon the local economy;  The cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it some other way; and  Any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.” 71 ) This is the Government’s longstanding view and was also contained in Planning Policy Statement 7: Sustainable Development in Rural Areas (which was cance lled when the NPPF was published) and is also replicated in the English National Parks and the Broads UK Government Vision and Circular 2010 at paragraph 31, which states: ‘Applications for all major developments should be subject to the most rigorous examination and proposals should be demonstrated to be in the public interest before being allowed to proceed… The Government expects all public authorities with responsibility for the regulation of development in the Parks to apply the test rigorously, liaising together to ensure that it is well understood by developer’ 72 ) The policy reflects the importance of the National Park designation in that it states that major development would normally be refused, rather than the ‘presumption in favour of sustainable development’, as set out in paragraph 14 of the NPPF. There is no precise definition within the NPPF of ‘major development’; the definition is addressed in the Planning Practice Guidance (Reference ID: 8-005-20140306): ‘Whether a proposed development in these designated areas should be treated as a major development, to which the policy in paragraph 116 of the Framework applies, will be a matter for the relevant decision taker, taking into account the proposal in question and the local context. The Framework is clear that great weight should be given to conserving landscape and scenic beauty in these designated areas irrespective of whether the policy in paragraph 116 is applicable. (Revision date: 06 03 2014).’

73 ) The requirements of the major development test are replicated within the Lake District National Park Authority Core Strategy Policy CS12 (Major Developments) , which states:

“Major developments will be subjected to the most rigorous examination and must be shown to be in the public interest. Theey will only be permitted in exceptional circumstances where it can be demonstrated that:  There are no alternative sites available outside the National Park;  There is a proven overriding national need that cannot be met in any other way;  The development is designed and carried out to cause least practicable harm;  Any detrimental effects on the special qualities of the National Park can be adequately mitiga ted; and  The development has no overall adverse impacts on the local economym .

All possible measures should be taken to minimise the adverse effects of development and associated infrastructure and where appropriate:  Provision should be made to meet local community needs;  Acceptable measures should be secured for site restoration; and  Arrangements should be made for suitable local community engagement prior to and during the development and subsequent restoration.

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Major development is defined as development which is more than local in character and which has a significant adverse imp act on the special qualities of the National Park.”

74) The explanatory text to Policy CS12 at paragraph 4.10.2 gives examples of what the authority considers to be ‘major developmen t’ and includes ‘pipelines’ and ‘water supply schemes’. As Policy CS12 encompasses and expands on the ‘exceptional circumstances’ test of NPPF Paragraph 116, an assessment of the Proposed Scheme against the criteria of CS12 is set out below.

There are no alternati ve sites available outside the National Park / there is a proven overriding national need that cannot be met in any other way 75) The Environment Agency plans to revoke Unite d Utilities’ existing abstraction licence at Ennerdale Water. The revocation of the licence would res ult in a substantial supply-demand deficit in the West Cumbria Resource Zone. 76) Following an options appraisal and selection process, United Utilities identified three feasible options in its draft Water Resources Management Plan to address t his deficit, which were:  The Thirlmere transfer option, which com prises the pipeline transfer of water to replace all sources within the West Cumbria Resource Zone  The local sources option, which provides a selection of ground and surface water sche mes, together with the necessary connectivity improvements, within the West Cumbria Resource Zone  The Kielder transfer option, which comprises the pipeline transfer of water from the Northumbrian Water area to replace all sources within the West Cumbria Resource Zone. 77) An Examination in Public (EiP) on the draft Water Resources Managem ent Plan was held in September 2014, following which o n 9 Decemb er 2014, the Secretary of State for Environment, Food and Rural Affairs directed that United Utilities should proceed with the Thirlmere option. 78) It is therefore considered that there is a proven overriding national need for the scheme due to the protection of an internationally protected species, and if a new water source is not delivered in advance of the licence revocation at Ennerdale Water there would be no legally available abstraction to provide public water supply to the population currently fed by Ennerdale Water. United Utilities would therefore be in breach of its obligations under the Water Industry Act 1991 to maintain a water supply system. 79) It is also considered that alternative sites outside the Lake District National Park have been explored through an options appraisal and E xamination i n Public, and the Secretary of State has directed United Utilities to proceed with the option of providing drinking water for West Cumb ria from Thirlmere Reservoir.

The development is d esigned and carried out to cause least practicable harm 80) Once the Thirlmere solution had been selected, a number of preliminary options for making this connection were developed and considered, taking into acc ount environment and sustainability considerations (e.g. ecology, landscape and visual, archaeology, impacts on businesses and local communities etc.). The chosen option was selected as it ensured a sus tainable solution, the new water treat ment works was outside of the boundary of the Lake District National Park and the pipelines c ould be located primarily in agricultural land to avoid disruption to the highway whilst minimising the impact on environmentally sensi tive areas w herever possible. 81) The route of the Raw Water Aqued uct has been carefully designed to ensure the water can be ‘gravity fed’, whilst minimising and avoiding impacts upon protected and sensitive areas, including Naddle Beck SSSI and SAC, Shoulthwaite Moss County Wildlife Site, ancient woodland, Armthwaite Hall and the associated grounds, the Lake District Wildlife Park, Isel Hall, the River Derwent, Gil l Wood ancient woodlan d, Gill Beck SSSI and the village of Blindcrake with Blindcrake Conservat ion Area and listed buildings.

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Planning, Design and Access Statement

Any detrimental effec ts on the special qualities of the National Park can be adequately mitigated 82) The ‘special qualities of the National Park’ are listed in the Core Strategy as its:  Complex geology  Diverse landscape  Concentration of Common Land  Unique mosaic of lakes, tarns and rivers  Wealth of habitats and wildlife  Extensive semi-natural woodlands  History of tourism and outdoor activities  Opportunities for quiet enjoyment  Open nature of the fells  Rich archaeology  Distinctive settlement character  Celebrated social and cultural roots. 83) A full Environmental Impact Assessment has been carried out and the ES summarises all the proposed mitigation measures in Appendix 23.1. The development has no overall adverse impacts on the local economy 84) A full numerical assessment of the economic impact of the Proposed Scheme on the local economy is contained within Chapter 16 of the accompanying ES. The chapter concludes that across the entire scheme there would be no significant positive or negative impacts on employment, economic development or the provision of tourism accommodation. Notwithstanding this, there are some positive effects of the scheme to the local economy which include inward investment and growth in employment opportunities into Cumbria during the construction phase. A resilient water supply provided by the proposed scheme is also essential to the growth and vitality of the local economy.

2.6 Allocations / Designations 85) The proposed scheme crosses the following allocations in the Local Plan Part Two - Allocations of Land DPD.  North Distinctive Area (Policy CS04)  Minerals Safeguarding Area (Policy CS30)  Conservation Area (Blindcrake – Policy CS27). 86) The proposed scheme lies within the North Distinctive Area (Policy CS04), which is one of five area based policies that sets out the Authority’s approach for each area. 87) Relevant to the Proposed Scheme from Policy CS04 is the following regarding landscape character: ‘We will use the Lake District Landscape Character Assessment to guide management of development and land use change. We will strengthen the landscape character of the North by:

 Conserving and enhancing the diverse patchwork of habitats especially water, moorland, woodland, gill and bog  Conserving and enhancing the historic landscape including historic route-ways, the distinctive pattern of field boundaries and walled enclosures, character of the vernacular bu ilt environment, and industrial archaeology  Protecti ng the skyline and views into and out of the area

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 Improving water quality in the north west catchments  Enhancing the sense of remoteness and tranquillity of the upland mountain massifs and less frequented fells north of Skiddaw and Blencathra. 88 ) The Lands cape and Visual Impact Chapter of the accompanying ES provides an assessment of the proposed scheme’s landscape impacts against the Lake District Landscape Character Assessment. An assessment of the Proposed Scheme’s landscape impacts is discussed in the policy assessment below. 89 ) Minerals S afeguarding Area (Policy CS30) states: ‘We will safeguard mineral resources from being unnecessarily sterilised by other forms of development by:

 identifyiing Mineral Safeguarding Areas (MSAs) for resources of local building stone, slate and high purity limestone and aggregates; and  not permitting development which would compromise the future extraction of imp ortant building stone, slate and high purity limestone at existing or former quarries.’ 90 ) Part 3 of the adopted Lake District National Park Authority Local Plan specifically covers the Minerals S afeguarding Area. As minerals can only be worked where they occur it is crucial that future access to minerals is not restricted by no n-mineral development. Minerals Safeguarding Areas are a way of protecting proven deposits of minerals which are, or may becom e, of economic value. They help to restrict non-mineral related development which would compromise the extraction of the mineral deposit in the future. 91 ) In the National Park, locally quarrie d building st one and slate contributes significantly to the distinctive character of many of the settlements and this feature is recognised as one of the ‘special qualities’. In addition, there are two granite quarries and two limestone quarries whi ch straddle, or are close to, the National Park boundary. They produce minerals to support the construction industry, steel industry, transport infrastructure and agriculture. 92 ) Policy MSA1: Minerals Safeguarding Areas states that permission will only be granted where the location of the proposa l relates to a settlement recognised bby Core Strategy Policy CS02; or the proposal can demonstrate that it will not affect the overall value of the mineral resource; or the mineral can be extracted satisfactorily prior to the development taking place; or the development is of a temporar y nature, can be completed and the site restored to a condition that do es not inhibit extraction within the timescale that the mineral is likely to be needed or there is an overriding need for the development. Figure 1 of the Local Plan Part 3 shows the extent of the MSA which covers large parts of the Lake District National Park area. Although the proposed scheme largely avoids the MSA as it is located primarily south of Thirlmere Reservoir, there are sections where the route crosses the MSA and is close to Moota Quarry (which is in Allerdale but close to loc al authority boundary). 93 ) The soils, geology and hydrogeology chapter of the ES has conducted a detailed analysis of the potential impacts on the MSA as a technical appendix to this chapter. This shows that very sma ll sections of the proposed scheme a round the Bridge End Connection fal l within the MSA for Igneous and/or Metamorphic Rock and Sand and Gravel. Moota Quarry lies approximately 200 m northeast of Scheme Section 7 (WTW – Quarry Hill). Given its current status as an active limestone quarryy this is an important economic asset for the National Park. Even though it is in Allerdale, Moota Quarry is referred to in the supporti ng paragraphs of the Lake District National Park Authority Local Plan part 3. 94 ) In terms of the purposes of Policy MSA 1, the ES chapter has concluded that the proposed scheme would not impact on the overall value of the mineral resource and long term operational impacts on the objectives of the MSA are unlikely. Whilst it is recognised that the presence of underground and above ground infrastructure has the potential to impede the future extraction of minerals, the proposed scheme only impacts on very small and discrete areas of the MSA. There are no records which indicate the presence of minerals where the scheme crosses the MSA, nor any outstanding planning proposals for minerals extraction. The depths of foundations and the pipeline trenches are

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Planning, Design and Access Statement

unlikely to encounter minerals even if they are present in the ground. Should they b e discovered this would be at such a small scale that it would not be economically viable to extract the mineral. 95) It is also noted that permission to extend Moota Quarry was granted by Allerdale Borough Council in November 2014. This permission provides 3.7ha of additional land for limestone ext raction and extends the existing life of the quarry beyond 2016. This is likely to prov ide adequate supply for the foreseeable future and it considered more likely that mineral extraction would occur at existing quarries rather than the development of new mineral deposits. The route of the proposed pipeline in Scheme Section 7 has been designed to minim ise impacts to the ongoing operation of Moota Quarry by crossing to the east of the . 96) The Proposed Scheme crosses through a smal l section within the Blindcrake Conservation Area. The policy which is relevant to the Conservation Area is Policy CS27: The Acclaimed Historic Environment, which states: ‘We will protect the internationally acclaimed historic environment of the Lake District National Park.

Development proposals will seek to conserve and enhance the character, integrity and setting of the historic environment including… no n-statutory sites includin g historic pa rks and gardens, conservation areas, and designated or propose d world heritage sites.’

97) The scheme has been subject to detailed assessment and discussed with the Heritage Advisor of the National Park. Where possible the route has been realigned and United Utilities is committed to continued discussions during the planning application stage to ensure potential impacts are adequately mitigated. It is considered that the Proposed Development would not affect the character, integrity and setting of the Blindcrake conservation area following post-construction reinstatement.

2.7 Planning Assessment

2.7.1 Inntroduction 98) To support the section above, the analysis belo w summaris es the environmental impacts of the proposed scheme agai nst the context and detailed planning policy objectives of the NPPF and the adopted Local Plan. It is not intended to duplicate the ES and should be cross referenced with this document. 99) In this context, it is recognised that Policy CSO1 of The Lake District National Park Authority Local Plan Part 1 Core Strategy (2010) (“ the Core Strategy”) has overriding importance as this sets out the principles of any development withi n the nationally significant and distinctive nature of the Lake District and this policy reflects the ‘Sandford Pri nciple’ which is where ‘if it appears that there is a conflict between National Park purposes we shall attach greater weight to the purposes of conserving and enhancing the natural beauty, wildlife and c ultural heritage of the La ke District National Park. 100) A key obj ectives under Paragraph 109 of the NPPF is that the planning system should ‘contribute to and enhance the natural and local environment by minimising impacts on biodiversity and preventing development from contributing to unacceptable water pollution’. National policy regarding flood risk is set out in section 10 of the NPPF, Meeting the Challenge of Climate Change, Floodi ng and Coastal Change. Paragraph 94 requires LPA’s to adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk. Paragraph 99 states that: new development should be planned to avoid increased vulnerabi lity to the impacts arising from climate change. 101) Also relevant to the Proposed Scheme is NPPF paragraph 12 concerning the conservation of t he historic environment. The NPPF recognises that heritage assets are an irreplaceable resource that should be conserved in a manner appropriate to their significance. Significance is defined by the NPPF as ‘the value of a heritage asset to this and future generations because of its heritage interest’. This significance may be related to archaeological, architectural and artistic or historic elements, and may also derive from the setting of the site (PParagraph 56)6 .

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2.7.2 Landscape and Visual Assessment

Planning Policcy 102) A core principle of the NPPF is that planning decisions should recognise the intrinsic character and beauty of t he countryside. Referring to the special status of National Parks, paragraph 115 assigns National Parks with ‘the highest status of protection in relation to landscape and scenic beauty’ and states that ‘great weight should be given to conserving landscape and s cenic beauty in the National Park’. This principle is supported by other policies of the NPPF including Paragraph 17 (General Planning Principles) and Paragraphs 58 (good design and landscaping). 103) The Core Strategy emphasises the special status of the N ational Park and Policy CS10: Achieving design excellence states that ‘deve lopment should complement the outstanding quality of the landscape and the council will support design that reinforces the importance of the local character and distinctiveness of the landscap e’. Policy CS11: The sustainable development principles require new development to ‘conserve and enhance the character and quality of the local landscape, of the wider countryside and of the built environment’ and Policy CS25: Provides protection for the spectacular landscape through a character-bas ed approach to conserve and enhance the Lake District’s landscape. It also reaffirms the position that the highest level of protection would be given to the landscape. Any development should maintain and enhance local distinctiveness, sense of place and tranquillity. 104) The saved Local Plan policy (1998) Policy BE1: Roof and Wall Materi als states that the council will ‘require materials for walls and roofs of development to be in keeping with local vernacular tradition’. Relevant policies from the Management Plan for the English Lake District (2015) is SL 1: A world­ class living cultural landscape, which states that the Partnership’s strategy is to ‘protect and conserve the extraordinary beauty and harmony of the Lake District landscape and attributes of Outstanding Universal Value and Special Qualities by using and promoting the Lake District Landscape Character Assessment to inform land management and development management decisions’.

Assessment against Planning Policy 105) Chapter 7 of the accompanying ES provides a summary of the Landscape and Vis ual Impact Assessment (LVIA). The LVIA has considered the potential effects on both the landscape and visual amenity within a study area determ ined by the geographical , cultural and visual context of the surroundin g landscape . Related landscape character assessments, such as the Cumbrian Landscape Character Assessment, have been consulted and their proposed guidelines have been considered and, where applicable, incorporated into the scheme. 106) Without mitigation, potential effects on landscape character would be most significant during the construction phases because of the loss of hedgerows, hedgerow trees and dry stone walls as well as the influence of RWA construction activities within a typically rural landscape. Visual draw associated with temporary compounds, pipeline construction activities and vehicle movements would alter local rural charact eristics. 107) Potential effects on landscape character resul ting from the pipeline installation would have reduced by the first Operational Year (the first year after construction is completed) but it would take up to five years for the hedgerows, trees and vegetat ion to establ ish. By year 15 after construction the impacts would have reduced to a po int where they are barely noticeable. 108) The new small scale structures at the Bridge End Connection would be located within the exist ing WTW site. Above ground valve structures and kiosks along the RWA would similarly be unobtrusive. The chan ge to landscape character would the refore be perceived only locally and within a relatively intricate Landscape Character Type. Overall there would not be a significant change to landscape character. 109) The siting and design of the proposed scheme has been informed by the relevant landscape character documents to minimise the impact on the sensitiv e landscape and special qualities of the Lake District National Park. During design development, a series of measures have been developed to avoid, reduce or offset the impact of the Proposed Scheme. Along the RWA pipeline, the

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narrowing of the working width – at intersections with field boundaries, woodland an d roads – would help to reduce the overall area of impact and m aintain the screening benefits of existing landscape features. Flexibility has been built into the working area to allow for further avoidance of features. This ensures that impact on landscape character is kept to a minimum and any adverse effects would be mostly temporary. Long-term landscape effects would be limited in scale and generally localised. 110) In terms of visual amenity, the majority of the proposed sc heme would comprise buried pipelines and would not be visible following the reinstatement and establishment of the proposed planting. Above ground development would be mainly limited to service kiosks and small buildings at the Bridge End connection point. As a result, the sensitive landscape of the Lake District National Park would be conserved and largely un affected by the proposals. Where above ground development is unavoidable this has been designed and located to minimise its visual impact. 111) Within the Lake Distri ct National Park, the pro posals would be largely temporary and the reinstatement of features would be undertaken following the completion of the works. It would n ot alter the distinctiveness, sense of place or tranquillity of this important landscape. As stated earlier in Section 2 of this report a detailed Environmental Masterplan is included within the accompanying ES which proposes the reinstatement of removed site features e.g. stone walls, fences, hedgerows and watercourses. 112) The design of the pro posed scheme with the mitigation measures incorporated is sensitive to the intrinsic beauty of the National Park in accordance with Paragraphs 17, 58 and 115 of the NPPF. Careful consideration has been given to the appearance of construction materials and remedial landscape works so that the proposed scheme meets the objectives of Policies CS10, CS11 and CS25 of the Lake District National Park Authority Local Plan and Policy BE1 of the Lake District National Park Authority Saved Local Plan.

2.7.3 Arboriculture

Planning Policcy 113) Objectives for trees a nd other habitats are provided at paragraph 118 of the NPPF:

‘planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including a ncient woodland and the loss of aged or veteran trees found outside a ncient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss’ 114) Relevant policies from the Saved Local Plan Policies (1998) are Policy NE12 - Protection of Woodlands and Trees, which states that ‘Development which involves or would lead to the clearance of or damage to semi-natural or amenity woodland or important trees will not be permitted unless the harm to landscape, amenity, nature conservation interests or cultural heritage is outweighed by the need for the development and, where appropriate, mitigation or compensatory measures can be secured by the imposition of planning conditions or the securing of planning obligations by agreement to minimise the harm caused.’ 115) A relevant policy from the Management Plan for the English Lake District (2015) Policy SL 6 - Well considered tree and woodland establishment and improvement, which states: the strategy to give priority to semi-natural woodland and other identified woodland where there is a significant opportunity to enhance their resilience and contribution to the landscape including the attributes of Outstanding Universal Value, biodiversity, recreation, flood prevention, carbon storage and productivity.

Assessment against Planning Policy 116) Whilst the routeing of the pipeline has tried to avoid direct impacts on trees this has not always been possible. Impacts would arise during construction through temporary or permanent land take associated with the pipeline, temporary construction compounds and laydown areas, and tempo rary access routes.

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Planning, Design and Access Statement

117) As report ed in the ES , the required working width of the pi peline during construction is generally 40 m. At locations where environmental constraints are encountered within the working width, it may be possible to reduce the working width over short distances to minimise impacts on these constraints (for example, at hedgerows or watercourse crossings where the working width may be reduced to approximately 20 m). Similarly, contractors may be able to realign the pi peline away from the centre line of the construction corridor to avoid particular constraints. In the case of arboricultu ral constraints, for example, this may mean that tree root protection areas falling withi n the working width may be avoidable. The Environmental Masterplan presented in the E S indicates where tree root protect ion areas within the working width may be avoidable through appropriate construction managem ent. 118) Trees which have special protection under the Planning Acts are those with Tree Preservation Orders or which are within a Conservation Area. In addition, the NPPF protects ancient woodlands and veteran trees from development unless the development clearly outweighs the loss. The ES identifies that there is one Conservation Area, Blindcrake, affected by the proposed development. 119) The scheme would potentially impact on trees and hedgerows in the Blindcrake Conservation Area (refer to the ES). There is one TPO at Lorton Park but there would be no direct impacts on this tree and it woul d be retained. The ES also identifies a TPO covering six trees and another TPO covering a single tree at Nether Place, Keswick, but as this section of works is to be tunnelled they would not be affected. 120) Up to four hectares of Ancient and Semi-Natural Woodland and Planted Ancient Woodland Sites would be affected by the working width at Briery Wier, Gill and Ellerswood, Messengermire Wood and Stormwood. 121) Apart from trees whic h are afforded special protection under the Planning Acts, trees and other vegetation are classified according to their quality and estimated remaining life. The highest quality trees are grade A and the poorest quality grade C, whilst some trees are unclassified. 122) Table 2.6 below summarises the number of trees identified either along or adjacent to the working width within the Lake District National Park.

Table 2.6 – Trees, Groups of Trees, Hedgerows and Woodlands Surveyed within the Lake District National Park GRADE CATEGORY TOTALS A B C U TREES 117 430 106 15 668 GROUPS 22 182 104 2 310 HEDGES 0 204 6 0 210 WOODLANDS 11 38 9 1 59 TOTALS 150 854 225 18 1247

123) Sixteen of the trees identified above are veteran trees. Veteran trees are trees which, due to their age, size or condition, are of cultural, historical, landscape or nature conservation value. Where trees or hedgerows need to be removed, the aim is as far as practicable to reinstate with new planting at the same location or nearby within the planning application boundary. However, as tree planting would be restr icted over the permanent easement of the pipeline, this may lead to a net loss of trees within the planning application boundary. Compensatory planting would therefore provide new trees at a greater ratio to those lost. A location in the Ennerdale Valley has been identified by the applicant as an are a for replacement planting. Tree pla nting would also be supported through the provision of a community grant fund under which local groups would be eligible to apply for monies to support local tree planting initiatives. Section 5 of the Planning Statement provides m ore details of the proposed compensation. 124) It is also important to avoid physical damage to trees whic h remain in situ including damage to their roots. Other mitigation measures include fencing prescribed to British Standard BS5837:2012 a nd exclusion zones around the Root P rotection Zones.

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The loss of trees is one of the more significant impacts of the scheme but the applicant recognises this and proposes a scheme of compensatory planting. As such it is considered that the detailed requirements of the saved Local Plan policy have been met.

2.7.4 Water Enviro nment

Planning Policcy 125) Paragrap h 109 of the NPPF states that the planning system should contribute to and enhance the natural and local environment by minimising impacts on biodiversity and preventing development from contributing to unacceptable water pollution. 126) Relevant policies from the Core Strategy (201 0) include Policy CS11 where the sustainable development principles include ‘that development should avoid adverse effects on, and where appropriate enhance, the quality or quantity of natural resources including water’. Policy CS26, Geodiversity and Biodiversity, affords protection to habitats and water environments . 127) A relevant policy from the Lake District Nation al Park Partnership’s Plan is Policy SL5 Improved water quality and resources in lakes, tarns, rivers, ground waters, and sea, which states the strategy to ‘achieve ‘good’ or better than ‘good’ water quality as defined by the Water Framework Directive in all lakes, rivers, tarns, and ground waters by implementing best practice catchment management’. 128) As referred to in Policy SL5, the Water Framework Directive (Directive 2000/60/EC) is the European Union’s (EU) water legislation that came into forc e in 2000, with the overarching objective to get all water bodies in Europe to attain good or high ecological status .

Assessment against Planning Policy 129) Chapter 9 of the accompanying ES provides an assessment on the Water Environment, which encompasses all watercourses including ditches, gills, becks, rivers and standing waters such as ponds, lakes and reservoirs. The assessment prior to mitigation has identified that pipeline construction, the construction and operation of new point features and operational changes to water resources have the most potential to cause impacts including some pos itive impacts. 130) A series of standard mitigation measures have been proposed to help manage pollution risk and reduce the potential im pacts of the construction on the water environment. These mitigation measures include good construction practice as defined in the project’s CCoP and adherence to the Environment Agency’s guidance on Pollution Prevention Guidelines (PPG), appropriate scheme design and environmental monitoring during construction. 131) The highest risk of potential impacts is from construction activities close to watercourses or associated with river/stream crossings. In addition to the standard mitigation measures listed above, additional mitigation is proposed at river crossings; including the selection of approp riate river crossing techniques and access methods based on river-specific characteristics. A land drainage strategy and water quality monitoring strategy have also been develope d. 132) The combined effect of the design with associated mitigati on measures is that the water environme nt would be protected and the risks of pollution reduced to a minimum. Avoiding adverse effects on the quality of the water e nvironment meets the requirements of the NPPF and Local Plan Policies CS11 and CS26.

2.7.5 Flood Risk

Planning Policcy 133) Paragrap hs 100, 101 and 102 of the NPPF set out the need for the ap plication of the Sequential Test to steer new deve lopment to areas with the lowest probability of flooding and if necessary, the Exception Test for the development to be located in zones with a lower probability of flooding. Further detailed guidance on flood risk is set out in the Technical Guidance to the National Planning Policy Framework (201 2).

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Planning, Design and Access Statement

134) Relevant Core Strategy policies include Policy CS11 sustainable development principles as this requires new development to reduce flood risk within the development and elsewhere and Policy CS17: Development and flood risk, which restates the requirement of national policy for development to comply with the Sequential Test and the Exception Test. 135) Relevant from the Management Plan for the English Lake District (2015) is SL4 - Increased resilience to flooding, which aims to Increase the resilience of the Lake District to flooding events and to mitigate and adapt to the increased likeli hood and severity of flooding arising from climate change.

Assessment against Planning Policy 136) A series of Flood Risk Assessment (FRA) reports have been produced to examine the level of risk from all potential sources of flooding from both construction and operational phases. The FRA’s address both the potential risk posed by the scheme to increasing flood risk in the local area, while also exami ning the potential risks posed by flood events upon construct ion operations and the operational infrastructure. 137) The proposed works at the Bridge End Connection are located in an a rea identified as Flood Zone 3. Any works items in the Flood Zone that could be vulnerable to water ingres s, would need to be appropriately elevat ed above the 1 in 100 year (1 %) flood level plus freeboard allowance. Warning signage would also be provided along the proposed access road to provide details of the risk posed and emergency warning procedures . All additional surface water runoff generated by the Bridge End Connection would need to be attenuated on site and discharged into a local watercourse at the greenfield runoff rate. 138) Whilst the Bridge End Connection includes development within Flood Zone 3, sequential testing in the FRA has demonstrated that no alternative sites are available so the Proposed S cheme could not be located in a lower risk flood zone. As the development is classed by the technical guidance t o the NPPF as water compatible and is designed to be resilien t to flooding, the Exception Test is also passed. Design considerations include dry proofing underground structures and raising any operational equipment which could fail in a flood situation above anticipated flood levels. 139) The impacts of the RWA on individual properties which are potentially vulnerable to flooding from the development are also examined by the series of FRA. It is concluded that specific mitigation is not required as a result of the proposed scheme. 140) With these mitigation measures in place the risk of flooding during the operational period is identified as low. In addition, the impact of the proposed scheme on flood risk elsewhere is not considered to result in any significant, adverse effects. 141) The proposed scheme therefore meets the objectives of the NPPF as it passes the tests required. Measures to reduce the rate of surface water run-off and the flood resilient design are consistent with the objectives of the Management Plan.

2.7.6 Ecology and Nature Con servation

Planning Policcy 142) Paragrap h 118 of the NPPF lists principles to ensure that biodiversity is conserved and enhanced and that any developm ent that detrimentally affects or causes loss to local ecology should have benefits that clearly outweigh these impacts. In addition to the NPPF, the Biodiversity 2020 strategy’s mission is to ‘halt overall biodiversity loss’ and to ‘retain the protection and improvement of the natural environment as core objectives of the planning system.’ 143) In addition to Policy CSO1 relating to the principles of conservation, relevant policies from the Core Strategy (2010) are Policy CS11: Sustainable development principles which include that development will avoid adverse effects on the quality and quantity of natural resources including biodiversity and Policy CS26: Geodiversity and biodiversity, which seeks to protect the important geodiversity and biodiversity in the Lake District National Park and requires mitigation and compensation to minimise the loss of geodiversity or biodiversity interests

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144) In addition, action plans under the UK Biodive rsity Action Plan (BAP) are implemented locally through the Cumbria BAP, which includes spec ies and habi tat action plans that outline broad and specific objectives for conservation and restoration of habitats and species of principal importance.

Assessment against Planning Policy 145) The ES confirms that construction activities in the absence of mitigation have the potential to cause habitat loss (both permanent and temporary), habitat fragmentation, habitat degradation or phys ical damage, pollution, introduction of invasive species, disturbance to species or habitats, direct injury/mortality to speci es, and hydrological changes through ground disturbance. 146) A series of broad bas ed mitigation measures are proposed to help reduce the sign ificant impacts of construction on ecological receptors. These include targeted pre-construction surveys undertaken by an experienced ecologist to ensure previous data are still relevant, oversight of ecologically sensitive works by an Ecological Cl erk of Works, temporary fencing to avoid incursion into sensitive adjacent habitats, implementation of the Environment Agency’s Pollution Prevention Guidelines and United Utilities’ Biosecurity Policy, and adheren ce to industry-standard environmental safeguards as detailed in the CCoP. In addition, construction works would be undertaken wherever practicable outside of key migrating, breeding and/or hibernation seasons (e.g. for red squirrels, birds, bats and salmonid fish) and not during the night time near sensitive habitats and species (e.g. for bats, otters and salmonid fish). Wherever practicable, all habitats would be restored to pre-construction conditions with elements of enhancement included (e.g. for birds, bats, red squirrels and reptiles). 147) With the mitigation introduced above and as detailed in the ES, residual construction phase effects are expected to be not significant for Great Crested Newts and other amphibians, reptiles, and specific bird receptors (including osprey, birds using Bassenthwaite Lake SSSI/NNR, and birds using waterbodies). 148) For other receptors, there is potential for residual impacts in the short to medium term for designated sites, other notable habitats, bats, otter, red squirrel, other bird receptors and aquatic ecology receptors, although the long term effec ts would also be not significant. However, the loss of woodland (including Ancient Woodland) cannot be directly mitigated and therefore as referred to in the Arboriculture section compensatory woodland planting is proposed at Ennerdale (also see section 5 of this report). 149) At Shoult hwaite Moss, it is proposed to turn additional land into mossland habitat to mitigate for the potential impacts of the pipeline construction. 150) The design of the scheme has carefully considered the ne ed to preserve and enhance biodiversity within the Lake District and it is considered that these assessments are compliant with Paragraph 118 of the NPPF and Lake District National Park Authority Core Strategy policies CS11 and CS26.

2.7.7 Cultural Heritage

Planning Policcy 151) Under Paragraph 128 of the NPPF, applicants for planning permission are required to provide a description of the significance of any affected heritage assets and their settings in sufficient detail to understand the potential impact of the proposal on them. In making planning decisions, considerable weight is to be given to the preservation of desi gnated heritage assets. 152) Paragrap h 132 of the NPPF states that where development would lead to substantial harm or total loss of an asset, local planning authorities are instructed that they shoul d refuse consent, unless it can be demonstrated that it is necessary to achieve substantial public be nefits that outweigh that harm or loss. 153) The Core Strategy Policy CS01, as referred to previously, places overriding significance of conserving and enhancing the cultural heritage of the National Park.

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Planning, Design and Access Statement

Assessment against Planning Policy 154) The proposed construction of the RWA would impact on kn own buried archaeological remains and the setting of known archaeological assets. It could also adversely impact on built heritage through the removal of gateposts and elements of structures and historic landscape types that contribute to the distinctive agricultu ral nature of the Lake District. The majority of the impacts on heritage as sets would be during the co nstruction phase and wo uld comprise permanent physical effects on undesignated archaeol ogical remains and temporary effects on the setting of historic buildings and historic landscape types. 155) Measures to reduce potential impacts on the historic environment have been incor porated into the design throughout its development to avoid and preserve heritage assets. The area around Blindcrake is an example of this where the desi gn has been changed through narrowing of the working width and detailed routing to achieve preservation i n situ of areas of landscape that contribute to the Lake Districts Outstanding Universal Value (OUV). Further detailed assessment would be carried out post planning submission to identify whether any further mitigation can be developed. 156) Mitigation agreed with the relevant heritage bodies comprise set-piece excavation, topographic survey, watching brief, photographic survey and landscape planting/reinstatement. Overall as a result of design decisions and the agreed mitigation, the impact on Cultural Heritage would be kept to a minimum in accordance with the NPPF and the Core Strategy objective to conserve the cultural heritage.

2.7.8 Soils Geology and Hydrogeology

Planning Policcy 157) The overriding national objective at Paragraph 109 of the NPPF is that ‘the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, geological conservation interests and soils, preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.” 158) The relevant Core Strategy policies are Policy CS11: Sustainable Development principles require development to avoid adverse impact on the quantity or quality of natural resources including soils and Policy CS26: Geodiversity and biodiversity protects the important geodiversity of the Lake District National Park and will not permit develo pment detrimental to the geodiversity of areas and features including Regi onally Important Geological / Geomorphological Sites. 159) In addition Policy CS30: Safeguards mineral resources being unnecessarily sterilised by other forms of development. The Saved Local Plan P olicies (1998) includes Policy MSA1: Minerals Safeguarding Areas, which states that development within Minerals Safeguarding Areas which can demonstrate they will not affect the overall value of the mineral resource, or there is an overridin g need for the development. 160) The Management Plan for the English Lake D istrict (2015) includes strategy SL 3 - Wise use o f geology contributing to local and national needs and demands, which seeks to ensure geological Sites of Special Scientific Interest and Local Geological Sites benefit fro m positive conservation management.

Assessment against Planning Policy 161) The ES describes desk and field studies to establish whet her there is any potentially contaminated land at Bridge End Connection or along the RWA. Additionally the ES examines, whether potential changes to base flow in river streams could occur, the protection of bedrock and secondary aquifers from groundwater pollution, avoiding buildings and infrastructure subsidence from dewatering (specifically through dewatering at the River Greta and A66 crossing), avoiding any damage to Gill Beck Geological SSSI and avoiding any degradation of pea ty soils southeast of Bassenthwaite Lake.

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Planning, Design and Access Statement

162) The geological SSSI at Gill Beck near Blindcrake would not be adversely affected by the proposed embankment which would carry the RWA over this natural ravine. 163) Measures to reduce potential impacts have been incorporated into the scheme design. For example, this includes managing groundwater drainage in the Derwent and Naddle catchments, avoiding impacts on protected and valued geological sites through routing the pipeline and associated infrastructure to avoid s ensitive sites and reducing the risks of encountering potential sources of contamination through routing decisions where this has been possible. Where preliminary risk assessments have identified contaminated land as a possibility, further ground investigations would be carried out prior to any development taking place. 164) In addition, the risk of pollution to soils and groundwater an d other har mful change s to the hydrogeological environment would be reduced through the application of the plans and principles set out in the Construction Strategies described in the ES and Environment Agency PPGs. For example, the implementation of a s oil management plan and good remediation practice would be followed by backfilling pipe trenches with material having a similar perm eability to the natural in-situ deposits. 165) A scheme of this scal e and complexity would carry some residual risks but Chapter 13 of the ES assesses these impacts and demonstrates that these risks have been mitigated as far as practicable and are mainly limited to the construction phase only. The Proposed Scheme therefore meets the objectives of the NPPF and the Core Strategy in terms of protecting soil s and the hydrogeological environme nt from pollu tion. The earlier section covered the Mineral Safeguarding Area (MSA).

2.7.9 Materials and Waste

Planning Policcy 166) National policy relatin g to waste is contained in National P lanning Policy for Waste (October 2014) which is separate to the NPPF. This document highlights the need for delivery of sustainable development and resource efficiency by driving waste management up the waste hierarchy. 167) Paragrap h 8 requires that developments make sufficient provision for waste management and the handling of waste arising from the construction and operation of development maximises reuse/recovery opportunities and minimises off-site disposal. 168) Relevant from the Core Strategy (2010) is Policy CS11 where sustainable development principles require new development to provide high quality, sustainable design and construction, including minimising waste.

Assessment against Planning Policy 169) Early scheme designs involved route optimisation for the best overall solution which included avoiding waterlogged and soft ground where pr acticable so that excavated soil materials would be more readily re-usable or recyclable, reducing materials use and eliminating waste. United Utilit ies would optimise the reuse of excavated material on-site withi n the scheme and current predictions indicate this would comprise at least 82.5 % reuse, with the potential for this to be exceeded. Contractors would be required to develop a Site Waste Management Plan (SWMP) for construction contracts and engage with competent waste management and recycling sub-contractors to ensure that waste is managed in accordance with the waste hierarchy. There would be no significant change in materials use or waste generated during operation and maintenance. 170) Overall the positive measures to reduce the amount of materials used to construct pipes, the high level of re-use of excavated material and other waste minimisation and segregation measures make a significant contribution to reducing the resource implicatio ns of the project in line with the Waste Hierarchy as encompassed in National Waste Policy.

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2.7.10 Public Access and Recreation

Planning Policcy 171) Paragrap hs 73 and 74 of the NPPF state the i mportance of high quality open spaces and opportunities for recreation in contributing to the health and well-being of communities and prohi bit the loss of open space and recreational land. Paragraph 75 seeks to protect and enhance public rights of way and access and states that local authorities should seek opportunities to provide better facilities for users. 172) Relevant policies from the Core Strategy (201 0) are Policy CS14: Sustainable transport solutions, which states that the rights of way network will be maintained and improved and Policy CS21: Open space and recreation, which states that the Nat ional Park Authority will protect existing open spaces (including rights of way) and only allow develop ment on sites in exceptional circumstances. 173) Also of relevance is the Cumbria Countryside Access Strategy 2014 to 2019 which provides the strategic framework for the management and improvement of countryside access and recreation in Cumbria (including the Lake District National Park). One of the four strategic aims of the docum ent is to: ‘Prov ide high quality, well mai ntained access to the countryside including the public rights of way netwo rk, open access land, access to water and other means which meets the needs of its users’.

Assessment against Planning Policy 174) The pipel ine easement and temporary fencing would directly or indirectly affect approximately 73 Public Rights of Way (PRoW). Affected PRoWs are described in the ES. Where it is technically possible and safe to do so, access would be maintained across the working width using wicket gates but for the safety of the general public the footpaths would be closed for a short duration at the time of the pipe laying in the vicinity of the PRoW. Consultation with PRoW officers and local groups would be carried out so that the clo sures can be publicised and the disturbance minimised. In addition, during the construction period a numb er of measures to reduce nuisances (including dust and noise) experienced by users of the PRoWss would be put in place; these are det ailed within the CCoP. 175) Within the Lake Distri ct National Park affected footpaths include the lo ng distance footpath Cumbria Way, Keswick Railway Path, NCN71 (Coast 2 Coast), NCN 10 (L and D Loop) and High Rigg Open Access Area. Where it is technically possible and safe to do so wicket gates would be installed in the temporary working area demarcation fence line to allow the public continued access across the working wid th. For the safety of the general pub lic 28 PRoWs would need to be closed for a short duration at t he time of the pipe laying in the vicinity of the PRoW. Diversi on routes to link PRoWs and maintain connection would also be maintained where possible subject to landowner agreement including formal diversions for NCN71 and NCN 10. 176) Access to twenty-seven recreational facilities would be affected including Dodd Wood Visitor Centre and Calvert Trust Adventure Centre whi ch are considered regionally important. A traffic management system would be implemented, meaning that access woul d be maintained at all times. 177) In terms of compliance with planning policy, it is inevitable that a scheme of this size and complexity would result in some short term disruption to the PRoW network. This di sruption would be limited to temporary closures and traffic management albeit this would need to be managed carefully and agreed with users, landowners an d the rights of way officeers.

2.7.11 Socio Economic

Planning Policcy 178) Section 3 of the NPPF relates to supporting a prosperous rural economy and state s that ‘planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable development’. To promote a strong rural economy, planning should support sustainable growth and expansion of all types of rural business, promote

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the development of agriculture, support sustainable tourism and promot e the retention of local services and community facilities. 179) Relevant policies from the Core Strategy (201 0) include Policy CS22: Employmen t, which supports business and employment opportunities that will diversify and strengthe n the economy of the Lake District National Park and Policy C S24: Delivering a sustainable tourism of a high quality which seeks to provide a sustainable tour ism experience for the diverse range of visitors to the National Park. 180) Relevant strategies from the Management Plan for the English Lake District (2015) include PE 3 - Increasing the number of staying visitors and P E 4 - A Year Round Visitor Industry, which aim to promote tourism in the Lake District and increase the number of visitors.

Assessment against Planning Policy 181) Potential impacts that have been considered within the social and economic chapter of the ES include those on local employment (directly and indirectly and economic and labour market forecasts are provided in the ES), impacts on tourism including the availability of visitor accommodation, maintaining access to community facilities and social infrastructure and the impacts of severance. 182) Across the Lake District, it is expected that there would be 24 resident ial, commercial or community properties or facilities that are expected to experience severance. These are all short term effects, with a maximum length of some 10 weeks. There are 18 residential, commercial or community properties that are expected to be affected by temporary land take. During this period some disruption to everyday routines may occur in the communities of Bassenthwaite, Underskiddaw and Blindcrake. 183) Mitigation has been proposed to reduce or prevent an additional four isolation impacts i.e. properties or communities experiencing significant levels of severance. This mitigat ion would take the form of a commitment by the applicant not t o close mult iple roads used by a single community at the same time 184) Overall the proposed scheme is consistent with social and economic planning objectives in that a key purpose of the scheme is to protect a sensitive environment and that whilst some disruption to communities and indivi duals is anticipated during constructi on, this would be temporary in nature and would be managed in consultation with local residents and service providers. In particularly the SCI outlines the consultation which has been undertaken wi th the touris m industry and local business groups to minimise disruption as far as is practicable during construction activity.

2.7.12 Agriculture and Sporting Land Use

Planning Policcy 185) Paragrap h 112 of the NPPF states that local planning authorities should:

“take into account the economic and other benefits of the best and most versatile (BMV) agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas o f poorer qualit y land in preference to that of a higher quality.” 186) BMV land is defined i n the Glossary at Annex 2 to the NPPF as land in grades 1, 2 and 3a of the Agricultural Land Classification (ALC).

Assessment against Planning Policy 187) The appli cation boundary has been developed in consultation with land owners and agricultural and sporting interests. This has resulted in an application boundary that, as far as is practically possible, minimises effects on agricultural soils, agricultural and sporting activities. This approach leaves 23 agricultural and sporting land interests within the Lake District National Park affected during construction.

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Planning, Design and Access Statement

188) Agricultural land is classified according to its quality and versatility with 1 been the best and 5 t he poorest (grade 3 is sub-divided into categories 3a and 3b). Grades 1, 2 and 3a are classified as the best and most versatile land (BMV). 189) Land quality for the whole scheme is predominantly Grade 3 or Grade 4 agriculture land. Based on the ALC Strategic Map information available to Natural Engl and, ALC surveys already undertaken and Soil Association data, it is considered likely that up to 20% of the land would be classified as BMV land, (assumed to be Grade 3a as no Gra de 1 or Grade 2 land is already graded as such within the study area). 190) The effects on soils and protection of their agricultural land capability is closely related to the procedures for stripping, storing and reinstatement of soils in all areas where the works are temporary and land is being returned to agriculture. A Soil Managemen t Strategy and Drainage Strategy would ensure good practice measures are employed and the s ustainability of soils and their agricultural land capability is protected. 191) Mitigation has been d eveloped to avoid or reduce construction and operational effects on agricultural and sporting activity. The Construction Strategy for Pipe Laying would be followed and specific mitigation measures would include provision of alternative access, reinstatement of boundary features and reinstatement of land drainage systems. 192) Whilst the applicant has taken all reasonable steps to avoid impacts, some limited residual impacts are unavoidable in a scheme of this scale and complexity. The applicant would work closely with all affected parties to mini mise disturbance and disruption as far as practicable.

2.7.13 Traffic and Transport

Planning Policcy 193) Objectives at Paragraph 29 of the NPPF state that ‘transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives’. In line with this objective, paragraph 32 of the NPPF requires all development that generates significant amounts of m ovement to be supported by a Trans port Statement or Transport Assessment. 194) Policy CS11 of the Core Strategy (2010) sustainable development principles aims to reduce people’s need to travel .

Assessment against Planning Policy 195) Chapter 18 of the accompanying ES includes an assessment of traffic and transport impacts on the local and strategic highway networks from traffic associated with the compound and laydown areas required for pipe laying during the construction period. The method of assessment has been agreed through discussions with Cumbria County Council as the local highway authority and as the strategic highways authority. 196) The assessment of traffic takes into account a representative construction period which reflects concurrent construction at various points on the proposed s chemes. It takes into account all materials brought into the site for the purposes of constructi on, as well as that removed as waste. Assumptions have bee n made based upon likely origins of materials and destination of waste, relative to the location of construction during May 2018. Vehicle routeings have been defined by the major strat egic corridors that provide east-west access to West Cumbria. 197) Baseline traffic counts were obtained at 27 junctions around the West Cumbria hig hway network, encompassing a 24 ho ur period within May 201 5. A spreadsheet model was produced to assess the impacts of construction traffic against background flows, relative to the thresholds prescribed within the Institute of Environmental Management and Assessment (IEMA) Guidance on assessment of traffic environmental impacts. This has identified locations which are sensitive to ch anges in traffic noise particularly if tolerance thresholds are exceeded during the construction period when set against the baseline position (either 10% HGV’s increase above existing or 30% total traffic).

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Planning, Design and Access Statement

198) There are no specific issues identified by the Transport Assessment which considers that impacts would generally be “slight” when reviewed against the key indicators of severance, pedestrian delay and amenity. Larger volumes of traffic associated with construction are generally present where background traffic is already high therefore the overall impact of the scheme during construction is identified as minimal. 199) The Trans port Assessment has demonstrated that whilst some locatio ns are sensitive to traffic increases the amount of additional traffic expected at these locations would only res ult in a slight change in local amenity. Furthermore any impacts would only occur for a temporary period during construction and any d iversions would not signi ficantly increase journey lengths. This is therefore in accordance with the objectives set out in paragraph 29 of the NPPF.

2.7.14 Noise and Vibration

Planning Policcy 200) Paragrap h 109 of the NPPF highlights the need to prevent developme nt from contributing to unacceptable levels of noise pollution. Paragraph 123 of the NPPF discusses the need to avoid noise from giving rise to significant adverse impacts on hea lth and quality of life, mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development and recognise that development will create some noise. 201) Relevant policies from the Core Strategy (201 0) include Policy CS11: Sustainable development principles, which requires development to minimise light and noise pollution.

Assessment against Planning Policy 202) Whilst elevated construction noise levels are predicted for many sensitive receptors close to the route of the RWA, the works would generally pass quickly through a given area and would therefore be short-lived. If rock is encountered, notably higher noise levels would be expected during rock breaking activities. Good practice guidance wo uld be followed, but there may be some locations, particularly where rock is encountered, that would require further noise mitigation to reduce noise impacts at nearby sensitive receptors. The ES chapter highlights those sensitive receptors most likely to experience significant noise impacts and suggests appropriate noise mitigation measures that may need to be employed. 203) Airborne noise impacts during enabling activities at the proposed WTW site compound are predicted to be significant at the Westwood and Williamsgate Farm receptors. No significant impacts are predicted at sensitive receptors close to the other temporary construction site compounds within the Lake District National Park. 204) It is anticipated that minor road crossings would be undertaken using open cut techniques over a 1­ 2 week period. Again, whilst elevated noise levels may be experienced, they are likely to be of short duration. However, there are some areas where more major works along existing roads would be required, taking place over a period of 8 to 12 weeks. Noise impacts at sensitive receptors close to these road/pipeline cro ssing points would be of longer duration and as such there is a greater potential for prolonged adverse effects. Within the LDNP authority area , properties on the edge of Keswick close to the A591 (east of Keswick) are expected to see significant construction noise impacts. Suggested noise mitigation measures to reduce the impacts are presented in the ES chapter. 205) Potentially significant noise impacts are anticipated from the pipeline crossing of the A591 (Chestnut Hill Road), south-east of Keswick, including during any directional drilling (should it be selected for this crossing point). Noise sensitive receptors are within 20 m of the crossing and due to the relat ively small s eparation distances between the receptors and this crossing, local noise control measures are li kely to be required, such as temporary noise screening. Directional drilling is anticipated at a number of other locations along the scheme (in each of the three LPA areas) but no significant impacts, save for those predicted close to Chestnut Hill Road (above), are predicted. 206) Ground compaction would be undertaken along haul routes, at crane pads, at site compounds and during tren ch backfilling. As such, adverse ground-borne vibration impacts during compaction may

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Planning, Design and Access Statement

arise at nearby sensitive receptors. Vibration p redictions during compaction have demonstrated that adverse impacts may be experienced at distances up to 55 m from such activities. Suitable mitigation, including informing affected resident s, would need to be impl emented, as appropriate. 207) Elevated noise levels have been predicted at nearby sens itive receptors for the construction of the tunnel launch and rece ption pits and their subsequent re-instatement in two areas a long the RWA route - the River Greta crossing in Keswick and in Netherfield, near Kes wick. Noise sensitive receptors are within 22 m and 17 m respectively. As well as following good practice , specific mitigation measures (s uch as the installation of screening b arriers/hoardings) are likely to be needed to reduce construction noise impacts for these nearest sensitive receptors. 208) The tunnel boring act ivities themselves are lik ely to take place 24-hours per day, seeven days p er week for their duration. During tunnelling there are predicted to be significant airbor ne noise impacts as a result of above ground plant and machinery at the nearest sensitive receptors, for both daytime and night-t ime periods. Tunnelling activities themselves are predicted to result in high levels of ground-borne noise and vibration at the nearest sensitive receptors, for daytime and night-time periods. Consideration would be given to mitigation measu res where feasible to reduce these impacts. The closest residents would be kept informed of the timing and duration of tunnel boring activities, with appropri ate monitoring where practicable. Given the distance to the nearest noise sensitive receptor and the relatively minor alterations required at Bridge End Connection (compared to other elements of the scheme), it is not anticipated that there would be significant construction noise impacts for sensitive receptors in the vicinity. 209) Piling would be undertaken at a number of locations within the Lake District National Park. Three different pi ling methods could be used on this scheme, these being cable percussion piling, pile driving (using vibro-hammer) and CFA piling. The method of piling that would be adopted in each location is not yet known. Airborne noise and ground-borne vibration generated during piling at nearby sensitive receptors is likely to result in s ignificant effects. Suitable mitigation, including selection of lower impact forms of piling (where possible) and temporary screening, would need to be implemented where appropriate. 210) No signifi cant noise effects are anticipated either from construction vehicle movem ents or during the operational phase of the Bridge End Connection. 211) Analysis undertaken has shown that no roads would expe rience a perceptible change in road t raffic noise level as a result of additional construction vehicles associated with the propos ed scheme. Therefore significant effects are not anticipated as a result of additional construction vehicles using the local road network. 212) Impacts on amenity including the tranquillity of the rural landscape from noise have been kept to a minimum and the Proposed Scheme is consistent with the objectives of Policy CS11.

2.7.15 Air Quality and Odour

Planning Policcy 213) Paragrap h 109 of the NPPF highlights the need to prevent developme nt from contributing to unacceptable levels of air pollution. 214) Policy CS11 of the Core Strategy Sustainable Development principles requires development to avoid adverse effects on, and where appropriat e enhance, the quality of natural resources including air.

Assessment against Planning Policy 215) Chapter 20 of the accompanying ES includes an assessment of air quality. Potential air quality impacts considered during the construction phase included those associated with construction vehicles on main haulage routes (emissions of nitrogen oxide (NOx), nitrogen dioxide (NO2) and particulate matter (PM10)), and construction processes (dust deposition). During the operational phase impacts associated with combustion emi ssions (from generators or other plant) and vehicle exhaust emissions were considered.

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Planning, Design and Access Statement

216) Existing air quality within the Lake District National Park Authority stud y area is considered to be good in the context of national air quality Objectives for NO2 and PM10. There are a number of properties in close proximity to earthworks activities (<20 m ) along the Raw Water Aqueduct, around Keswick and under the River Greta, where residents are likely to be highly sensitive to dust emissions due to their close proximity to works. However the impact of construction vehicles on local air quality at identified receptor locations within the Lake District National is predicted to be negligible. 217) Mitigation measures will include s tandard goo d practice measures to mitigate dust emissions from the propos ed development should be included within the construction code of practice to preven t or minimise the release of dust entering the atmosphere and/oor being deposited on nearby receptors. Particular attention would be paid to operations which must unavoidably take place close to the site boundary. Mitigation measures appropriate for the identified likely level of risk are outlined in ES and it is recommended that they are agreed wit h the local authority. Eff ective implementation of a CCoP and incorporatio n of mitigation measures proposed s hould reduce all construction dust soiling and human health impacts to ‘not s ignificant’. 218) It is considered that the Proposed Scheme would not lead to adverse effects on air quality and is therefore is in accordance with Paragraph 109 of the NPPF and Policy CS11 of the Lake District National Park Authority Local Plan Core Strategy.

2.7.16 Summary of Consultatio n in the Lake District N ational Park 219) Several phases of consultation have taken place prior to this planning submission. The first phase followed the EiP and this focused on raising the awareness of the scheme and developing options for the proposed locations of the Water Treatment Works and Service Reservoirs. This phase involved one to one meetings with the LPA’s, public exhibitions in Thirlmere and Keswick, exhibitions at country shows, leaflet drops, social media announcements and establishing a dedicated website and email for responding to questions. In total over 700 people attended these events with 168 specific responses received. Comments ranged from the need for the scheme to sustainable mitigation. The SCI provides specific details of the stakeholder consultations which took place. 220) The second phase focused on gathering the views of the l ocal community, businesses and landowners taking into account feedback received in Phase 1. This took place from December 2014 to May 2015 and the applicant engaged with the local community and stakeholders through further public exhi bitions at Keswick, Bassenthwaite and Thirlmere which were extensively advertised including s ocial media. Presentations to local councils ranging from pari sh councils to the County Council were undertaken and these were supported by tours of the route. Specific meetings took place with the Forestry Commission, Keswick Tourism and landowners in Blindcrake. Over 450 individuals or stakeholders attended these events with comments raised about potential disruption, impacts on local businesses, funding the scheme, employment opportunities and also other specific questions. 221) Using the feedback received at the second phase, the third phase in the run up to this planning application has concentrated on scheme specif ics through one to one meetings (including landowners) and meeting interest group and tourism group meetings. Particular issues raised include maintaining the tourism market in Keswick with many businesses wanted to understand compensation arrangements. Specific issues associated wi th the const ruction programme were also discussed. The outcome of phase 3 was final changes to the design particularly around detailed route selection (for example across a field), remedial works and mitigation. 222) The outcome of consultation and engagement has therefore fed into the proposed scheme now subject to this planning application. If planning permission is granted, the applicant would continue engageme nt and consultation activities through three more phases of consultation. These additional phases would focus on final definitive construct ion plans, m obilisation arrangements and post construction mitigation. 223) Overall the applicant has engaged and consulted on the proposed scheme from its inception to its conclusion including during the aftercare period. This reflects the applicant’s commitment to work with the local community as a majo r service provider and custodian of the water supply.

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Planning, Design and Access Statement

2.8 Design and Access 224) This Design and Access section demonstrates how site and context analysis has been used to influence the design development t o produce a sustainable and high qu ality infrastructure scheme. This section focusses on the permanent development and its design elements which are as follows:

2.8.1 Bridge End WTW - Connection Works

Site Analysis and Visualisation 225) Works are proposed at the existing Bridge End Water Treatment Works to accommodate a new RWA connection. The new small scale Bridge End Connection structures would be located within the existing Bridge End WTW site at the northernmost part of the Thirlmere. The change to landscape character would only be perceived very locally due to small increase in built development and the limited tree loss.

Design and Laayout Strateggy 226) Proposed development at Bridge End WTW (the Bridge E nd connection) would co nsist of new valve house, control kiosk, concrete channel, connection of new pipes and realignm ent of the boundary fence and an extension to the access road. The temporary development associated with the RWA installation and Bridge End connection would be contractor’s compound and laydown area. The site is an established WTW but would requ ire an extension to accommodate the new infrastructure. 227) The scale and location of the new assets is dictated by their function with limited flexibility in order to connect in with the existing site infrastructure. New structures are designed to match those existing with smaller kiosks constructed in Green Reinforced Plastic (GRP).

Access and Movement 228) The exist ing permanent access would be extended around the new development proposals to allow vehicular access to maintain and operate the additional infrastructure at the site. The existing site access would be used for cons truction purposes.

2.8.2 RWA and Associated Infrastructure 229) The pipel ine has been routed to avoid the need for pumping, with water transferred to the proposed Water Treatment Works under gravity. The route is dictated by the hydraulic profile and has to run between certain topographic limits to maintain the gravity feed. 230) Through extensive surveys and stakeholder communication including discussions with landowners the route has developed to minimis e the impacts on the environment and local communities. 231) Along the route there would be a number of valve chambers which accommodate the below ground infrastructure required to operate and maintain the pipeline. These chambers would have a concrete surround and where possible would be located at field boundaries. To allow automation at a number of the valves small GRP kiosks housing switch gear would be constructed along the route, sited at field edges wherever possible.

Access and Movement 232) During construction a number of temporary access points to the local highway network would be required for construction purposes. A haul rout e would be i ncorporated into the working easement to reduce impacts on the highway. 233) The pipeline route would be reinstated following construction with small gates included within field boundaries to allow operational access for survey via a qua d bike or similar. The applicant has developed the scheme over a number of years and has invested a significant amount of resources into consulting and engaging with its customers, the community, statutory bodies, la ndowners and businesses prior to this planning submission. From the inception of the proposed scheme it has been recognised that this was a major linear project within a sensitive rural setting a nd therefore it

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Planning, Design and Access Statement

has been designed as sensitively as practicable to reflect the built and natural environment which surrounds it. The assessment of the proposed scheme provided in this PDAS has demonstrated that through the design and mitigation it meets the objectives of the Local Plan.

2.9 Summary 234) The appli cant has developed the scheme over a number of years and has invested a significant amount of resources into consulting and engaging with its c ustomers, the community, statutory bodies, landowners and businesses prior to this planning submission. From the inception of the proposed scheme it has been recognised that this was a major linear project within a sensitive rural setting and therefore it has been designed as sensitively as practicable to reflect the built and natural environment which surrounds it. The assessment of the proposed scheme provided in this PDAS has demonstrated that through the design and mitigation it meets the objectives of the Local Plan.

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Planning, Design and Access Statement

3. Allerdale Borough Council

3.1 Scheme Description 235) Development of a water supply connection from Thirlmere Reservoir to area of West Cumbria comprising, within Allerdale Borough Council of:  A water treatment works (WTW) with associated vehicular access, landscaping, and temporary working areas, off the A595, near Blindcrake  A service reservoir (SR) and val ve house, with vehicular access and landscaping at Moota Hill  A pumping station (PS) with vehicular access, fencing and landscapi ng at Harrot Hill, near Cockermouth  Underground mains supply pipe lines from the proposed WTW to Quarry Hill, Bro ughton Cros s and extending into the  The slip-lining of existing pipelin es from Broughton Cross to Stainburn Service Reservoir and from Cockermouth to Southwaite Farm. 236) Incorporating the development of, valve chambers, excavation and landscaping, temporary vehicular accesses, working areas, compounds, hard standings and other associated development along the route. 237) The detailed scheme descriptions and locations, for each section, are listed in Table 3.1 below:

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Planning, Design and Access Statement

Table 3.1 – Allerdale Scheme Sections

Section/Facility (number Development Description Location Description Associated Drawings and location)

Section 6 - The proposed The proposed development site comprises five  The development would be located to the north  General Site Layout Plan new WTW linked agricultural fields with a total area of west of the A595, approximately equidistant B2707061/S3/ABC/WTW/01 approximately 27.3 ha. between and Blindcrake. To the east of  Proposed Site Sections The proposed 80 ML/day capacity WTW the A595 is the western boundary of the Lake B2707061/S3/ABC/WTW/02 includes both water treatment process and District National Park and 03 ancillary buildings, together with items of plant  The site is greenfield and presently comprises  Control Building – Roof and and machinery and below-ground level open semi-improved grassland. The area Floor plans structures. Much of the plant and machinery surrounding the site is predominately agricultural B2707061/S3/ABC/WTW/05 would be housed within a large green roofed  The northern and western boundaries are  Control Building – Elevations building. A new access would be provided for demarcated by existing field boundaries defined B2707061/S3/ABC/WTW/06 construction and operation vehicles serving the by fence, hedgerow and stone walls with Hags  Workshop – Roof and Floor site from the A595. Wood adjacent to the south western boundary. plans Hags Wood is a conifer woodland block, B2707061/S3/ABC/WTW/07 consisting of evergreen trees with deciduous trees on the edge bordering the proposed site.  Workshop – Elevations Hedgerows are interspersed with mature B2707061/S3/ABC/WTW/08 deciduous trees  Filter and Chemical Building –  The north east boundary is demarcated in part by Floor plans a stone wall adjacent to a minor road and wind B2707061/S3/ABC/WTW/09 farm access. The eastern boundary continues  Filter and Chemical Building – adjacent to a highway layby, adjacent to this is a Elevations small area of mature deciduous woodland with B2707061/S3/ABC/WTW/10 further trees within the layby verge. A hedge runs  Filter and Chemical Building – along the majority of the site frontage to the A595 Sections  A cluster of dwellings known as Williamsgate are B2707061/S3/ABC/WTW/11 located to the north east and are the nearest  Service Water Kiosk – General residential properties to the proposed WTW. A arrangement plan and further two properties, a bungalow and a farm are elevations located approximately 1.4 km to the north with B2707061/S3/ABC/WTW/12 access from the local road, which runs along the Lamella Clarifier Tank – General eastern edge of the site.  41

Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location) arrangement plan and elevations B2707061/S3/ABC/WTW/13  Flocculation Tank Kiosks – Roof plan and elevations B2707061/S3/ABC/WTW/14  Flocculation Tank – General arrangement and sections B2707061/S3/ABC/WTW/15  Inlet Control and Turbine Chamber – General arrangement, roof plan and section B2707061/S3/ABC/WTW/16 Section 7 – Network Main This section consists of a new single (500 mm)  From the WTW, the pipeline extends in a broadly  Allerdale Borough Council from the new WTW to the network main from the new WTW site to the north easterly direction across a relatively General Layout existing Quarry Hill WTW existing Quarry Hill WTW site. The pipeline elevated and open landscape to the west of B2707061/S2/ABC/1 - 8 would be laid largely using an open-cut Bothel and the A595. A series of small streams construction technique with the exception of cut through the rolling topography. The area three road crossings which would adopt consists of large fields of improved pasture with trenchless techniques, and a directional drill very sparse tree cover; some large scale conifer under the River Ellen. plantations are evident The section also includes temporary accesses  The pipeline heads along the western side of the and contractors’ compounds/laydown areas. A595, towards the CEMEX Moota Quarry. The decommissioning of Quarry Hill WTW Crossing the A595 just past the village of would involve the removal of plant and Blindcrake, it continues approximately 0.9 km machinery and the closing of the Isolation valve along the eastern edge of the road (this section to turn off public water supplies and capping being in the National Park) and past Moota the existing network at the WTW. Quarry on the other side of the road, before returning back over the A595 adjacent to the B5301 Parsonby Road junction and into Allerdale district

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Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location)  From here the mains then run northward in the direction of Plumbland and Threapland, crossing Threapland Gill approximately 1.7 km south of Plumbland  Continuing in a north easterly direction, the pipeline passes to the north of Wharrels Hill and Wharrels Quarry, continuing through open countryside and agricultural land  After the pipeline has passed north of Bothel, the pipeline crosses the River Ellen and the A591 continuing in a north easterly direction approximately 1 km north of Torpenhow. The area is a large scale undulating landscape interspersed with native woodland, tree clumps and plantations, consisting of a series of ridges and valleys that rise gently towards the fringes of the Lakeland Fells. The pipeline heads further east to Quarry Hill WTW, where it terminates to the south of the B5299, approximately 1.2 km from to the east and 1 km west of Boltongate. Section 8 - Moota Hill Service The proposed development site comprises two  The proposed site for the SR is greenfield and  General Site Layout Reservoir linked agricultural fields with a total area of located some 1.3 km north east of Blindcrake. B2707061/S3/ABC/MH/01 approximately 4.8 ha The site is bounded to the south east by the  Floor Plan The scheme involves the creation of a new A595. The area surrounding the site is B2707061/S3/ABC/MH/02 predominately agricultural 25 Ml service reservoir with valve house.  Roof Plan The SR would be a largely buried structure with  The site consists of open semi improved B2707061/S3/ABC/MH/03 grassland. Development near the site includes an above ground valve house facing the A595.  Elevations Moota Garden Centre and Threapland Park (a In addition there would be a new permanent B2707061/S3/ABC/MH/04 access, ground re-profiling and fencing. static Caravan Park) 0.8 km north east on the A595. Sections 9 - Network Main This section involves the laying of new twin  To the south west of the WTW, the route runs to  Allerdale Borough Council 43

Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location) from the proposed WTW to (800 mm) network mains, using an open cut the north of Brides Beck around the northern General Layout proposed Harrot Hill Pumping construction technique, from the WTW. Both fringe of Bridekirk. The landscape in the area is B2707061/S2/ABC/1 and 9 - 12 Station and sludge mains to pipes pass under the River Derwent and A66 managed rural farmland comprising significant Cockermouth Waste Water using tunnelling techniques. areas of improved pasture in regular medium to Treatment Works This section also includes the laying of a single large field patterns (150 mm) sludge main and a foul water pipe  The pipeline crosses three local lanes serving (150 mm) from the WTW to the existing Bridekirk, before continuing south west towards Cockermouth Waste Water Treatment Works the A594. The corridor runs through open (WwTW), using the same trench as the network countryside and crosses the A594 some 500 m mains until south of the Derwent where it would north of its junction with the A595 near Papcastle. branch off to the WwTW. This section also Papcastle has a rich archaeological heritage includes a single network main pipe from south  To the south west of Papcastle the pipeline of the River Derwent to Harrot Hill Pumping crosses the River Derwent and the A66 (at which Station. point the sludge mains connects into The section also includes temporary accesses Cockermouth WwTW and one network main into and contractors’ compounds/laydown areas. the Stainburn to Cornhow mains) and only one network main continues south running to the west of the A66, past the Laureats Housing Estate to the west of Cockermouth to the site of the proposed new pumping station at Harrot Hill on Ellerbeck Brow Section 10 - Proposed Harrot This section deals with the construction of a  The proposed Harrot Hill pumping Station is  General Site Layout Plan Hill Pumping Station new Pumping Station, comprising a control located within the south western corner of a large B2707061/S3/ABC/HH/01 building, electricity substation, new permanent field, with a proposed development area of  Elevations access, landscaping and stock proof fencing. approximately 0.65 ha B2707061/S3/ABC/HH/02 and There would also be a temporary contractors’  The site is greenfield and is bounded by a 03 compound maintained hedgerow boundary on Ellerbeck  Landscaped Elevations Brow and a hedgerow and hedgerow trees to the B2707061/S3/ABC/HH/04 west  Landscape Plan  The remaining two boundaries would be formed B2707061/S3/ABC/HH/05 by the development and are currently open field. The site and the surrounding area consist of open  Floor Plan

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Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location) improved grassland. B2707061/S3/ABC/HH/06  Internal Building Section B2707061/S3/ABC/HH/07 and B2707061/S3/ABC/HH/08

Section 11 – Network Main This section is for a new single (800 mm)  The pipeline passes between Wellington Farm to  Allerdale Borough Council from the proposed Harrot Hill pipeline, laid using an open cut construction the west and Mitchells Auction Place to the east General Layout Pumping Station to Ullock technique, from Harrot Hill Pumping Station to and crosses Simonscales Beck as it passes south B2707061/S2/ABC/12 - 18 Ullock, including temporary access and towards the A5086. At the A5086 the route runs contractors’ compounds/laydown areas. south west in proximity (around 150 m) to the west of the road. The route passes the village of Eaglesfield, passing to the west of Paddle School, and crossing Paddle Beck and Hotchberry Brow local road  The landscape throughout this section is large scale with undulating topography consisting of large fields of improved pasture. Field boundaries are typically formed by hedgerows, with few hedgerow trees, in addition to some fence boundaries with sparse tree cover. Small streams and rivers cut through the rolling topography, some of which are well vegetated. The pipeline continues south, crossing the road for Cragg Farm including a number of stream crossings. The pipeline continues to passes through predominately agricultural land, which is interspersed with farms and isolated properties  Passing Ullock the pipeline crosses Black Beck heading towards Mockerin Tarn. The route crosses Snary Beck to the south of Mockerin Tarn, and into Copeland district.

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Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location)

Section 16 – Network Main – This section is for a new (550 mm) pipe, laid  This section runs from south west of Papcastle  Allerdale Borough Council Papcastle to Broughton Cross using an open cut construction technique, to near the A66/A595 roundabout west of General Layout replace two existing mains pipe, which would Cockermouth to the Broughton Cross area using B2707061/S2/ABC/11 and 19 - be abandoned. There would also be temporary an open cut construction technique as it is not 20 accesses and contractors’ compounds/lay­ possible to reuse the existing mains in this area down area.  The section starts to the south west of Papcastle and intersects with the network main from the WTW to Summergrove. The section starts at approximately 30 m AOD and continues to Broughton Cross at approximately 35 m AOD remaining within the River Derwent Valley  The route runs westwards towards the village of Brigham, with the A66 to the north. It passes to the north of the village of Brigham and moves northwards to run along the southern edge of the A66  The landscape is characterised as a wide and deep valley with open floodplain. The winding River Derwent and the linear A66 are key features within the valley bottom. The landscape is managed as rural farmland comprising significant areas of improved pasture in regular shaped medium to large field patterns. Hedgerows are the predominant field boundary with individual mature hedgerow trees. Native woodland and tree clumps are common in the valley  Towards Brigham the route crosses Eller Beck to the east of Brigham and passes by the Grade I listed St. Bridget’s Church, Grade II* listed Parsonage Farmhouse and Grade II listed The Old Vicarage. Passing these buildings the pipeline crosses Stony Beck and passes to the

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Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location) north of Brigham Caravan Park and runs adjacent to the disused Kirk Cross Quarry. Section 17 – Broughton This section involves the slip-lining of existing  This section of the pipeline follows the route of  Allerdale Borough Council Cross to Stainburn Service network mains. Temporary launch and two existing water mains not far from the River General Layout Reservoir reception pits would be required. Fitting Derwent. The section is proposed to be slip-lined, B2707061/S2/ABC/20 - 24 excavations would also be required to enable with some parts of open cut

access to the existing fittings. Small sections  The landscape for this section is characterised by would be laid by open cut where it is not managed rural farmland comprising significant possible to slip-line. areas of improved pasture in regular shaped There would also be temporary accesses and medium to large field pattern. Hedgerows forming contactor’s compounds/lay-down areas. field boundaries, native woodland, tree clumps and coniferous plantations are common throughout the areas  The settlement pattern includes Bridgefoot, Great Clifton and Stainburn and other scattered farms and an increased number of dispersed residential properties and caravan parks, some as clusters of properties  In the vicinity of Bridgefoot the pipeline crosses the River Marron, which is a designated SSSI and SAC and also crosses Lostrigg Beck to the east of Bridgefoot and Harry Gill to the east of Great Clifton. Section 18 – Cockermouth to This section involves the slip-lining of existing  The slip-lined section continues south east from  Allerdale Borough Council Southwaite Farm network mains and small sections would be laid the A66/ A595 roundabout west of Cockermouth General Layout by open cut where it is not possible to slip-line. within the River Derwent valley to Southwaite B2707061/S2/ABC/11 - 12 and

Temporary launch and reception pits would be Farm, running through the urban area of 25 - 27 required. Fitting excavations would also be Cockermouth. The northern section would be required to enable access to the existing abandoned. The southern existing main would fittings. Certain sections of the existing mains predominantly be slip-lined with small sections of would be abandoned as they are not required. open cut

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Planning, Design and Access Statement

Section/Facility (number Development Description Location Description Associated Drawings and location) There would also be contractors’ accesses and  Through the urban area of Cockermouth, the contractor/lay down areas. route follows roads through predominately residential housing areas. Use of slip-lining would minimise the impact within the urban area. Where sections of open cut are required these would be undertaken within the road or footway  To the east and west of Cockermouth the landscape quickly becomes rural with high levels of vegetation and lesser influence from the urban area. Settlement patterns beyond the urban area are defined by scattered farms and properties  The pipeline follows the route of the Cockermouth Conservation Area as it runs through Cockermouth. There are considerable archaeological assets in the wider Cockermouth area through which Section 18 is aligned.

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Planning, Design and Access Statement

3.2 Planning Applications along the Route 238) During the design of the scheme, United Utilities have liaised closely with Allerdale Borough Council. Part of this process was the consideration of development proposals along the proposed route and the need to be as least d isruptive to t hese as pos sible. In September 201 5, planning application information was requested from all l ocal authorities affected by the scheme, to identify potential land use impacts of the scheme, for developments submitted/aapproved within the last 5 years and within a 150m buffer zone of the Proposed Scheme. The data was plotte d on a GIS system and compared against the red line planning application boundary for the Proposed Scheme. 239) A review of the applications identi fied that approximately 200 planning applications were submitted/approved in the last five years were found within the 150 m buffer within the Allerdale Borough Council section, though only the following planning applications were potentially directly affected by the scheme either in terms of :  2/2013/ 0038 Meadow End - Change of use of agricultural land to extend existing gardens to rear of properties  2/2011/ 0766 Melbreak Hotel - Proposed layout of site and change of use to allow siting of 60 log cabins (to replace extant permission 2/2005/0517).

3.3 Planning Policy Assessment

3.3.1 Planning Policy Context 240) The Development Plan for Allerdale Borough Council comprises:  Allerdale Local Plan (Part1) Strategic and Development Management Policies (2014)  Saved Policies of th e Allerdale Local Plan (1 999)  Saved Policies of th e Local Plan First Alteration (2006). 241) Allerdale Borough Council has consulted on the Allerdale Local Plan (Part 2) Site Allocations Development Plan Document – Issues and Opt ions Discussion Paper (July 2014) which will, once adopted, become part of the Allerdale Local Plan. Allerdale Borough Council anticipates consultation to be held on a ‘Preferred Options’ document in early 2016. 242) The West Cumbria Water Supply is identified in the Allerdale Local Plan at Policy S23 Supporting and Safeguarding Strategic Infrastructure, whic h states that the council will ‘Support proposals to secure future drinking water supplies for West Cumbria’. 243) The policy also states that: ‘The Council will support priorities and improvements set out in the Local Transport Plan and other delivery documents by working with partners and ensuring development will not prejudice the implementation of proposed schemes and projects’

3.4 Allocations / Designations 244) The Prop osed Scheme crosses the following allocations in the Allerdale Local Plan (1999) Proposals Map:  County Landscape (EN22)  Locally Important Landscape (EN23) replaced by Local Plan Policy S35 Protecting and Enhancing Biodiversity and Geodiversity)  Site of Special Scientific Interest (EN27). 245) In July 2014 Allerdale Borough Council formal ly adopted the Allerdale Local Plan, which formally deletes a number of the policies of the old Allerdale Local Plan, such as those above, and also includes revisions to the 1999 Aller dale Local Plan (1999) Proposals Map. However, as the Loc al Plan Part 1 retains many of the provisions of the old Proposal Map, these allocations are still

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Planning, Design and Access Statement

considered of relevance. The following assessment provides an assessment of all relevant Local Plan policies. 246) For Allerdale and Copeland, the adopted Cumbria County Council Minerals and Waste Core Strategy provide policies on safeguarding future minerals resources. As existing planning permissions for general crushed rock already provide for a landbank of at least fifteen years to be maintained throughout and beyond the plan period further permission for mineral extraction are not deemed to be required . The plan would not identify any Preferred Areas for new crushed rock mineral extraction but only identify Mineral Safeguarding Areas to protect the crushed rock resources for future ge nerations.

3.5 Planning Assessment 247) To support the section above, the analysis below summarises the environmental impacts of the proposed scheme agai nst the context and detailed planning policy objectives of the NPPF and the adopted Local Plan. It is not intended to duplicate the ES. 248) In this context, object ive SO5c of the Allerdale Local Plan (the Local Plan) is to ‘Protect and enhance existing social, community and utility related infrastructure’ and within Appendix 8 ‘Identification and deliv ery of infrastructure’ the West Cumbria Water Supply is identified as a key scheme to delivering this objective. 249) A Key objective of the planning system under Paragraph 109 of the NPPF is that it should ‘contribute to and enhance the natural and local environment by minimising impacts on biodiversity and preventing development from contributing to unacceptable water pollution’. In addition, national policy regarding flood risk is set out in section 10 of the NPPF, Meeting the Challenge of Climate Change, F looding and Coastal Change. Paragr aph 94 requires LPAs to adopt proactive strategies to mitigate and adapt to climate change, taking ful l account of flood risk. Paragraph 99 states that: new development should be planned to avoid increased vulnerability to the impacts arising from climate change. 250) Also of significance to the Proposed Scheme is NPPF paragraph 12 concerning the conservati on of the historic environment. The NPP F recognises that heritage assets are an irreplaceable resource that should be conserved in a manner appropriate to their significance. Significance is defined by the NPPF as ‘the value of a heritage asset to this and future generations because of its heritage interest’. This significance may be related to archaeological, architectural and artistic or historic elements, and may also derive from the setting of the site (Paragraph 56).

3.5.1 Landscape and Visual Planning Policy

251) Paragrap h 17 (General Planning Principles) of the NPPF states that all development should seek to: secure high quality design a good standard of amenity for all existing and future occupants of land and buildings and response for the character and beauty of the countryside. 252) NPPF Paragraphs 58 and 109 state that planning decisions should aim to ensure good design and landscaping, whilst protecting and enhancing the natural en vironment. 253) Relevant policies from the Local Plan Part 1 (2014) include Policy S2 Sustainable Development Principles which states the council will ensure that ‘landscape character and local distinctiveness is protected, conserved and wherever possible enhanced’ and Policy S32 Safeguarding Amenity which prohibits development that would have a detrimental effect on the local area in terms of visual amenity. Further policies are Policy S33 Landscape, which requires landscape character and local distinctiveness to be protected, conserved and, wherever possible, enhanced and for proposals to be compat ible with the distinctive characteristics and features of Cumbria’s landscape types and sub types. Policy M14 Standards of Good Design requires proposals to be accompanied by landscaping schemes in order to mitigate any visual impact and integrate the development into its wider surroundin gs. Assessment against Pllaanning Policcy

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Planning, Design and Access Statement

254) The effects on landscape character would be most significant during the constructi on phases where there is the potential for effects on the character area resulting from loss of hedgerows, hedgerow trees and the influence of construction activities within a typically rural and relatively tranquil landscape. 255) The proposals have been developed to minimise landscape impacts as far as practicable, including incorporati ng features into the building design that minimise the visual appearance and including mitigation proposals to screen visual impacts and replace features that contribute to landscape character. 256) Most of the scheme in Allerdale would be located underground and fol lowing the reinstatement and establishm ent of the proposed planting would b e largely hid den from view. It would take a number of years for the hedgerows, trees and vegetation to establis h. By year 15 after construction the impacts would have reduced to a po int where they are barely noticeable. The lands cape would be largely returned to normal within five years and after 15 years would have completel y re-established. Above ground facilities have been sited and designed to minimise the impact on land resources and visual amenity. 257) The importance of the landscape surrounding the site of the proposed Water Treatment Works near Hag Wood has been a major consideration in its design and measures to minimise impacts on landscape character have been incorporated. It has been sensitively sited in relation to the existing topography using natural and local materials which are appropriate to the setting and function of the development. This includes limiting the height of the development as far as practicable and using a ‘green roof’ design to integrate the new structures within the surrounding undulating landscape and reduce visibility of the development from the surrounding area and particularly from the Lake District National Park. 258) Moota Hill Service Reservoir would comprise a predominantly below g round development incorporated into the rolling landscape. It would be landscaped to minimise visual effects and to enable integration into the landscape, whilst the design of the external walls and wing walls to the valve house would use local stone laid in a vernacular style appropriate to the local architecture. 259) The design of Harrot Hill Pumping Station has been developed in consultation with the local planning authority to ensure its design and construction materials are in keeping with the local vernacular. 260) Other mitigation includes replacement tree planting, reinstatement of hedgerows, woodlands, watercourses and drystone walls. Where this is undertaken these features would be returned to their previous states as soon as it is practicably. 261) Overall it is recognised that the nature of the Proposed Scheme, being a major infrastructure project in a rural landscape, would have some adverse effects upon landscape char acter but the proposals have been d eveloped to minimise these through siting, design and mitigation. With the inclusion of these measures, the Proposed Sch eme is in ac cordance with paragraphs 17, 58 and 109 of the NPPF and policies S2, S32, S33 and M14 of the Local plan which seek to minimise visual impact and impacts on the rural landscape.

3.5.2 Arboriculture Planning Policy

262) The national objective relating to arboriculture is set out in Paragraph 118 of the NPPF, which states: ‘planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss’

263) Relevant policies from the Local Plan Part 1 are Policy S35 Protecting and Enhanccing Biodiversity and Geodiversity, whic h requires development to protect existing trees, hedgerows and woodland (including ancient trees and hedgerows) that are considered important to the local community, 51

Planning, Design and Access Statement

contribute positively to the character of the area and/or are of a nature conservation value. In addition, Policy DM17 Trees, Hedgerows and Woodland, seeks to protect existing t ree; removal of trees will only be permitted ‘in exceptional circumstances where it can b e demonstrated that the economic viability of the development is prejudiced and there are proposed wider benefits that outweigh the loss incurred. However where a development poses significant harm to an irreplaceable habitat which cannot be mitigated or compensated for, permission will be refused. Replacement planting that maintains local amenity, the character of the area and nature conservation interest will be required’. Assessment against Pllaanning Policcy

264) Whilst the routeing has tried to avoid direct im pacts on trees this has not always been possible. Impacts would occur during construction through temporary or permanent land take associated with the pipeline, temporary construction compounds and car parks, mobilisation sites and temporary access routes. 265) As report ed in the ES , the required working width of the pi peline during construction is generally 40 m. At locations where environmental constraints are encountered within the working width, it may be possible to reduce the working width over short distances to minimise impacts on these constraints (for example, at hedgerows or watercourse crossings where the working width may be reduced to approximately 20 m). Similarly, contractors may be able to realign the pi peline away from the centre line of the construction corridor to avoid particular constraints. In the case of arboricultu ral constraints, for example, this may mean that tree root protection areas falling withi n the working width may be avoidable. The Environmental Masterplan presented in the E S indicates where tree root protect ion areas within the working width may be avoidable through appropriate construction managem ent. 266) Trees which have protection under the Planning Acts are those with Tree Preservation Orders or which are within a Conservation Area. In addition, the NPPF protects ancient woodlands and veteran trees from development unless the dev elopment clearly outweighs the loss. The ES identifies that there is one Conservation Area at Cockermouth where two trees would be affected. There is one TPO at Parklands in the vicinity of the Proposed Scheme, but this tree would not be affected. 26 7) A limited area, approximately 60m2, of Ancien t and Semi-Natural Woodland and Planted Ancient Woodland Sites would be affected by the working width at Newbiggin Woods. 268) Apart from trees which are afforded special protection under the Planning Acts, trees and other vegetation are classified according to their quality and remaining life. The highest quality trees are grade A and the poorest quality grade C, whilst some trees are unclassi fied. 269) Table 3.5 below summarises the number of trees identified within Allerdale either along or adjacent to the working width.

Table 3.5 – Trees, Groups of Trees, Hedgerows and Woodlands Surveyed Within Allerdale GRADE CATEGORY TOTALS A B C U TREES 117 462 173 18 770 GROUPS 24 345 119 1 489 HEDGES 2 235 87 0 324 WOODLANDS 3 36 5 0 44 TOTALS 146 1078 384 19 1627

270) Four of the trees listed above are veteran trees. Veteran trees are trees which, due to their age, size or condition, are of cultural, historical, landscape or nature conservation value. 271) Where trees or hedgerows need to be removed the aim is to reinstate them at the same location or as near as practicable. However, as tree planti ng would be restricted for operational reasons over

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Planning, Design and Access Statement

and in proximity to the permanent easement this would lead to a net loss in trees within the working width of the scheme. Compensatory planting would deliver new trees at a greater ratio to those which are l ost. A location in the Ennerdale Valley has been identified by the applicant as an area for replacement planting and tree planting as a strategic mitigation measures to compensate for tree losses across the whole scheme would also be supported through the provision of a community grant fund under which local groups would be eligible to apply for monies to support local tree planting initiatives. Section 5 of this statement provides more detail of the compensatory planting. 272) It is also important to avoid physical damage to trees whic h remain in situ including damage to their roots. Other mitigation measures include fencing prescribed to British Standard BS5837:2012 and exclusion zones around the Root Protection Zones. 273) The loss of trees is one of the mo re significant impacts of the scheme but the applicant has recognised this and proposes a scheme of compensatory planting. The development is required to maintain water supplies to West Cumbria and as such it is considered that the exceptional circumstances required by Policy DM17 of the Local Plan have been met and that the compensatory measures help address the objectives of this policy.

3.5.3 Water Enviro nment Planning Policy

274) Paragrap h 109 of the NPPF states that the planning system should ‘contribute to and enhance the natural and local environment by minimising impacts on biodiversity and preventing development from contributing to unacceptable water pollution’. 275) Relevant policies from the Local Plan are Policy S2 Sustainable Development Principles which seeks to protect water quality, Policy S32 Safeguarding Amenity which prohibits development that would cause pollution t o the water environment or cause deterioration of the Water Framework Directive Classification Status, Poli cy S35 Protecting and Enhancing Bi odiversity and Geodiversity, which expects development to protect and enhance key ecological habitats including watercourses and Policy S36 Air, Water and Soil Quality which resists development that would have a demonstra ble direct or indirect adverse impact on The Water Framework Directive and the status of the watercourse. 276) In addition, the Water Framework Directive (Directive 2000/60/EC) has the overarching objective to ensure all water bodies in Europe attain Good or High Ecological Status. Assessment against Pllaanning Policcy

277) Potential impacts are associated with pipeline construction, construction and operation of the new water work treatment works, service reservoirs and any operational changes which may result in changes to water resources. 278) A series of standard mitigation measures has been proposed to help manage pollution risk and reduce the impacts of the construction of the Proposed Scheme on the water environment. These mitigation measures include a Construction Code of Practic e (CoCP) and adherence to the Environment Agency’s guidance on Pollution Prevention Guidelines (PPG), appropriate scheme design, oversight of works and environmental monitoring during construction (where required). 279) The most significant potential impacts on the water environment from construction activities are close to watercourses or associated with river/sstream crossings. In addition to the s tandard mitigation measures listed above, additional mitigation has been propos ed including the selection of appropriate river crossing techniques and access methods based on river specific characteristics. A land drainage strategy and water quality monitoring strategy have also been developed. 280) The incorporation of specific mitigation measures would ensure that the quality of the water environment is maintained and protected from pollution meeting the objectives of Policies S35 and S36.

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Planning, Design and Access Statement

3.5.4 Flood Risk Planning Policy

281) National policy regarding flood risk is set out in section 10 of the NPPF: Meeting the Challenge of Climate Change, Flooding and Coastal Change. Paragraph 94 requires LPAs to adopt proactive strategies to mitigate and adapt to climate chan ge, taking full account of flood risk. Paragraph 99 states that new development should be planned to avoid increased vulnerability to the impacts arising from climate change. 282) Paragrap hs 100, 101 and 102 of the NPPF set out the need for the ap plication of the Sequential Test to steer new development to areas with the lowest probability of flooding and if necessary, the Exception Test for the development to be located in zones with a lower probability of flooding. Further detailed guidance on flood risk is set out in the Technical Guidance to the National Planning Policy Framework (2012). 283) Relevant policies from the Local Plan Part 1 include Policy S2 Sustainable Development Principles, which requires development to minimise the risk to people and property as a result of flooding and Policy S29 Flood Risk and Surface Water Drainage, which states that developments should be avoided in locations that would be at risk of flooding or where it would increase the level of flooding elsewhere. It also reaffirms the Sequential and Exceptions tests as set out i n national policy. Assessment against Pllaanning Policcy

284) The Technical Guidance to the National Planning Policy F ramework (2012) lists under ‘Water­ compatible development’, ‘Water transmission i nfrastructure and pumping stations’. The majority of the Proposed Scheme, including the Water Treatment Works, Moota Hill Service Reservoir and Harrot Hill Pumping Station is located outside of Flood Zones 2 and 3. The spatial extent of the Network Water Mains means sections of Flood Zone 3 are crossed; however Table 3 ‘Flood risk vulnerability and flood zone ‘compatibility’’ of the Technical Guidance shows that water transmission infrastructure is an app ropriate development in all flood zone categories, including Flood Zone 3. 285) The FRA provided as part of the ES has completed the Sequential Test and the Exception Test where required in Flood Zone 3 and these tests are considered to have been passed. 286) Planning policy princi ples are add ressed through the incorporation of mitigation measures. These include all sub-surface elements at the new WTW site being ‘designed t o prevent water ingress and to be able to withstand the hydraulic pressures associated with rising groundwater levels. Any increase in the volume of surface water runoff generated by the proposed WTW site would need to be attenuated on site and discharged at the greenfield runoff rate. 287) All sub-surface elements at the M oota Hill SR site would be designed to prevent water ingress and would also need to be able to withstand the hydraulic pressures associated with rising groundwater levels. Any above ground elements at the Harrot Hill PS sit e that could be vulnerable to water ingress, such as electrical equipment, would need to be raised above the level of possible flooding including an allowance for climate change. 288) With the mitigation measures described above the risk of flooding to the scheme during its operationa l period is considered to be low. In addition, the impact of the proposed scheme on flood risk elsewhere is not considered to result in any significant, adverse effects. The residual risks that remain are limited to the failure of individual assets and infrastructure but this risk is limited as they are subject to rigorous maintenance and inspection regimes. 289) The Proposed Scheme is therefore considered to be in accordance with NPPF paragraphs 100, 101, 102 a nd 109 as the tests requ ired are passed and Local Plan polic ies S2 and S29.

3.5.5 Ecology and Nature Con servation Planning Policy

290) Paragrap h 118 of the NPPF lists a number of principles to ensure that biodiversity is conserved and enhan ced and that any development that detrimentally affects or causes loss to local ecology should have benefits that clearly outweigh these impacts. It is of particular importan ce if:

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“...significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated or, as a last resort, compensated for, then planning permission should be refused

291) Relevant policies from the Local Plan (Part 1) are Policy S2 Sustainable Development Principles, which seeks to protect, maintain, enhance and re-connect the range and vitality of habitats and species and Policy S32 Safeguarding Amenity prohibits development that causes s ignificant adverse impact in relation to biodiversity. Policy S35 Protecting and Enhancing Biodiversity and Geodiversi ty, requires development to protect and enhance key ecological habitats and wildlife corridors and to maintain and enhan ce conditions for priority habitats and species id entified in the Cumbria and UK Biodiversity Action Plan Priority Species and habitats or the Cumbria Biodiversity Data Centre. 292) The Biodiversity 2020 strategy’s mission is to “halt overall biodiversity loss” and “retain the protection and improvement of the natural environment as core objectives of the planning system.” Assessment against Pllaanning Policcy

293) It is considered that c onstruction activities could cause habitat loss (both permanent and temporary), habitat fragmentation, habitat degradation or physical damage, pollution, introduction of invasive species, disturbance to species or hab itats, direct injury/mortali ty to species, and hydrological changes through ground disturbance, all of which have the potential to adversely impact most of the ecological receptors. 294) A series of generic m itigation measures have been proposed to help reduce the impacts of construction. These m itigation measures include targeted pre-construction surveys to ensure previous data are still relevant, oversight of eco logically sensitive works by an Ecolo gical Clerk of Works, temporary fencing to avoid incursion into sensitive adjacent habitats, implementation of the Environment Agency’s Pollution Prevention Gui delines and United Utilities’ Biosecurity Policy, and adherence to industry-standard environmental safeguards (as detailed in the Proposed Scheme’s Construction Code of Practice in the ES). 295) In addition, works are recommended to be undertaken outside of key migrating, breeding and/or hibernation seasons (e.g. for red squirrels, birds, bats and salmonid fish) and not during the night time near sensitive habitats and species (e.g. for bats, otters and salmonid fish). Wherever practicable, all habitats would be restored to pre-construction conditions with elements of enhancement included (e.g. for birds, bats, red squirrels and reptiles). 296) With the mitigation recommended above and detailed in the ecology technical appendices of the ES, residual effects of the construction phase a re expected to be not significant for Great Crested Newts and other amphibians, reptiles, and specific bird. For other receptors, there is potential for residual impacts in the short to medium term for designated sites, other notable habitats, bats, otter, red squirrel, other bird receptors and aquatic ecology receptors, althoug h the long term effects would not be significant. However, the loss of woodla nd as part of the Proposed Scheme cannot be mitigated and compensatory woodland planting has been incorporated as part of the strategic mitigation measures to accompany the Proposed Scheme, in the Ennerdale Valley (see section 5 for more information). 297) The mitigation and compensation all contribute to the objective of preserving biodiversity within Allerdale and it is considered that the sensitive approach taken by the applicant is compliant with Paragraph 118 of the NPPF and Policies S2, S32 and S35 of the Local Plan.

3.5.6 Cultural Heritage Planning Policy

298) Under Paragraph 128 of the NPPF, applicants for planning permission are required to provide a description of the significance of any affected heritage assets and their settings in sufficient detail to understand the potential impact of the proposal on them. In making planning decisions, great weight is to be given to the preservation of designated heritage assets. 299) Paragrap h 132 of the NPPF states that where development would lead to substantial harm or total loss of significance, local planning authorities are instructed that they should refuse consent, unless

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it can be demonstrated that it is necessary to achieve subst antial public benefits that outweigh that harm or loss. 300) Relevant from the Local Plan (Part 1) is Policy S27 Heritage Assets, which seeks to conserve and enhance the historic environment including all heritage assets and their settings in a manner appropriate to their intrinsic historic value and s ignificance. The policy states that only proposals which do n ot harm any positive qualities of the heritage asset(s) would be approved, unless there is a clear and convincing public benefit to the proposal that would outweigh the harm caused to the asset. Assessment against Pllaanning Policcy

301) Construction activities associated with the proj ect would potentially impact on known buried archaeological remains and historic landscape types. This would include elements integral to the understanding of the asset. The activities could also influence built heritage through adverse visual impact on the setting of listed buildings and also on the setting of archaeological remains from the temporary compounds and laydown areas. Any impacts are mainly limited to the construction phase although the setting of heritage assets could be affected during the operation phase as a result of new elements of above-ground infrastructure. 302) The cons truction of the Network Main would require the temporary removal of a Grade II listed milestone east of Broughton Cross. The milestone would be carefully removed prior to construction and would be stored in a secure and weatherproof location for the durat ion of the construction works and reinstated to its ori ginal location on completion of the construction works. The temporary removal of this will also require Listed Building Consent (to be submitted in due course). 303) The setting of Scheduled Monuments Roman forts at Papcastle and part of the vic us, the Rom ano- British farmstead in Fitz Woods and the Settlement 25 m south-east of Gatra would experience some temporary disturbance to their setting, but it would not have a long-term effects or direct impacts on the monum ents. 304) Measures to reduce potential impacts on the historic environment have been incor porated into the design throughout its development to avoid and preserve heritage assets. This has been done in consultation with heritage stakeholders. Mitigation agreed includes set-piece excavation, topographic survey, watching brief, photographic survey and landscape planting/reinstatement. 305) The approach to Cultural Heritage is therefore compliant with the polic ies of NPPF as no substantial harm has been assessed on designated heritage assets during the construction phase of the project . It is also meets the requirements of Policy S27 as any potential impacts on the setting of heritage assets are addressed to prevent harm to any positive qualities of the heritage asset.

3.5.7 Soils, Geology and Hydr ogeology Planning Policy

306) The overriding national objective at Paragraph 109 of the NPPF is that ‘the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, geological conservation interests and soils, preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.” 307) Relevant policies from the Local Plan (Part 1) are Policy S2 Sustainable Development Principles, which states the counc il will protect soils, water sources and water quali ty, and ensure they are resilient to climate change and Policy S36 Air, Water and Soil Quality prohibits development that will have an adverse impact on the characteristics of surrounding soils and substrata. The policy states that the Council will seek to ensure the use of poorer quality land in preference to that of a higher quality whilst having regard for the economic and other benefits of the best and most versatile land, where development is considered necessary.

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Assessment against Planning Policcy

308) Issues to be considered are the presence of potentially contaminated l and, whether any changes to base flows in river streams would occur, protecting bedrock and second ary aquifers from groundwater pollution and avoiding buildings and infrastructure subsidence as a res ult of dewatering. 309) Measures to reduce t hese potenti al impacts include managing groundwater draina ge, avoiding impacts on protected a nd valued geological sites through routing the pipeline and associated infrastructure to avoid sensitive sites. The risks of encountering contaminated land have been reduced through routing decisions where this has been possible. Where preliminary risk assessments have identified that contaminated land is a possibility, further ground investigations would be carried out prior to any development taking place. 310) In addition, the risk of pollution to soils and groundwater and other harmful change s to the hydrogeological environment would be reduced through the application of the plans and principles set out in the Construction Code of Practice, Site Specific Method Statements, the Material Management Plan and Environment Agency PPGs. Implementation of a soil management plan and good remediation practice would be followed by backfilling pipe trenches with material having similar permeability and characteristics to the natural in-situ deposi ts. 311) Minerals Safeguardin g Areas are provided under Core Strategy Policy 14 and these relate to Sand and Gravel at scheme SSections 11, 16, 18, Limestone rock at scheme Sections 6, 7, 8, 9, 11, 13, 16 and shallow coal and fire clay at scheme Sections 11, 12, 14, 15). The soils, geology and Hydrogeology section of the ES has provided a detailed analysis of the impact on m inerals deposits within the MSA and has concluded that the proposed schemes has minimal impacts on potential mineral de posits and does compromise the objectives of this policy. In addition, there are no operational mineral ext raction activities or extant planning applications for workings within 250m of the Proposed Scheme. Therefore it is considered that the proposed sch eme would not impact on the MSA. In addition the scheme section 7 has bee n designed to maintain access to Moota Quarry. 312) Chapter 13 of the ES demonstrates that risks have been mitigated as far as possible and are mainly limited to the construction phase only. The impleme ntation of the proposed mitigation measures would minimise impacts in accordance with the NPPF objectives and Poli cy S2 and S36 of the Local Plan.

3.5.8 Materials and Waste Planning Policy

313) National policy relatin g to waste is contained i n National P lanning Policy for Waste (October 2014). It highlights the need for sustainable development and resource efficiency by driving waste management up the waste hierarchy. 314) Paragrap h 8 requires the implementation of the waste hierarchy; that the development makes sufficient provision for waste management and that the handling of waste arising fro m the construction and opera tion of development maximises reuse/recovery o pportunities. Overall the need for offf-site dispos al should be minimised. 315) Relevant policies from the Local Plan (Part 1) are Policy S2 Sustainable Development Principles which states the counc il will promote waste reduction and recycling and Policy DM12 Sustainable Construction which states development must promote sustainable waste management. 316) Relevant from the Cumbria County Council Core Strategy (2009) include Objective 2, which aims for effective waste mini misation measures to be adopted and managed at the highest achievable level within the waste hierarchy and the Waste SStrategy, which states that by 2020: ‘waste will be managed near to where it is produced, as far as practicable bearing in mind Cumbria's relatively small and dispersed pattern of population’. Assessment against Planning Policcy

317) The production of unnecessary waste is inefficient from both a cost and sustainabi lity perspective as it results in additional costs for it s disposal whilst also depleting natural resources. Where waste

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is produced, re-use and recycling li mits the nee d to obtain new materials and also provides a positive benefit in terms of reducing transportation impacts. 318) Early scheme designs involved route optimisation for the best overall solution which included avoiding waterlogged and soft ground where possible and potential sources of ground contamination so that excavated soil materials would be more readily re-usable or recyclable. In addition materials use would be reduced by minimising pipeline le ngths where possible an d successfully optimising the length of gravity fed pipeline to reduce the need for pumps and associated materials / product use. 319) United Utilities would optimise the re-use of excavated material on-site within the scheme and current predictions indicate this is approximately 82.5 % although this could be exceeded further. Contractors would be required to develop a Site Waste Management Plan (SWMP) for construction contracts and engage with competent waste management and recycling sub-contractors to ensure that waste is managed in accordance with the waste hierarchy. 320) During operation, there would be no significant change in materials use or waste generated during operation and maintenance. 321) Overall the positive measures to reduce the amount of materials used to construct pipes, the high level of re-use of excavated material and other waste minimisation and segregation measures make a significant contribution to reducing the resource implications of the project in line with the Waste Hierarchy, Local Plan policies S2 an d DM12 and Objective 2 of the Cumbria County Council Core Strategy.

3.5.9 Public Access and Recreation Planning Policy

322) NPPF paragraphs 73 and 74 state the importance of high quality open spaces and opportunities for recreation in contributing to the health and well-being of communities and prohibit the loss of open space and recreational land. Parag raph 75 seeks to protect and enhance public rights of way and access and states that local authorities should seek opportunities to provide better facilities for users. 323) Relevant from the Local Plan (Part 1) includes Policy S22 Transport Principles wh ich requires development to protect and enhance designated public rights of way. 324) Also of relevance is the Cumbria Countryside Access Strategy 2014 to 2019 which provides the strategic framework for the management and improvement of countryside access and recreation in Cumbria (including the Lake Distric t National Park). One of four strategic aims of the document is to: ‘Provide high quality, well maintained access to the countrysside includin g the public rights of way network, open access land, access to water and other means which meets the needs of its users’. Assessment against Pllaanning Policcy

325) 29 PRoWs within Allerdale, including NCN71 (Coast 2 Coast), would be directly or indirectly affected. Where it is technically possible and safe to do so, wicket gates would be installed in the temporary working area demarcation fence line to allow the public continued access across the working width. For the safety of the general public 17 PRoWs would ne ed to be closed for a short duration at the time of the pipe laying in the vicinity of the PRoW. A formal diversion would be provided for NCN71. 326) Access to High Dyke Equestrian Centre, Great Clifton Village Hall and Great Clifton Rugby League Pitch would be disrupted during construction. A traffic management system would be implemented, meaning that access would be maintained. 327) The majority of impacts on public access and recreation would be minor. Detailed discussions would be held with PRoW officers, local cycling groups and the managers/owners of the facilities that are affecte d in order to discuss and agree the temporary closures and d iversions. The applicant would require the contractor to work in consultation with all parties to limit disruption during construction and Rights of Way would be reinstated and ‘made-good’ following construction. Whilst a scheme of this scale and complexit y inevitably has some implications for the Rights of Way Network these are mainly limited to the construction peri od and are t emporary in nature. This collaborative approach t herefore meets the objectives of the NPPF and Policy S2 of t he Local Plan.

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3.5.10 Socio Economics Planning Policy

328) The NPP F sets out twelve core land-use principles that should underpin decision taking and decision making; these include the principle that planning should “proac tively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs”. 329) Section 1 of the NPPF ‘Building a strong, competitive economy’ highlights that the Government is committed to securing economic growth in order to create jobs and prosperity, buildi ng on the country’s inherent strengths, and meeting the twin challenges of global competition and of a low carbon future. NPPF Paragraph 19 states that: “The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning ssystem.”

330) Section 3 of the NPPF ‘Supporting a prosperous rural economy’ states that ‘planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable development’. To promote a strong rural economy, planning should support sustainable growth and expansion of all types of rural business, promote the development of agriculture, support sustainable tourism and promote the retention of local services and community facilities. 331) Relevant policies from the Local Plan (Part 1) are Policy S2 Sustainable Development Principles, which states the counc il’s objective of supporting the rural economy, Policy S14 Rural Economy, which states that the council is committed to supporting the economic prosperity and sustainability of rural communities and Policy S26 Community and Rural Services, which states that the council will protect existing community facilities which provi de for peopl e’s day to day, social and cultural needs. Assessment against Planning Policcy

332) Potential impacts that have been considered within the social and economic chapter of the ES include those on local employment (directly and indirectly), effects on tourism includ ing the availability of visitor accommodation, maintaining access to community facilities and social infrastructure and disruption from severance. A detailed numerical analysis of economic impacts is provided in the ES. 333) It is anticipated that there would be 24 residential, commercial or community properties or facilities that would potentially experience severance. These are all short term with a maximum length of 10 weeks. There are 19 residential, commercial or community properties that are ident ified as effected by temporary land take. 334) Mitigation has been proposed to reduce or prevent an additional 5 isolation impacts. This mitigation would take the form of a commitment by UU not t o close multiple roads used by a single community at the same time; At Bridekirk, mitigation would be in the form of a commitment not to undertake the road closure during school term time. As highlighted earlier in this section and the accompanying SCI, the applicant has engaged closely with local communities, landowners and businesses to minimise disruption as far as is practicable.

3.5.11 Agriculture and Sporting Land Use Planning Policy

335) Paragrap h 112 of the NPPF states that local planning authorities should: “take into account the economic and other benefits of the best and most versatile (BMV) agricultural land. Where significant developme nt of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas o f poorer qualit y land in preference to that of a higher quality.”

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336) BMV land is defined i n the Glossary at Annex 2 to the NPPF as land in grades 1, 2 and 3a of the Agricultural Land Classification (ALC). 337) Relevant from the Local Plan (Part 1) includes Policy S2 Sustainable Development Principles, which states that significant development on the best most versatile land should be avoided. Assessment against Planning Policcy Objectives

338) Construction of the pi pelines would require access for plant, vehicles and operatives in a temporary working co rridor of up to 40m in width. Within this corridor a smaller area would be subject to direct soil stripping and excavation works necessary to lay the pip e work and associated fittings. Construction of the pro posed new water treatment works, service reservoirs and pumping stations along with the fittings on the pipe work would result in permanent land-take. 339) The appli cation boundary has been developed in consultation with land owners and agricultural and sporting interests. This has resulted in an application boundary that, as far as is practically possible, minimises effects on agricultural soils, and agricultural and sporting activities. 340) Within Allerdale Borough Council, 23 agricultural and sporting interests would experience some adverse impacts during the construction phase. 341) Mitigation has been d eveloped to avoid or reduce construction and operational effects on agricultural and sporting activity. The Construction Strategy for Pipe Laying would be followed and specific mitigation measures would include provision of alternative access, reinstate ment of boundary features and reinstatement of land drainage systems. 342) The effects on soils and protection of their agricultural land capability is closely related to the procedures for stripping, storing and reinstatemment of soils in all areas where the works are temporary and land is being returned to agriculture. A Soil Management Strategy and Drainage Strategy would ensure best practice measures are employed and the sustainability of soils and their agricultural land capability is protected. 343) Agricultural land is classified according to its quality and versatility with 1 been the best and 5 t he poorest (grade 3 is sub-divided into categories 3a and 3b). Grades 1, 2 and 3a are classified as the best and most versatile land (BMV). 344) Based on the ALC Strategic Map information available to Natural England, ALC surveys already undertaken and Soil Association data, it is considered likely that up to 20% of the land would be classified as BMV land, (assumed to be Grade 3a as no Grade 1 or Grade 2 land is already graded as such within the stud y area). 345) Whilst the applicant has taken all reasonable steps to avoid impacts, some limited residual impacts are unavoidable in a scheme of this scale and complexity. The applicant would work closely with all affected parties to minimise disturbance, disrup tion and any long term impacts and subject to planning permission three more phases of consultation are planned prior to construction and following construction (see below).

3.5.12 Traffic and Transport Planning Policy

346) Paragrap h 29 of the NPPF states: “Transport policies have an important role to plaay in facilitating sustainable development but also in contributing to wider sustainability and health objectives. The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that diffe rent policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas.”

347) Paragrap h 32 of the NPPF requires all development that generates significant amounts of movement to be supported by a Transport Statement or Transport Assessment. 348) Relevant policies from the Local Plan (Part 1) are Policy S22 Transport Principles, which states that development should improve accessibility and movement in the local area, ensure they can be 60

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accessed safely and that they do not compromise the safety of any transport route, and makes provision for a Transport Assessment / Travel Plan to accompany devel opment proposals where necessary. Policy S32 Safeguarding Amenity prohibits development that would gen erate severe highway infrastructure or network problems in relation to access, road safety, traffic flow or car parking. Assessment against Pllaanning Policcy Objectives

349) Baseline traffic counts were obtained at 27 junctions around the West Cumbria hig hway network, encompassing a 24 hour period wit hin May 2015. A spreadsheet model was produced to assess the impacts of construction traffic against backgrou nd flows, relative to the thresholds prescribed within the Institute of Environmental Management and Assessment (IEMA) Guidance on assessment of traffic environmental impacts. The key locations in Allerdale where thresholds are p otentially exceeded during the construction period (either 10 % HGV’s or 30 % total traffic) are the Unnamed Road and School Lane at Bothel within Section 7 (WTW to Quarry Hill). 350) These locations are considered to be Sensitiv e due to property directly adjoining the highway and relatively low background traffic flows. As a result, it may only take a relatively smal l increase in HGV traffic to create a perception of impact amongst local residents. The Transport Assessment considered that impacts would generally be slight when reviewed against the key indicators of severance, pedestrian delay / amenity. Larger volumes of t raffic associated with construction are generally present wher e background traffic is al ready high therefore the overall impact of the scheme during construction is identified as minimal. 351) The Trans port Assessment has demonstrated that whilst a number of locations are sensitive to traffic increases the amount of additional traffic expected at these locations would only result in a slight change in local amenity. Furthermore any impacts would only occur for a tem porary period during construction. Therefore, it is considered that the objectives of the NPPF and Local Plan Policy S32 have been met.

3.5.13 Noise and Vibration Planning Policy

352) Paragrap h 109 of the NPPF highlights the need to prevent developme nt from contributing to unacceptable levels of noise pollution. 353) Paragrap h 123 of the NPPF discusses the need to avoid noise from giving rise to significant adverse impacts on health and quality of life, m itigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development and recognise that development would create some noise. 354) Relevant policies from the Allerdale Borough Council Local Plan (Part 1) include Policy S32 Safeguarding Amenity, which prohi bits development that would result in pollution or hazards which prejudice the health an d safety of communities and their environments or result in a detrimental effect on the local area in terms of or environmental quality. Assessment against Pllaanning Policcy Objectives

355) Whilst elevated construction noise levels are predicted for many sensitive receptors close to the route of the open cut and slip-lining works, construction acti vities would generally pass quickly through a given area and would therefore be short-lived. If rock is encountered, notably higher noise levels would be expected during rock breaking activities. Good practice guidance would be followed, but there may be some locations, particularly where rock is encountered, that would require further noise mitigation to reduce noise impacts at nearby sensitive receptors. The ES chapter highlights those sensitive receptors most likely to experience significant noise impacts and suggests appropriate mitigation measures that may need to be employed. 356) Construction activities taking place at the temporary laydown areas that are selected to also function as temporary site compounds along the Network section of the route, most notably the establishm ent of the site compounds, have the potential to cause signifi cant adverse airborne noise impacts at the nearest noise sensitive receptors. Table 19.2 within the ES presents the separation distances between sensitive receptors and laydown (potential site compound) areas within Allerdale 61

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BC, highlighting those receptors most susceptible to adverse impacts during construction of the site compounds. 357) It is anticipated that minor road crossings would be undertaken using open cut techniques over a 1­ 2 week period. Again, whilst elevated noise levels may be experienced, they are likely to be of short duration. However, there are some areas where more major works along existing roads would be required, taking place over a longer period. Noise impacts at sensitive receptors close to these road/pipeline crossing points would be of longer duration and as such there is a greater potential for prolonged adverse effects. 358) Ground compaction would be undertaken along haul routes, at crane pads, at site compounds and during tren ch backfilling. As such, adverse ground-borne vibration impacts during compaction may arise at nearby sensitive receptors. Vibration p redictions during compaction have demonstrated that adverse impacts may be experienced at distances up to 55 m from such activities. Suitable mitigation, including informing affected resident s, would need to be impl emented, as appropriate. Vibratory compaction techniques should not be used within 11 m of nearby sensitive receptors to protect against potential building damage. 359) There is potential for elevated construction noise levels over an extended period of time at the new WTW, and for a shorter duration at Moota Hill SR and Harrot Hill PS. Construction noise has been evaluated at these locations. Noise calculations suggest that with the adoption of appropriate noise control measures and management practices, to be designed and adopted in consultation with the local authority, would avoid noise thresholds from being exceeded. 360) Analysis undertaken has shown that two roads would experience perceptible increases in road traffic noise level as a result of additional construction vehicles associated with the proposed scheme, an unnamed road linking Bothel and Torpenhow, and School Lane in Bothel. These increases in noise are considered t o be temporary adverse construction noise impacts associated with the scheme. 361) The new WTW site consists of numerous buildings to house various plant items. The main building, the Filter and Chemical building, is approximately 80 m long and 65 m wide, and some 14 m tall at its tallest point. This building is pro posed to have clad walls, and a green roofing system, with roller shutter doors. Operational noise emissions hav e been calculated in relation to noise levels at the nearest properties to the WTW. These calculations sugges t that total noise levels a s a result of the combined effect of the existing noise sources and the proposed WTW site are below threshold values for both day-tim e and night-time operations. Therefore adverse effects are not expected at nearby properties as a result of operations at the proposed WTW. 362) During the operation phase Moota SR would comprises a service reservoir and associated valve house. The Moota SR is located just off the junction between the A595 and B5301. The service reservoir would emit very little if any noise in its operational state, whilst the valve house is likely to contain pipework and valves, which are expected to emit very little noise too. The valve house is likely to be constructed of concrete, approximately 600 mm thick, and would have no louvres or other openings apart from double s kinned security doors. The nearest noise sensitive receptors to the SR are a motel on the A595, approximately 670 m to the north east, and a residential property located approximately 690 m to the south west, again on the A595. It is therefore not likely to give rise to noise concerns. 363) Amenity i s maintained in accordance with NPPF and the Local Plan and no specific noise mitigation measures are required during operation of the permanent installations. During construction, adverse impacts are predicted to occur at a number of locations, these impacts wo uld be mitigated through good neighbour constructi on practices and specific measures where necessary.

3.5.14 Air Quality and Odour Planning Policy

364) Paragrap h 109 of the NPPF highlights the need to prevent developme nt from contributing to unacceptable levels of air pollution.

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365) Relevant policies from the Local Plan (Part 1) are Policy S2 Sustainable Development Principles which states the counc il will minimise the impact on natural resources by avoiding pollution and Policy S32 Safeguardi ng Amenity states that development will not be supported that results in ‘pollution or hazards which prejudice the health and safety of communities and their environments, including n ature conservation interests and the water environment which cannot be overcome by appropriate mitigation measures’. In addition Policy S36 Air, Water and Soil Quality states that unless adequate mitigation measures can be secured, development pro posals will be resisted that would have an adverse impact on air quality. Assessment against Pllaanning Policcy

366) There are a number of properties in close proximity to earthworks activities (<20 m) at scheme components 16 (Network main – Papcastle to Broughton Cross), 17 (Sliplining – Broughton Cross to Stainburn), and 18 (Sliplining – Cockermouth to Southwaite Farm) where residents are likely to be highly sensitive to dust emissions due to their c lose proximity to works. Defra background 2018 annual mean PM10 concentrations are <24 µg. m-3 across the Allerdale Borough Council study area, therefore the sensitivity of people who may be exposed to particulate matter emissions (PM10) associated with construction activities is likely to be low and the impact of construction vehicles on local air quality at identified receptor locations is predicted to be negligible. 367) Mitigation measures incorporated into the scheme include : standard good practice measures to mitigate dust emissions from the proposed development should be included within a CCoP to prevent or minimise the release of dust entering the atmosphere and/or being deposited on nearby receptors. Particular attention wou ld be paid to operations which must unavoidably take place c lose to the site boundary. Mitigation measures appropriate for the identified likely level of risk are outlined in the air quality assessment (IAQM, February 2014) and it is recommended that they are included in the CCoP for the site, which should be agreed with the local authority. Effective implementation of the CCoP and incorporation of mitigation measures proposed should reduce all construction dust soiling and human health impacts to ‘not significant’. 368) With the mitigation measures the Proposed Scheme would not contrib ute to unacceptable leve ls of air pollution and is therefore is in accordance with Paragrap h 109 of the NPPF and Local Plan.

3.6 Consultation 369) Several phases of consultation have taken place prior to this planning submission. The first phase took place in summer 2014 following the EiP and this focused on raising the awareness of the scheme and developing options for the proposed locations of the Water Treatment Works and Service Reservoirs. For Allerdale t his focused on the Water Treatment Works that is now proposed under this application near Hagswood, the WTW and Pumping Station at Harrot Hill and the Service Reservoir at Moota Hill. 370) The second phase focused on gathering the views of the l ocal community, businesses and landowners taking into account feedback received in Phase 1. This took place from December 2014 to May 2015 and the applicant engaged with the local community and stakeholders through further public exhi bitions in Aspatria, , Lorton, Cockermouth and Seaton which were advertised extensively including on social media. Presentations to local councils ranging from parish councils to the County Council were undertaken and these were supported by tours of the route. Specific meetings also took place with landowners in Bothel and Cockermouth. Over 450 individuals or stakeholders attended these events with comments raised about potent ial disruption, impacts on local businesses, fundi ng the scheme, employment opportunities and specific technical questions. 371) Using the feedback received at the second phase, the third phase in the run up to this planning application has concentrated on scheme specif ics with one to one meetings (including landowners), interest group and tour ism group meetings. Specific issues associated with the construction programme were discussed as well as compensation arrangements. The outcome of phase 3 was final changes to the design particularly around detailed route selection (for example across a field), remedial works and mitigation. 372) The outcome of consultation and engagement has therefore fed into the proposed scheme now subject to this planning application. Should planning permission be received, the applicant will continue engagement and consultation activities through three more phases of planned consultation. 63

Planning, Design and Access Statement

These additional phases will focus on final definitive construction plans, mobilisation arrangements and post construction mitigation. 373) Overall the applicant has engaged and consulted on the proposed scheme from its inception to its conclusion including during the aftercare period. This reflects the applicant’s commitment to work with the local community as custodian of the water supply.

3.7 Design and Access 374) This Design and Access section demonstrates how site and context analysis has been used in design development to produce a sustainable and high quality infrastructure scheme. This sectio n focusses on the key permanent developments, which are as follows:

3.7.1 New Water Treatment Works Site (WTW) Site Analyssis and Surrounding Context

375) The proposed develo pment site comprises five linked open semi improved grassland fields, which are currently grazed with a total area of approxi mately 27.3 ha. The northern and western boundaries are demarcated by existing field boundaries defined by fenc e, hedgerow and stone walls. Hags Wood is adjacent to the western boundary. The north east boundary is demarcated in part by a stone wall adjacent to a minor road. The eastern boundary continues adjacent to a highway layby, with a hedge along the majority of t he site frontage adjacent to the A595. The area surrounding the site is predominantly agricultural. 376) Hags Wood is adjacent to the western boundary and is a woodland block consisting of evergre en conifer trees with deciduous trees on the edge bordering the proposed site. There are two small ditches crossing the sit e, these are visible due to the different vegetation growing along the route. The ditches feed into a beck which runs along t he north perimeter of the site. 377) The site is in proximity to the Lake District National Park, t he boundary of which is formed by the A595, and as such the landscape character of the development site shares some qualities and characteristics with the adjacent areas in the National Park. The importance of the l andscape surrounding the site is therefore a major consideration and there are a number of local Landscape Character Areas. Efforts to minimise impacts on landscape character and in views through innovative design have been explored and are described later in this document (see Figure 3.1). 378) The accompanying landscape assessment recognises the sensitivity of the landscape to large scale development and it is noted expressly that this kind if development is largely absent from t he area. The assessment suggest impacts resulting from larger developments can be reduced by their careful location away from ridge tops and their scale and form respect local vernacular building materials and characte r.

Figure 3.1 - Existing landscape is characterised by rolling hills patterned with hedgerows and small plantations

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Planning, Design and Access Statement

379) The trees in the east corner of the site and along the layby currently provide an established screen in views from the east. There are open views of the site from nearby properties at Williamsgate and also from further along the road which runs parallel to the site boundary. 380) The land immediately south of the A595 is at lower level than the road, rolling downwards towards the valley of the River Derwent. The landform screens views of the site from the village, however longer distance views are possible from Watch Hill, a prominent ridge line on the south east of the valley. 38 1) The exist ing trees and hedgerows surrounding the site are predominantly deciduous, and combined with the natural landform provide screening of the site from the surrounding area. It is recognised however that screening benefit of these deciduous trees is most apparent in the summer months and during winter the months the screening is lessened. Design Evolution

382) As detailed in Chapter 3 of the Environment Statement the original preferred site for the WTW was at a location closer to Bridekirk adjacent to Pinggy Wood. Although the site met the required engineering criteria the scale of the development at that location, which occupied an elevated position ov erlooking the A595 was a concern and United Ut ilities explored other alternatives in conjunction with advisers from the Local Planning Authority. 383) Further as sessment led to the selection of the proposed site and the design has evolved through an appraisal process which considered options from a landscape, architectural and technical perspective. 384) Taking into account the existing features on site, landscape character and the local landscape and policy context, the following design principles were developed to inform the design of the development:  Use natural and local materials wherever practicable and in a manner that is appropriate to the setting and function of the devel opment  Take cues from the surrounding landscape and environment and reflect this in the proposed landscape and architectural des ign and site layout for the development. This would include having regard to the guidance contained in t he relevant published landscape character assessments.  Limit the height of the developm ent  Use materials which minimise glare as this can draw attention to a development in this remot e landscape and where developm ent is not a significant part  Consider the potent ial for effects on views from all directions surrounding the site and incorporate innovative design solutions to promote integration the development into the landscape and to include screening where appropriate. This may include the reuse excavated materials on site to alter the landform for enhanced screening purposes  Retain and reinforce existing landscape features such as trees, walls, hedges an d existing walls wherever possible  Incorporate appropriate measures for biodiversity enhan cement as part of the landscape proposals;  Consider the phasing and const ruction programme of the project to identify ways to minimise the visual impact of temporary works (e.g. early placement of excavated materials)  Reduce the environmental impact through the minimisation of natural resources, by optimising the material selection, reducing operational energy and mitigating pollution sourc es. 385) Other architectural approaches were considered, including a design in the form of traditional farmyard style buildings similar to the existing Ennerdale WTW. Howev er it was quickly apparent that the scale of the proposed WTW was much larger and consequently did not lend itself to the same approach, as the mass and height would be considerably greater than the indigenous farmyards and other ‘traditional’ agricultural buildings in the locality.

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386) An ‘iconic’ architectural solution was also considered, but given the context close to the Lake District National Park, and the local planning policies, it was considered that such an approach would not be appropriate in this location. 387) The proposed ‘green roof’ design emerged through consideration of important factors such as the need to reduce visibility of the development from the surrounding area and particula rly from the Lake District National Park. The green roof solution provides the optimum response to the context and in so far as possible for a for a treatment works of this scale, the design takes its cue from the surrounding landscape and adopts a strategy to minimise overall visual effects. 388) A further aspect of design development involved careful consideration of the location of the WTW in relation to the existing topography. The land at the WTW site is undulating and tends to slope in a north-westerly direction from higher ground adjacent to Hags Wood and the A495 to lower-lying land adjacent to watercourses. The necessary hydraulic requirements for the development (the inlet and outlet level s) are fixed and therefore there are considerations in respect of this and i n relation to siting of the development on existing slopes, whilst also taking account of other factors such as visibility and distance from properties. 389) If for example the treatment works were located on the lower land on the hillside, the level at which the main elements of plant would sit would not change and as a result potentially more structures would need to be situated above ground. A further consequence of locating the WT W on the lower slopes would be the need to import larger volumes of fill materials to create support under and around the structures. This would mean siting new structures on potentially less stable made up ground and would resu lt in an increase in the number of heavy goods vehicles entering and exiti ng the site during construction. 390) After considering options for siting it was concluded that the best locat ion for the WTW would be to position the WTW toward the southern part of the site near to Hags Wood and to cut into the higher ground, which would mean that the majority of the structures would be screened in views from the National Park by this existing landform. This approach also ensures that distance from properties in the locality is maximised. Excavating into the existing landform not only offers screening benefits but generates on site arisings that can be used in other parts of the site where it can be utilised to provide additional screening benefit. This is a sustainable approach to materials re-use. It is considered that the screening afforded by the landform in combination with the implementation of a robust scheme of new soft landscaping offers the best solution for minimising overal l visibility of the large structures associated with the functional requirements of the WTW. 39 1) Having determined the optimum location of the proposed WTW, the site layout was developed with the aim of minimising environmental effects. Site Layout

392) The A595 runs along a natural ridge line, and the propose d WTW is effectively screened from view from much of the National Park by this ridge, however, views may be possible into the southern corner of the site due to the higher landform close to Hags Wood. The proposals place the works to the south and south-west of the site, cutting into the higher ground where the land rises towards Hags Wood. This strategy of cutting into the hillside brings the double advantage of concealing the works from the west and south-west aspects, while generating a greater volume of f ill material for the creation of landscaped mounds to the north, south and east. It is a strategy that would minimise the overall visual effects associated with the proposed treatment works. 393) The proposal includes some large above ground structures required for the functional operation of the wastewater treatment works, these are the filter buildings, chemical buildings an d the Motor Control Centre which a re combined under the large green roof. 394) The requirement for a Control Building and Workshops was recognised, as an opportunity to place these in a position whe re they may screen the plant requirements that have a more industrial appearance. These have been placed at either side of the entrance to the site in an ‘L’ formation, designed to provide a welcoming entrance but with the dual purpose of screening the processes at the top end of the site (i.e. the south-eastern part of the works), which include the flocculation chambers, turbine and inlet chambers, much of which lay below ground, but have some visual presence, including kio sks at ground level.

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395) A further consideration for the site layout was the final levels of the contact tank and service reservoir relative to existing ground levels. It was established that to limit the potent ial visual effect of these, ideally the tanks would need be set into the hillside as far as possible; the l ayout theref ore places these at the bottom, lower end of the site to allow the tanks to be partially dug into the ground and thereb y limit the amount of above ground s tructures that could be visible. This strategy allows a significant area for establishing new woodland planting between the works and the A595 at the top end of the site. 396) The proposed arrangement puts the main tanks and associated inlet/outlet chambers, at the lower end of the site, and partially buried into the hills ide and with scope for bunding and landscaping on the lower side to further minimise their visibility. Architectural Concept

397) Central to the architectural concept is the proposed ‘green’ roof (i.e. a built-up roof providing a natural planted covering) covering much of the centre of the site and cloaking the largest buildings, in particular the filters and chemical buildings (see Figure 3. 2). 398) The green roof has been designed to give a natural appearance when the development is viewed from the surrounding area this mini mises the visual impact and has potential to promote biodiversity and slow o r intercept rainwater run-off. It is appreciated that the landscape surrounding the site changes seasonally an d as a result the appearance of a solid structure roof could be more difficult to integrate. The natural green roof offers the potential to reflect seasonal changes and blend with the surrounding landscape.

Figure 3.2 - The proposed design places all the major plant and buildings under one ‘green’ roof

Materials

399) As stated previously the Control Building and Workshops are grouped together on either side of the entrance to the site in an ‘L’ formation, forming two sides of a courtyard, typical of traditional settlements. Although contemporar y in style these buildings are designed in a palet te of materials sympathetic to the location. A gabi on wall – filled with stone excavated from the site – is proposed 67

Planning, Design and Access Statement

for the outward facing elevations, wrapping around the buildings on two sides, and forming a retaining wall behind the workshops. This allows the ground level to the rear of the workshops to be raised accordingly, reducing the scale of the buildings when viewed from the road and creating t he impression of being set into the landscape. 400) Figure 3.3 shows the proposed palette of materials for the Control Building. The proposed zinc finish of the standing seam roof wraps down to meet the gabion wall. This form echoes the ‘wrapping over’ of the green roof of the process buildings beyond, while the zinc finish is evocative of traditional slate in colour. 401) The proposed materials for the elevations facing into the courtyard are a mixture of render finish and timber boarding on the Control Building, the render finish being characteristic of many Lakel and vernacular buildings. The finishes for the workshops are timber with translucent polycarbonate panels over the doors the latter, face into the site to provide natural light into the workshops. Where timber cladding is proposed for the workshop fenestration this would be treated as an over-cladding on a profiled metal cladding base to reduce maintenance and maintain security levels.

Figure 3.3 - The proposed palette of materials for the Control Building includes gabio n walls, zinc roof, render and timber

Landscape Strategy

402) The proposed landscape strategy is integral to the design concept for the building and site layout. The main aims of the proposed landscape strategy are to minimise land scape and visual effects resulting from the deve lopment. The proposals include elements which seek to achieve these overarching aims including:  Creation earth mounds with new planting an d exploitatio n of landform to integrate the development into the surroundings  Retention of existing mature trees and hedgerows, to retain existing landscape pattern and character and use trees for screening  Reinstate and reinforce existing hedges where possible  Reinstate ditches and provide habitat enhancements where practical on adjacent land  Establish significant areas of new woodland planting, hedgerows and wildflora and hedgerows. 403) The landscape strategy proposes to create new planting belts to the south alongside the site entrance, between the treatment works and the A595; in strategic locations to the north; and to the northwest, particularly where the bund around t he underground tanks can be planted. A small drainage ditch emergin g from Hags Wood would be diverted and re-inst ated further east down-s lope and beyond the working area of the WTW. Access and Movement

404) Access to the site is taken from the existing la yby adjacent to the A595. Vehicles would approach the site from the south with or right turn into the site from the north. The access has been located to allow safe access and egress from the site and to keep traffic as far away as possible from the residential properties at Williamsgate.

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405) The site layout provid es a one-way internal road system enabling access at a gradient of around 1 in 40 to relatively level areas for laydown and deliveries. The exceptions to this are the gradient on the access road to the treated water pumping station, where the gradient increases to around 1 in 20 in order to achieve side access to the upper part of pump house chambere .

3.7.2 New Service Reservoir – Moota Hill Site Analyssis and Surrounding Context

406) A new service reservoir is required on the section of pipeli ne between the proposed WTW and existing Quarry Hill WTW to ensure sufficient water is available during emergency situations such as plant failure. 407) The proposed develo pment site comprises two linked agricultural fields with a total area of approximately 4.8 ha. The site is greenfield and is bounded to the south east by the A595, beyond this is the Lake District National Par k. A maintained hedgerow forms the boundaries with the A595 and the local road which itself forms the south western boundary. The area surroun ding the site is predominantly agricultural. 408) The landscape asses sment accompanying recognises the sensitivity of the landscape to large scale development and it is noted that this kind of development is largely absent from the area. The assessment suggest impacts resulting from larger developments can be reduced by their careful location away from ridge tops and t heir scale and form respect local vernacular building material s and character. Design Evolution and Appearance

409) Service reservoirs are buried concrete structures that store water at the head of the distribution network. The top and bottom water levels in the reservoir are dictated by the need t o gravitate water into supply. In order to minimise the impact on the landscape the struct ure would be largely buried into the hillside with re-profiling around it such that only the valve house is exposed. Figure 3.4 is a photomontage which provides an illustrative example of how the service reservoir m ay appear following reinstatement of the site to final ground levels (in t he summer). Figure 3.4 Photomontage of the new Moota Hill Service Reservoir (illustrative purposes only)

410) After a thorough optioneering process which is detailed in Chapter 3 of the Environmental Statement, the Moota Hill site next to the A595 was chosen as the preferred location for the service reservoir. The site is at the optimum hydraulic l ocation to minimise pumping and be nefits from good access off the B5301. 411) The SR has been sited to minimise the cut and fill of excavated material with some spoil proposed to be used in a landscape mound to the boundary with the A595. Following advice from Cumbria Highways the site access would be taken from the B5301. 412) The design includes for:  External handrailing to the valve house woull d be black powder coated not plain galvanised steel to minimise landsca pe and visual impact  External walls and wing walls to the valve houses would be faced with local stone laid in a vernacular style appropriate to the local architecture 69

Planning, Design and Access Statement

 Visible element of the valve hou ses and wing walls would be minimised to reduce landscape and visual impact  Embankments to SRs would be profiled to ensure suitab le gradients for safe grass cutting maintenance, maximum 1:3 and shall be slackened whe re possible t o improve integration of the SR into the existing ground profiles and topography to minimise landscape and visual impact  Lighting would be low level and directional where possible and would be capable of being manually operated or motion sensor only, lighting shall not be in operation 24hrs  Existing dry stone walls and hedgerows will be retained wherever possible to retain existing landscape features and minimise landscape character impact  The provision of a new access to the B5301  Landscaping at the boundary wi th the A595 and the provision of a hedgerow to the northern bounda ry. Access and Movement

413) A new access would be provided for construction and operational purposes off the B5301 Parsonby Brow, via the A595.

3.7.3 New Pumping Station Site – Harrot Hill Site Analyssis and Surrounding Context

414) The proposed develo pment site is within a south western corner of a large field with a proposed development area of approximately 0.65 ha. The site is greenfield and is located 0.4 km west of Cockermouth, the nearest settlement, with access via the A66 and Ellerbeck Brow, a local road. 415) The site is bounded to the south by a maintained hedgerow field boundary on Ellerbeck Brow and an overgro wn hedgerow with hedgerow trees to the west. The remaining two boundaries would be formed by the development and are currently open field. The site and surrounding a rea consists of open improved grassland. 416) Harrot Hill PS is located within La ndscape Character Landscape Character area of medium sensitivity. Papcastle is located to the north and has views towards the site. Cockermouth has some views partially filtered to the site. Design Evolution and Appearance

417) The pumping station is located at the optimum elevation to transfer flows further west into the network via the proposed Service Reservoir at High Leys. Further details are provided in Chapter 3 of the Envi ronmental Statement. The scale of t he pumping station and its layout are dictated by the equipment operationally needed to transfer the required volume of flow. 418) The details of the development have been dis cussed with officers from the local planning authority and their landscape advisers and h ave evolved through an iterative process. Alternative materials and building designs have been explored aided by visualisations from both distant and near views. 419) Key design features incorporated to mitigate the visual impact include:  The use of approprriate materials to match the local vernacular  The inclusion of a double ridge to the roof line  The cutting in to the hillside to reduce the overall building height  Incorporation of enhanced security to the building to remove the need for palisad e fencing  Enhanced landscaping to the boundary with the Ellerbeck Brow and the commitment to enhanced management of the existing field boundaries  The provision of a turning head within the site to avoid the need for an internal access road around the entire site.

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Access and Movement

420) Access for both construction and operational purposes would be off the Ellerbeck Brow Road. An internal access road and turning head would be provided for the purposes of operation and maintenance.

3.8 Summary 421) The appli cant has developed the scheme over a number of years and has invested a significant amount of resources into consulting and engaging with its c ustomers, the community, statutory bodies, landowners and businesses prior to this planning submission. From the inception of the proposed scheme it has been recognised that this was a major linear project within a sensitive rural setting and therefore it has been designed as sensitively as practicable to reflect the built and natural environment which surrounds it. The assessment of the proposed scheme provided in this PDAS has demonstrated that through the design and mitigation it meets the objectives of the Local Plan.

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4. Copeland Borough Council

4.1 Scheme Description 422) Development of a water supply connection from Thirlmere Reservoir to the area of West Cumbria comprising within Copeland Borough Council of:  A new service reservoir, valve house and pumping station with vehic ular access, fencing and landscaping adjacent to the existing service reservoir at High Leys, near Arlecdon  Underground pipelines running from Ullock to the proposed High Leys Service Reservoir and onto the existing service reservoirs at Kelton Fell and Summergrove. This would incorporate the development of valve chambers , excavation and landscaping, temporary vehicular accesses, working areas, compounds, hard standings and other associated development along the route.

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Table 4.1 – Copeland Scheme Sections

Section/Facility Development Description Location Description Associated Drawings (number and location)

Section 12 Network This section includes the laying of a new (800 mm)  The majority of the landscape in the area is large  Copeland Borough Council Main – Ullock to High network main pipeline from Ullock to a new service scale and undulating consisting of a series of ridges General Layout Leys Service Reservoir reservoir at High Leys. This pipe-laying would and valleys that rise gently towards the limestone B2707061/S2/CBC/1 - 4 largely be laid by open cut, though it would be laid fringes of the Lakeland Fells. The pipeline corridor using a directional drill construction technique continues in a south westerly direction, with the under Smithy Beck and Colliergate Beck. There A5086 to the east and the River Marron to the west would also be temporary accesses and  Continuing along the A5086 towards the village of contractors’ compound/lay down areas. Crossgates, the pipeline crosses Wood Beck to the west of the village before moving south west, away from the A5086, through open countryside towards the village of Asby, passing in close proximity to a Scheduled Monument located to the west of the pipeline route  The pipeline crosses Asby Road, entering open countryside again and crossing Smithy Beck and Colliergate Beck. The landscape consists of well managed regular shaped medium to large pasture fields. Hedge-bound pasture fields dominate the landscape, interspersed with native woodland, tree clumps and large scale conifer plantations  The corridor continues south west towards the village of Arlecdon and , crossing Pasture Road, and continues to the location of a proposed new service reservoir and pumping station, adjacent to the existing High Leys SR. Section 13 Network This section includes a new 400 mm pipeline, laid  From the site of the proposed High Leys SR/PS, the  Copeland Borough Council Main – High Leys by open cut, from the proposed High Leys Service Kelton Fell leg runs north east and then branches in General Layout Service Reservoir to Reservoir to the existing service reservoir at a south easterly direction approximately 400 m south B2707061/S2/CBC/4 and 9 - 10 the existing Kelton Fell Kelton Fell, along with temporary accesses and of Asby. Crossing the A5086 the pipeline continues

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Section/Facility Development Description Location Description Associated Drawings (number and location) Service Reservoir contractor compound/laydown areas. alongside a local road up Kelton Fell. To the west of the route is the disused Kelton Quarry. For the final kilometre or so the pipeline leaves the road corridor and ascends in a south easterly direction, finally entering Kelton Fell SR  The landscape is characterised by rural farmland comprising significant areas of improved pasture in regular shaped medium field patterns. Hedgerows are the predominant field boundary type, although they become less common and are replaced by drystone walls on the high ground towards Kelton Fell SR. The landscape typically becomes more rugged around Kelton Fell through the influence of the Lake District foothills. Section 14 –High Leys This section includes a new 50 Ml service  The proposed High Leys SR and PS is currently  Site Location Plan Service Reservoir and reservoir with pumping station. The development located approximately 1 km south west of Asby. The B2707061/S3/CBC/HL/01 Pumping Station would consist of a service reservoir located largely proposed development site comprises four linked  Floor Plan below re-contoured ground levels, agricultural fields with a total area of approximately B2707061/S3/CBC/HL/02 decommissioning of the existing service reservoir, 14.7 ha. One very large field would be divided into  Roof Plan removal of the existing security fencing, and two with a new boundary formed by extending an B2707061/S3/CBC/HL/03 installation of a new stock proof fencing around existing field boundary line.  Elevations part of the site.  The site comprises semi-improved pasture, and B2707061/S3/CBC/HL/04 A new permanent access of Pastures Road and a access is gained via the Pastures Road of the contractors’ compound would also be included. A5086, to the eastern boundary of the site. The area surrounding the site is elevated, open and predominately agricultural. Vegetation coverage is limited and confined to lower elevations along the watercourses Section 15 – Network This section includes a new (800 mm) pipeline  Leaving the proposed High Leys SR and PS site, the  Copeland Borough Council Main from High Leys from High Leys to the existing Summergrove pipeline continues south west and passes through General Layout Service Service Reservoir site. Arlecdon, crossing Arlecdon Road. The pipeline B2707061/S2/CBC/4 - 8

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Section/Facility Development Description Location Description Associated Drawings (number and location) Reservoir/Pumping There would also be temporary access and continues south west, with the A5086 again to the Station to the existing compound/laydown areas. south of route, through open countryside towards Summergrove Service and to the north of the village of Frizington, crossing Reservoir Lingla Beck. Beyond Frizington the pipeline crosses the road to Kirsgill How and the road to Frizington Hall before passing to the south of an area of Ancient Woodland, Jobbygill Wood  The landscape is characterised by well managed regular shaped medium to large pasture fields. Hedge bound pasture fields are the dominant type, interspersed with native woodland, tree clumps and large scale conifer plantations  The pipeline passes to the north of Rheda Park and crosses the River Keekle and crossing the B5295 north west of , the route finally runs west towards the existing Summergrove SR.

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4.2 Planning Applications along the Route 423) During the design of the scheme, United Utilities has liaised closely with Copeland Borough Council. Part of this process was the consideration of deve lopment proposals along the proposed route and the need to be as least disruptive to t hese as possible. In September 201 5, planning application information was requested from all local authorities affected by the scheme to identify potential land use impacts of the scheme, for developments submitted/approved within the last 5 years and within a 150 m buffer zone of the Proposed Sche me. The data were plotted on a GIS system and compared against the final planning application boundary. 424) Fifty one planning applications submitted in the last 5 years were found within the 150 m buffer. The followi ng planning permissions were directly affected by the scheme, either in terms of location of sensitive use:  4/10/20 66/0F1, Weddicar Hall, Cleator Moor - Application for new planning permission to replace an Exta nt permission 4/10/2066/0F1 – holiday Development)  4/13/2348/0FI, Erection of dwelling (retrospective)

4.3 Planning Policy Assessment

4.3.1 Planning Policy Context 425) The development plan for Copeland Borough Council comprises the Core Strategy and Development Management Policies DPD (adopted 5 December 2013). Copeland Borough Council will also continue to have regard to the remaining ‘saved’ policies from t he Copeland Local Plan 2001-2016 (2006) relating to specific areas of land (which will be reviewed in the Site Allocations and Policies Plan). 426) Copeland Borough Council is currently updating the remaining 2001-16 'saved' policies and published the Site Allocations and Policies Plan Preferred Options (January 2015) for consultation between 12 January and 20 March 2015. The council intends to consult on the revised document in early 2016. 427) Copeland Borough Council Core Strategy Policy ST2 – Spatial Development Strategy states that development outside the defined settlement boundary will be restricted to that which has a proven requirement for such a location, including infrastructure that requires locating outside settlement limits.

4.3.2 Allocations / Designations 428) The Proposed Scheme crosses the following allocations in the Copeland Local Plan 2001-2016:  Landscape of County Importance ( listed in the Core Strategy and Development Management Policies DPD as bei ng superseded by ENV5 Protecting and Enhanci ng the Borough’s Landscapes and DM26 Landscaping)  Tourism Opportunity Site (Ehen / Keekle Valleys) (listed in the Core Strategy and Development Management Policies DPD as b eing superseded by ER10 Renaissance through Tourism) 429) Policy ENV 5 states:

‘The Borough’s landscapes will be protected and enhanced by:

 Protecting all landscapes from inappropriate change by ensuring that developme nt does not threaten or detract from the distinctive characteristics of that particular area

 Where the benefits of the development outweigh the potential harm, ensuring that the impact of the development on the landscape is minimised through adequate mitigation, preferably on-site

 Supporting proposals which enhance the value of the Borough’s landscapes’ 430) Policy DM26 – Lands caping state s:

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Planning, Design and Access Statement

‘All development proposals will be assessed in terms of their potential impact on the landscape. Developers should re fer to the Cumbria Landscape Character Assessment and Cumbria Historic Landscape Characterisation documents for their particular character area and design their development to be congruent with that character.

The Council will continue to protect the areas designated as Landscapes of County Importance on the Proposals Map from inappropriate change until a more detailed Landscape Ch aracter Assessment can be completed for the Copeland plan area.

Proposals will be assessed according to whether the proposed structures and associated landscaping relate well in terms of visual impact, scale, character, amenity value and local distinctiveness and the cumulative impact of developments will be taken into account as part of this assessment.

Development proposals, where necessary, will be required to include landscaping schemes that retain existing landscape features, reinforce local landscape character and mitigate against any adverse visual impact. Care should be taken that landscaping schemes do not include invasive non-native species.

The Council will require landscaping schemes to be maintained for a minimum of five years.’ 431) Policy ER10 is supportive of appropriate tourism development which accords with the principle s of sustainable development within the Ehen / Keekle Valleys. 432) For Allerdale and Copeland, the adopted Cumbria County Council Minerals and Waste Core Strategy provide policies on safeguarding future minerals resources. As existing planning permissions for genera l crushed rock already provide for a land bank of at least fifteen years to be maintained throughout and beyond the plan period further permission for mineral extraction are not deemed to be required . The plan will not identify any Preferred Areas for new crush ed rock mineral extraction but only identify Mineral Safeguarding Areas to protect the crushed rock resources for future generations. 433) MSA’s are provided under Core Strategy Policy 14 and these relate to Sand and Gravel at scheme Sections 11, 16, 18, Limestone rock at scheme Sections 6, 7, 8, 9, 11, 13, 16 and shallow coal and fire clay at scheme Sections 11, 12, 14, 15). The soils, geology and Hydrogeology section of the ES has provided a detailed analysis of the impact on minerals deposits within the MSA and has concluded that the proposed schemes has minimal impacts on potential mineral deposits and does compromise the objectives of this policy. In addition, there are no operational mineral extraction activities or extant planning applications for workings within 250 m of the Proposed Scheme. Therefore it is considered that the proposed scheme would not impact on the MSA.

4.4 Planning Assessment 434) The analysis in the following section summarises the impact of the proposed scheme against the context and detailed planning policy objectives of the NPPF and the adopted Local Plan. This section is not intended to duplicate the ES and should be cross referenced with this document. 435) The Copeland Local Plan 2013-2028 Core Strategy and Development Plan Polices DPD (the Local Plan) provides the land use policies relevant to assessing planning applicatio ns. An overriding policy which is particularl y relevant is Policy ST1 Strategic Development Principles which sets four key objectives which underpin the Local Plan which are economic and social sustainability, environmental sustainability, protect enhance a nd restore the Borough’s valued assets and ensure the creation and retention of quality places. Policy ST4 emphasises the importance of utility capacity and infrastructure through point d which expects ‘utility and other infrastructure providers to rectify as soon as possible any network shortcomings which risk preventing or delaying development’. 436) Key objectives of the planning system under Paragraph 109 of the NP PF is that it should ‘contribute to and enhance the natural and local environment by minimising impacts on biodiversity and preventing development from contributing to unacceptable water pollution’. In addition, national policy regarding flood r isk is set out in section 10 of the NPPF, Meeting the Challenge of Climate

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Change, Flooding and Coastal Change. Paragraph 94 requires LPAs to adopt proactive strategies to mitigate and adapt to c limate change, taking full account of flood risk. Paragraph 99 states that: new development should be planned to avoid increased vulnerability to the impacts arising from climate change. 437) Also of significance to the Proposed Scheme is NPPF paragraph 12 concerning the conservati on of the historic environment. The NPPF recognises that heritage assets are an irreplaceable resource that should be conserved in a manner appropriate to their significance. Significance is defined by the NPPF as ‘the value of a heritage asset to this and future generations because of its heritage interest’. This significance may be related to archaeological, architectural and artistic or historic elements, and may also derive from the setting of the site (Paragraph 56).

4.4.1 Landscape and Visual Assessment

Planning Policy 438) Paragrap h 17 (General Planning Principles) of the NPPF states that all development should seek to secure high quality design a good standard of amenity for all existing and future occupants of land and buildings and response for the character and beauty of the countryside. NPPF Paragraphs 58 and 109 state that planning decisio ns should aim to ensure good design and landscaping, whilst protecting and enhanci ng the natural environment. 439) Relevant policies from the Local Plan include Policy ST1 – Strategic Development Principles, which seeks to protect and enhance landscapes and Policy ENV5 – Protecting and Enhancing the Borough’s Landscapes , which protects landscapes from inappropriate c hange by ‘ensuring development does not detract from its characteristics, requires any potential harm on the landscape to be outweighed by the benefits of development and that impacts of development are minimised through adequate mitigation, preferably onsite’. 440) In addition, Policy DM10 – Achieving Quality of Place requ ires development to respond positively to the character of the site and the immediate a nd wider setting and enhance local distinctiveness. Of particularly relevance to the Proposed Scheme is Policy DM26 – Landscaping, which requires developers to refer to the Cumbria Landscape Character Assessment and Cumbria Historic Landscape Characterisation documents and ‘Proposals will be assessed according to whether the proposed structures and associated landscaping relate well in terms of visual impact, scale, character, amenity value and local distinctiveness and the cumulative impact of developments will be taken into account as part of this assessment’.

Assessment against Pllaanning Policcy 441) Chapter 7 of the accompanying ES provides a summary of the Landscape and Vis ual Impact Assessment (LVIA) which has been undertaken to evaluate the effects of the proposed scheme is Copeland. 442) Copeland is characterised mainly by a large-scale undulating landscape consisting of a series of ridges and valleys that rise gently toward the fringes of the Lakeland Fells. A short section falls within an urban fringe landscape. The landscape consists of well managed regular shaped medi um to large pasture fields. Hedge bound pasture fields dominate, interspersed with native woodland, tree clumps and large scale conifer plantations. 443) Cleator Moor is the main urban settlement within the study area. Settlement patterns within the surrounding area include the dispersed villages of Asby, Arl ecdon, Rowrah and Kirk land. Small rural settlements occur throughout the area including scattered farms and a number of dispersed residential properties, some as clusters of properties. 444) Effects on landscape character would mainly occur during the construction phases from the loss of hedgerows, hedgerow trees and the influence of construction activities of the pipelin e and High Leys Service Reservoir within a typically rural and relatively tranquil landscape. 445) Effects on landscape character resulting from the pipeline installation would still be present during the first year after cons truction as the hedgerows, trees and vegetation establishes but by five years after operation it would be barely noticeable. By year 15 after construct ion the impa cts would have reduced to a point whe re they are barely noticeable.

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446) The Service Reservoir would introduce a more prevalent feature into the landscape. This would impact on the landscape at the first operational year after construction as there would continue to be a reduction in tranquillity and loss of sense of place and rural character due to the presence of the new built form and the temporary loss of hedge rows while these re-establish. Once reinstated vegetation re-establishes, and other existing vegetation is strengthened , the initial impacts would reduce significantly over time so that by Year 15 it would be much less noticeable. 447) Effects on visual receptors due to the scheme would vary according to the location of the receptor, the type of development being viewed, the temporary or permanent nature of the development and characteristics of the existing view. In general, effects during the construction period would be most significant due to construction activ ity for the Network Water Main and High Leys Service Reservoir reducing visual amenity and changing views from visual receptors. 448) On completion of construction, effects would reduce as construction activity ceases. Effects in the first year after development for the vast majority of receptors would reduce but over time the establishm ent of re-instated hedgerows and trees along the Network Water Main alignment wou ld reduce the effects further in the medium term. 449) Measures have been incorporated into its design to reduce visual impact. Overall it is recognised that the nature of the P roposed Scheme being a major infrastructure project in a rural landscape would have some effects on landscape character but the proposals have been designed to mitigate these as far as possible through sit ing, design and mitigatio n. With the inclusion of these measures, the Proposed Scheme is in accordance with pa ragraphs 17, 58 and 109 of the NPPF and the requirements of Local Plan Policies ENV5 and DM26.

4.4.2 Arboriculture

Planning Policy 450) The national objective relating to arboriculture is set out in Paragraph 118 of the NPPF, which states:

‘planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss’. 451) Relevant from the Local Plan is Policy DM26 – Landscaping, which requires for development proposals which are lik ely to affect any trees in the borough to submit proposals for the replacement or relocation of any trees removed, with net provision at a minimum ration of 2:1, wi th a preference for the repl acement of trees on site and with native species. . Policy DM28 – The protection of trees is particularly relevant as this sets out the detail ed requirements to justify any trees which are proposed t o be removed and in particular those in a Conservation Area, covered by a TPO, veteran trees or an cient woodland. Any removal of trees in these circumstances must be jus tified by a full assessment of the impact on amen ity and a sta tement of why the benefits of the development outweigh the harm. Where tree removal is proposed compe nsatory planting is required at a ratio of at least 2:1 .

Assessment against Pllaanning Policcy 452) Whilst the routeing has tried to avoid direct im pacts on trees this has not always been possible. Impacts would occur during construction through temporary or permane nt land take associated with the pipeline, temporary construction compounds and car parks, mobilisation sites and temporary access routes. 453) As report ed in the ES , the required working width of the pi peline during construction is generally 40 m. At locations where environmental constraints are encountered within the working width, it may be possible to reduce the working width over short distances to minimise impacts on these constraints (for example, at hedgerows or watercourse crossings where the working width may be reduced to approximately 20 m). Similarly, contractors may be able to realign the pi peline away from the centre line of the construction corridor to avoid particular constraints. In the case of arboricultu ral constraints, for example, this may mean that tree root protection areas falling withi n the

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working width may be avoidable. The Environmental Masterplan presented in the E S indicates where tree root protect ion areas within the working width may be avoidable through appropriate construction managem ent. 454) Trees which have protection under the Planning Acts are those with Tree Preservation Orders or which are within a Conservation Area. In addition, the NPPF protects ancient woodl ands and veteran trees from development unless the development clearly outweighs the loss. There is a TPO at Summergrove. It is not anticipated that this would be directly affected. There are no Conservation Areas within the Copeland section of the scheme. 455) Apart from trees which are afforded special protection under the Planning Acts, trees and other vegetation are classified according to their qual ity and remaining life. The highest quality trees are grade A and the poorest quality grade C, whilst some trees are unclassified. For Copeland, the approximate number and grade of trees or hedgerows affected are set out in table 4.4 below (this does not indicate the actual numbe r of trees to be lost as it is still being determined which trees can be maintained):

Table 4.4 – Trees, Groups of Trees, Hedgerows and Woodlan ds Surveyed within Copeland GRADE CATEGORY TOTALS A B C U TREES 5 58 23 6 92 GROUPS 0 26 16 0 42 HEDGES 0 29 53 0 82 WOODLANDS 0 0 0 0 0 TOTALS 5 113 92 6 216 456) One of the trees identified above is a veteran tree. Veteran trees are trees which, due to their age, size or condition, are of cultural, historical, landscape or nature conservation value. 457) Where trees or hedgerows need to be removed the aim is to reinstate them at the same location or as near as practicable. However, as tree planti ng would be restricted over the perm anent easement this would lead to a net loss in trees. Compensatory planting would plant new trees at a greater ratio to those which are lost. A location in the Ennerdale Valley has been identified by the applicant as an area for replacement planting and t ree planting would also be supported through the provision of a community grant fund under which local groups would be el igible to apply for monies to support local tree planting initiatives. Section 5 of this statement provides more detail of the compensatory planting. 458) It is also important to avoid physical damage to trees whic h remain in situ including damage to their roots. Other mitigation measures in clude fencin g prescribed to British Standard BS5837:2012 and exclusion zones around the Root Protection Zones.

The loss of trees is one of the more significant impacts of the scheme but the applicant has recognised this and proposes a scheme of com pensatory planting. This planting would meet the requirement of Policy DM28.

4.4.3 Water Enviro nment

Planning Policy 459) Paragrap h 109 of the NPPF states that the planning system should ‘contribute to and enhance the natural and local environment by minimising impacts on biodiversity and preventing development from contributing to unacceptable water pollution’. 460) Relevant from the Local Plan is Policy ST1 – Strategic Development Principles, which seeks to protect and enhance the Borough’s valued assets by requiring development to minimise water pollution.

Assessment against Pllaanning Policcy

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461) Potential impacts are associated with pipeline construction, construction and operation of the new water work treatment works, service reservoirs and any operational changes which may result in changes to water resources. In Copeland the impact of the scheme on water resources has been assessed as having a beneficial effect. 462) A series of standard mitigation measures have been proposed to help manage pollution risk and reduce the impacts of the construction of the Proposed Scheme on the water environment. These mitigation measures include good construction practice (as defined in a Construction Code of Practice (CCoP) and adherence to the Environment Agency’s guidance on Pollution Prevention Guidelines (PPG), appropriate scheme design, oversight of works and environmental monitoring during construction (where required). 463) The highest potential impact on the water env ironment from construction activities is close to watercourses or associated with river/stream crossings. In addition to the standard mitigation measures listed above, additional mitigation has been proposed including the selection of appropriate river crossing techniques and access methods based on river specific characteristics. A land drainage strategy and water quality management strategy have also been developed. Overa ll it is considered that the scheme meets the objective of the NPPF and the Local Plan Policy ST1.

4.4.4 Flood Risk

Planning Policy 464) Paragrap hs 100, 101 and 102 of the NPPF set out the need for the ap plication of the Sequential Test to steer new development to areas with the lowest probability of flooding and if necessary, the Exception Test for the development to be located in zones with a lower probability of flooding. Further detailed guidance on flood risk is set out in the Technical Guidance to the National Planning Policy Framework (2012). 465) Relevant policies from the Local Plan include Policy ST1 – Strategic Development Principles, which directs development towards sites that are at least risk from flooding and whe re development in areas of flood risk is unavoidable, ensure that the risk is minimised or mitigated through appropriate design and Policy ENV1 – Flood Risk and Risk Management, which seeks to ensure that development in the Borough is not prejudic ed by flood risk. In additi on Policy DM24 – Development Proposals and Flood Risk prohibits developm ent that will cause an unacceptable risk of flooding or increase the risk of flooding elsewhere, or would cause interference with or loss of access to a watercourse.

Assessment against Pllaanning Policcy 466) To comply with both the National Planning Policy Framework for flood risk and the Local Plan, a Flood Risk Assessment (FRA) has been produced and is provided in Chapter 10 of the ES. The FRA reports address both the potential risk posed by the scheme to increasing flood risk in the local area, while also examining the potential risks posed by flood events upon construction operations and the operational infrastructure. 467) For Copeland Borough Council the FRA has identified the potential for groundwater flooding at the High Leys Service Reservoir and P umping Stat ion and washout chambers associated with the Network M ains from Ul lock to Summergrove an d Kelton Fel l are located in Flood Zone 3 so the Sequential Test must be applied. The two mains could also impact on surface water flooding if surface water runoff as a result of the development increased. 468) The FRA has completed the Sequential Test for High Leys and has concluded that development cannot be located elsewhere. In addition, the development is water compatible and is designed to be resilient to flooding should this occur. For example, all s ub-surface elements at High Leys would require flood proofing to prevent water ingress and withstan d the hydraulic pressures associated with rising groundwater levels. Any above ground elements at High Leys that could be v ulnerable to water ingress, such as those items containing electrical equipment, would need to be raised so they avoid potential flood levels. Other mitigation would ensure that any increase in surface water runoff would be attenuated on site unless the impact can be deemed negligible in agreement with the LPA and Enviro nment Agency.

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469) The implementation of these measures means the risk from flooding during its operational period is considered to be low. In addition, t he impact of the proposed scheme o n flood risk elsewhere is not considered to result in any significant, adverse effects. Any flood risks associated with the failure of individual assets and infrastructure is low and extremely unlikely as structures such as Service Reservoirs are subject to rigorous maintenance and inspection regimes. 470) The Proposed Scheme is therefore considered to be in ac cordance with NPPF paragraphs 100, 101, 102 a nd 109, and Local Plan policy DM24.

4.4.5 Ecology and Nature Con servation

Planning Policy 471) Paragrap h 118 of the NPPF lists a number of principles to ensure that biodiversity is conserved and enhan ced and that any development that detrimentally affects or causes loss to local ecology should have benefits that clearly outweigh these impacts. Of particular importance i s that ‘if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused ’. 472) Relevant policies from the Local Plan are Policy ST1 – St rategic Development Principles, which seeks to protect, and enhance the borough’s valued assets by requiring development to minimis e water pollution and Policy ENV3 – Biodiversity and Geodiversity, which aims to contribute to the implementation of UK and Cumbria Biodiversity Action Plan s by improving the condition of designated sites and ensuring that development incorporates measures to protect and enhance any biodiversity interest. 473) In addition Policy DM25 – Protecting Nature Conservation Sites, Habitats and Species, which seeks to maximise opp ortunities for conservation, restoration, enhancement and connection of natural habitats for species listed in UK and Cumbria Biodiversity Action Plans. The policy also prohibits development that would cause an adverse effect on locally rec ognised sites of biodiversity and geodiversity importance or protected species unless the benefits of the development outwei gh the impact and prevention, mitigation and compensation measures are i mplemented. 474) The Biodiversity 2020 strategy’s mission is to ‘halt overall biodiversity loss’ and ‘retain the protection and improvement of the natural environment as core objectives of the planning system.”

Assessment against Pllaanning Policcy 475) It is considered that c onstruction activities could cause habitat loss (both permanent and temporary), habitat fragmentation, habitat degradation or physical damage, pollution, introduction of invasive species, disturbance to species or hab itats, direct injury/mortali ty to species, and hydrological changes through ground disturbance, all of which have the potential to adversely impact most of the ecological receptors. 476) A series of generic m itigation measures has been proposed to help reduce the impacts of the construction of the Proposed Scheme. These mitigation measures include targeted pre-construction surveys undertaken by an experienced ecologist to ensure previous data are still relevant, overs ight of ecologically sensitive works by a n Ecological Clerk of Works, temporary fencing to avoid incursion into sensitive adjacent habitats, implementation of the Environment Age ncy’s Pollution Prevention Guidelines and United Utilities’ Biosecurity Policy, and adherence to industry-stand ard environm ental safeguards (as detailed in the CCoP). 477) In addition, works are recommended to be undertaken outside of key migrating, breeding and/or hibernation seasons (e.g. for red squirrels, birds, bats and salmonid fish) and not during the night time near sensitive habitats and species (e.g. for bats, otters and salmonid fish). Wherever possible, all habitats would be restored to pre-construction conditions with elements of enhancement included (e.g. for birds, bats, red squirrels and reptiles). 478) With the mitigation above and as detailed in the ecology technical appendices of the ES, residual effects of the construction phase are expected to be not significant for Great Crested Newts and other amphibians, reptiles, and specific bird. For other receptors, there is potential for residual impacts in the short to medium term for designated sites, other notable habitats, bats, otter, red squirrel, other bird receptors and aquatic ecology receptors, although the long term effects would 82

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also be not significant. However, the loss of woodland scheme wide would be offset by compensatory woodland planting which is a strategic mitigation measure for the whole scheme in the Ennerdale Valley (see Section 5.) 479) The mitigation and compensation to be incorp orated into t he Proposed Scheme all contribute to preserving and enhancing biodiversity and it is considered t o be compliant with Paragraph 118 of the NPPF and Policies ST1, ENV3 and DM25 of the Local Plan.

4.4.6 Cultural Heritage

Planning Policy 480) Under Paragraph 128 of the NPPF, applicants for planning permission are required to provide a description of the significance of any affected heritage assets and their settings in sufficient detail to understand the potential impact of the proposal on them. In making planning decisions, great weight is to be given to the preservation of designated heritage assets. 481) Paragrap h 132 of the NPPF states that where development would lead to substantial harm or total loss of significance, local planning authorities are instructed that they should refuse consent, unless it can be demonstrated that it is necessary to achieve subst antial public benefits that outweigh that harm or loss. 482) Relevant policies from the Local Plan are Policy ST1 – Strategic Development Principles, which aims to protect and enhance the Borough’s cultural and historic features and their settings, Policy ENV4 – Heritage Assets, which protects features considered to be of historic, archaeological or cultural val ue and Policy DM27 – Built Heritage and Archaeology, which seeks to protect the historic, cultural and architectural character of the Borough’s historic sites, and prohibits development that would have a significant adverse effect on a Scheduled Ancient M onument or its wider site or setting. Development should not have a significant adverse effect on the setting or important views of the building and not cause u nacceptable impact up on a site of archaeological importance.

Assessment against Pllaanning Policcy 483) Construction activities associated with the proj ect would potentially physically impact on known buried archaeological remains and historic landscape types . The majority of the assets in the south section of the Network Main are of negligible or low value and therefore potential impacts are limited. Only a small number have potential adverse im pacts where elements integral to the understandi ng of the asset may be removed. The construction activities could also impact on built heritage thro ugh adverse visual impact on the setting of undesignated histori c buildings and on the setting of a Scheduled Monument but the majority of the immpacts would be temporary and limited to the construction phase only. These include the setting of the Church of St Brides, St Br idget’s Church and Outbuildings at Kirkland Gate. This would only be temp orary and would not have long-term effect on the monuments. 484) There are no potential adverse impacts on setting of heritage during the operation phase as a result of new elements of above-ground infrastructure. 485) Measures to reduce potential impacts on the historic environment have been incor porated into the design throughout its development to avoid and preserve heritage assets. This has been done in consultation with heritage stakeholders. Agreed mitigation comprises set-piece excavation, topographic survey, watching brief, photographic survey and landscape planting/reinstatement. 486) The project is compliant with the policies of NPPF as no substantial harm has been assessed on designated heritage assets during the operation of the project. It is also in accordance with Policies ENV 4 and DM27 in that potential impacts on the setting of heritage assets are add ressed to prevent ha rm to any positive qualities of the heritage asset.

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4.4.7 Soils, Geology and Hydr ogeology

Planning Policy 487) The overriding national objective at Paragraph 109 of the NPPF is that ‘the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, geological conservation interests and soils, preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.” 488) Relevant policies from the Local Plan are Policy ST1 – St rategic Development Principles, which requires development to minimise ground pollution and for new development to address land contamination with appropriate remediation measures and Policy ENV3 – Biodiversity and Geodiversity, which seeks to improve the condition of designated sites. I 489) In addition, Policy DM11 – Sustainable Devel opment Standards requires surface water to be managed appropriately and Policy DM25 – Protecting Nature Conservation Sites, Habitats and Species, which prohibits development that would have an a dverse impact upon locally recognised sites of geodiversity im portance, including Regionally Important Geologi cal/Geomorphological Sites, unless the benefits outweigh the impacts of the development, and mitigation measures are included.

Assessment against Pllaanning Policcy 490) Issues to be considered are the presence of potentially contaminated l and, whether any changes to base flows in river streams would occur, protecting bedrock and second ary aquifers from groundwater pollution and avoiding buildings and infrastructure subsidence as a res ult of dewatering. 491) Measures to reduce potential impacts include managing groundwater drainage, avoiding impacts on protected and value d geological sites through routing the pipeline an d associated infrastructure to avoid sens itive sites and reducing t he risks of encountering contaminated land through routing decisions where this has been possible. Where preliminary risk assessments have identified that contaminated land rem ains as a possibility, further ground investigations would be c arried out prior to any development taking place. 492) The risk of pollution to soils and g roundwater and other harmful changes to the hydrogeological environment would be reduced through the application of the plans and principles set out in the CCoP, Construction Strategies and Management Plans presented in the ES, the Material Management Plan and Environment Agency PPGs. Implementation of a soil management plan and good remediation practice would be followed by backfilling pipe trenches with material providing a similar permeability to the natural in-situ deposits. 493) Chapter 13 of the ES demonstrates that risks have been mitigated as far as possible and are mainly limited to the construction phase only. The impleme ntation of the proposed mitigation measures would minimise impacts in accordance with the NPPF objectives and Poli cies ST1, ENV3, DM11 and DM25 of the Local Plan.

4.4.8 Materials and Waste

Planning Policy 494) National policy relatin g to waste is contained in National P lanning Policy for Waste (October 2014). It highlights the need for delivery of sustainable development and resource efficiency by driving waste management up the waste hierarchy. 495) Paragrap h 8 requires the implementation of the waste hierarchy; that the development makes sufficient provision for waste management and the handling of waste arising from the construction and operation of development maximises reuse/recovery opportunities. Overall development should minimise the need for off-site disposal. 496) Relevant policies from the Local Plan are Policy ST1 – St rategic Development Principles, which requires tha t new development minimises waste and maximises opportunities for recycling and Policy DM11 – Sustainable Development Standards, which encourages construction materials to be sourced from local and sustainable sources of production.

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497) Relevant from the Cumbria County Council Core Strategy (2009) include Objective 2, which aims for effective waste mini misation measures to be adopted and managed at the highest achievable level within the waste hierarchy and the Waste SStrategy, which states that by 2020: ‘waste will be managed near to where it is produced, as far as practicable bearing in mind Cumbria's relatively small and dispersed pattern of population’.

Assessment against Pllaanning Policcy 498) Early scheme designs involved route optimisation for the best overall solution which included avoiding waterlogged and soft ground where possible and potential sources of ground contamination so that excavated soil materials would be more readily re-usable or recyclable. In addition, materials use would be reduced by minimising pipeline le ngths where possible an d successfully optimising the length of gravity fed pipeline to reduce the need for pumps and associated materials / product use. 499) United Utilities would optimise the reuse of ex cavated material on-site within the scheme and current predictions indicate this is approximately 82.5 % although this rate could be exceeded further. Contractors would be requi red develop a Site Waste Management Plan (SWMP) for construction contracts and engage with compet ent waste management and recycling sub­ contractors to ensure that waste is managed in accordance with the waste hierarchy. 500) During operation, there would be no significant change in materials use or waste generated during operation and maintenance. 501) Overall the positive measures to reduce the amount of materials used to construct pipes, the high level of re-use of excavated material and other waste minimisation and segregation measures make a significant contribution to reducing the resource implications of the project in line with the Waste Hierarchy and Local Plan policies ST1 and DM11.

4.4.9 Public Access and Recreation

Planning Policy 502) NPPF paragraphs 73 and 74 state the importance of high quality open spaces and opportunities for recreation in contributing to the health and well-being of communities and prohibit the loss of open space and recreational land. Parag raph 75 seeks to protect and enhance public rights of way and access and states that local authorities should seek opportunities to provide better facilities for users. 503) Relevant policies from the Local Plan are Policy ST1 – St rategic Development Principles, which requires development to accommodate traffic and access arrangements in ways that make it safe and convenient for ped estrians and cyclists and Policy SS5 – Provision and Access to Open Space and Green Infrastructure, which protects against the loss of designated open space and access routes. Als o relevant is Policy ENV6 – Access to the Countryside, which seeks to ensure access to the countryside for residents and visitors 504) The Cum bria Countryside Access Strategy 2014 to 2019 also provides the strategic framework for the management and improvement of countrysi de access and recreation in Cumbria (including the Lake Distric t National Park). One of four strategic aims of the document is to: ‘Provide high quality, well maintained access to the countr yside including the pub lic rights of way network, open access land, access to water and other means which meets the needs of its users’.

Assessment against Pllaanning Policcy 505) Chapter 16 of the ES assesses the effects on public access taking into account changes in accessibility to Public Rights of Ways (PRoWs) and change s in the amenity (pleasantness) experienced by walkers, cyclists and equestrians. PRoWs refers to public footpaths, bridleways, permissive routes, railway paths, National Cycle Networks (NCNs), cycle routes and open access land. 506) Five PRoWs within Copeland would be crossed by the working width. Where it is technically possible and safe to do so, wicket gates would be installed in the temporary working area demarcation fence line to allow the public continued access across the working widt h. For the safety of the general public three P RoWs would need to be closed for a short duration at the time of the pipe laying in the vicinity of the PRoW.

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507) In addition, access to Cumbria Kart Racing and Summergrove Hall (Woodland) would be directly affected so a traffic management system would be implemented to maintain access. 508) The majority of impacts on public access and recreation would be minor. Detailed discussions would be held with PRoW officers, local cycling groups and the managers/owners of the facilities that are affecte d in order to discuss and agree the temporary closures and d iversions. The applicant would require the contractor to work in consultation with all parties to limit disruption during construction and Rights of Way would be reinstated and ‘made-good’ following construction. 509) Whilst a scheme of this scale and complexity inevitably has some implications for the Rights of Way Network these are mainly limited to the construction period and are temporary in nature. It is considered that the scheme is consistent with the Local Plan objectives and the Cumbria Countrysid e Access Strategy to maintain public access to the PRoW network.

4.4.10 Socio Economics

Planning Policy 510) The NPP F sets out twelve core land-use principles that should underpin decision taking and decision making; these include the principle that planning should “proac tively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs”. 511) Section 1 of the NPPF ‘Building a strong, competitive economy’ highlights that the Government is committed to securing economic growth in order to create jobs and prosperity, buildi ng on the country’s inherent strengths, and meeting the twin challenges of global competition and of a low carbon future. NPPF Paragraph 19 states that:

“The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning ssystem.” 512) Section 3 of the NPPF ‘Supporting a prosperous rural economy’ states that ‘planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable development’. To promote a strong rural economy, planning should support sustainable growth and expansion of all types of rural business, promote the development of agriculture, support sustainable tourism and promote the retention of local services and community facilities. 513) Relevant policies from the Local Plan are Policy SS5 - Provision and Access to Open Space and Green Infrastructure, which states that adequate provision and access to open spac e will be promoted by measures including protecting against the loss of designated open spa ce. In addition, policy ENV6 – Access to the Count ryside states the council will ensure access to the countryside for residents and visitors.

Assessment against Pllaanning Policcy 514) Potential impacts that have been considered within the social and economic chapter of the ES include those on local employment (directly and indirectly), effects on tourism includ ing the availability of visitor accommodation, maintaining access to community facilities and social infrastructure and disruption from severance. 515) Only one minor effect has been identified in the ES for Copeland due to temporary land take. Subject to planning, the applicant would continue to work closely with the local communities and individuals to minimise disruption. Further detai ls of consultation to date are summarised later in this section and within the accompanying SCI.

4.4.11 Agriculture and Sporting Land Use

Planning Policy 516) Paragrap h 112 of the NPPF states that local planning authorities should:

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“take into account the economic and other benefits of the best and most versatile (BMV) agricultural land. Where significant development of agricultural land is demonstrat ed to be necessary, local planning authorities should seek to use areas of poorrer quality land in preference to that of a higher quality.” 517) BMV land is defined i n the Glossary at Annex 2 to the NPPF as land in grades 1, 2 and 3a of the Agricultural Land Classification (ALC). 518) Relevant from the Local Plan is Policy ST1 – Strategic Development Principles, which states that the council will manage developme nt pressures to protect the Borough’s agricultural assets.

Assessment against Pllaanning Policcy Objectives 519) Chapter 17 of the accompanying ES considers the potenti al effects of the proposed scheme on soils, agriculture and sporting interests. It details the effects of the cons truction and operation of the proposed scheme on a griculture and sporting land use the soils and land uses within the application boundary and, in particular, on agricultural and related activities as this is the predominant land use. 520) Construction of the pi pelines would require access for plant, vehicles and operatives in a temporary working co rridor of up to 40 m in wi dth. Within this corridor a smaller area would be subject to direct soil stripping and excavation works necessary to lay the pip e work and associated fittings. Construction of the Hig h Leys servi ce reservoir and pumping station alo ng with the fittings on the pipe work would result in permanent land-take. 521) The effects on soils and protection of their agricultural land capability is closely related to the procedures for stripping, storing and reinstatemment of soils in all areas where the works are temporary and land is being returned to agriculture. A Soil Management Strategy and Drainage Strategy would ensure best practice measures are employed and the sustainability of soils and their agricultural land capability is protected. 522) The appli cation boundary has been developed in consultation with land owners and agricultural and sporting interests. Within Copeland Borough Council, four agricultural and sporting interests would experience some adverse impacts during the construction phase. 523) Mitigation has been d eveloped to avoid or reduce construction and operational effects on agricultural and sporting activity. The Code of Practice for Pipe Laying would be followed and specific mitigation measures would include provision of alternative access, reinstate ment of boundary features and reinstatement of land drainage systems. 524) Agricultural land is classified according to its quality and versatility with 1 been the best and 5 the poorest (grade 3 is sub-divided into categories 3a and 3b). Grades 1, 2 and 3a are classified as the best and most versatile land (BMV). 525) Based on the ALC Strategic Map information available to Natural England, ALC surveys already undertaken and Soil Association data, it is considered likely that up to 20% of the land would be classified as BMV land, (assumed to be Grade 3a as no Grade 1 or Grade 2 land is already graded as such within the stud y area). 526) Whilst the applicant has taken all reasonable steps to avoid impacts, some limited residual impacts are unavoidable in a scheme of this scale and complexity. The applicant would work closely with all affected parties to minimise disturbance, disrup tion or any long term impacts.

4.4.12 Traffic and Transport

Planning Policy 527) Paragrap h 29 of the NPPF states:

“Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives. The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas.” 87

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528) Paragrap h 32 of the NPPF requires all development that generates significant amounts of movement to be supported by a Transport Statement or Transport Assessment. 529) Relevant policies from the Local Plan are Policy ST1 – St rategic Development Principles, which requires development to accommodate traffic and access arrangements in ways that make it safe and convenient for ped estrians and cyclists to move around and Policy DM22 – Accessible Developments, which requires the layout of the development responds positively to existing movement patterns in the area.

Assessment against Pllaanning Policcy Objectives 530) Chapter 18 of the accompanying ES includes an assessment of Traffic and Transport impacts on the local and strategic highway networks that would carry traffic to and from the compound and laydown areas associated with pipe laying during the construction period. The method of assessment has been agreed through discussions with the two incumbent highway authorities; namely Cu mbria County Council and Highways England. 531) The assessment of traffic impact considers a representative constructi on period, namely that which reflects concurrent construction at various points on the Network and Raw Water Aqueduct schemes. It takes into account all materials brought into the site for the purposes of construction, as well as that removed as waste. Assumptions have been made based upon likely ori gins of materials and destination of waste, relative to the location of construction during May 2018. Vehicle Routeings have been defined by t he major strategic corridors that provide east-west access to West Cumbria. 532) Baseline traffic counts were obtained at 27 junctions around the West Cumbria hig hway network, encompassing a 24 hour period wit hin May 2015. A spreadsheet model was produced to assess the impacts of construction traffic against backgrou nd flows, relative to the thresholds prescribed within the Institute of Environmental Management and Assessment (IEMA) Guidance on assessment of traffic environmental impacts. In Copeland, thresholds were only exceeded at one location during the construction period (either 10 % HGV’s or 30 % total traffic) at Pasture Road to the north of Rowrah at Section 14 ( High Leys S ervice Rese rvoir and Pumping Station). 533) Due to the presence of frontage property and low background traffic flows, a relatively small increase in HGV traffic may create a perception of impact amongst local residents. Notwithstanding the above, the assessment in the ES has concluded that impacts would generally be slight when reviewed against the key indicators of severance, pedestria n delay / am enity as prescribed by the IEMA guidance. Large r volumes of traffic associated with construction are generally present where traffic is already high, therefore the overall growth is identified as minimal.

4.4.13 Noise and Vibration

Planning Policy 534) Paragrap h 109 of the NPPF highlights the need to prevent developme nt from contributing to unacceptable levels of noise pollution. 535) Paragrap h 123 of the NPPF discusses the need to avoid noise from giving rise to significant adverse impacts on health and quality of life, m itigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development and recognise that development would create some noise. 536) Relevant from the Local Plan is Policy DM10 – Achieving Quality of Place, which requires development to create and maintain reasonable standards of amenity.

Assessment against Pllaanning Policcy 537) Whilst elevated construction noise levels are predicted for many sensitive receptors close to the route of the open cut works, the works would generally pass quickly through a given area and would therefore be short-lived. If rock is encountered, notably higher noise levels would be expected during rock breaking activities. Good practice guidance would be followed, but there may be some locations, particularly where rock is encountered, that would require further noise mitigation to reduce noise impacts at nearby sensitive receptors. The ES chapter highlights thos e sensitive

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receptors most likely to experience significant noise impacts and suggests appropriate mitigation measures that may need to be employed. 538) Construction activities taking place at the temporary laydown areas that are selected to also function as temporary site compounds along the Network section of the route, most notably the establishm ent of the site compounds, have the potential to cause signifi cant adverse airborne noise impacts at the nearest noise sensitive receptors. Table 19.2 within the ES presents the separation distances between sensitive receptors and laydown (potential site compound) areas within Copeland BC, highlighting those receptors most susceptible to adverse impacts during construction of the site compounds. 539) It is anticipated that minor road crossings would be undertaken using open cut techniques over a 1­ 2 week period. Again, whilst elevated noise levels may be experienced, they are likely to be of short duration. However, there are some areas where more major works along existing roads would be required, taking place over a longer period. Noise impacts at sensitive receptors close to these road/pipeline crossing points would be of longer duration and as such there is a greater potential for prolonged adverse effects. 540) Ground compaction would be undertaken along haul routes, at crane pads, at site compounds and during tren ch backfilling. As such, adverse ground-borne vibration impacts during compaction may arise at nearby sensitive receptors. Vibration p redictions during compaction have demonstrated that adverse impacts may be experienced at distances up to 55 m from such activities. Suitable mitigation, including informing affected resident s, would be implemented, as appropriate. Vibratory compaction techniques should not be used within 11 m of nearby sensitive receptors to protect against potential building damage. 541) There is potential for elevated construction noise levels over an extended period of time at the new High Leys SR and PS. Construction noise has been evaluated at this location. Noise calculatio ns suggest that with the adoption of appropriate noise control measures and managem ent practices, to be designed and adopted in consultation with the local authority, would avoid noise thresholds from being exceeded. 542) Analysis undertaken has shown that three roads would ex perience perceptible increases in road traffic noise level as a result of additional construction vehicles associated with the proposed scheme, Pasture Road, Mill Street and the B52 94 Bowthorn Road/ Road. These increases in noise wou ld be just about perceptible to local residents and are considered to be temporary adverse construction noise impacts associated with the sche me. 543) High Leys SR and PS are proposed to be built in a rural area north east of Frizington. The proposed SR and PS are located off Pasture Road, Frizingt on. The SR would emit very little or no noise in its operational state. The PS consists of a concrete building (600 mm wall thickness) to house pumps, compressors, a surge vessel, pipework and control systems. There would be no louvres or other openings except for double skinned security doors. Initial noise calculations have been carried out taking into account the likely noise generated by the proposed pumps and compressor within the concrete structure. These initial calculations indicate that the noise level at the nearest sensitive receptors, as a result of the H igh Leys PS , would be very low and imperceptible. It is therefore considered that adverse impacts are very unlikely at the nearest sensitive receptor locations to the High Leys PS. 544) Amenity i s maintained in accordance with Policy DM10 and no specific noise mitigation measures are required during operation of the permanent installations. During construction, adverse impacts are predict ed to occur at a number of locations, these impacts would be mitigated through good neighbour construction practices and specific measures where necessary.

4.4.14 Air Quality and Odour

Planning Policy 545) Paragrap h 109 of the NPPF highlights the need to prevent developme nt from contributing to unacceptable levels of air pollution.

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546) The relevant policy from the Local Plan (Part 1) is Policy ST1 – Strategic Development Principl es, which requires development to mini mise air pollution.

Assessment against Pllaanning Policcy 547) The potential air quality impacts, at identified receptor locations, have been assessed following best practice guidance. 548) Potential air quality impacts considered during the construction phase included those associated with construction vehicles on main haulage routes (emissions of nitrogen oxide (NOx), nitrogen dioxide (NO2) and part iculate matter (PM10)), and construction processes (dust deposition). During the operational phase i mpacts associated with combustion emissions (from generators or other plant) and vehicle exhaust emissions were considered. 549) Existing air quality in the Copeland Borough Council study area is considered to be good in the context of national air quality Objectives for NO2 and PM10. There are a number of properties in close proxi mity to routes used by construction vehicles close to the site entrances at scheme component 15 (Network Main – High Leys to Summergrove ) where residents are likely to be highly sensitive to dust emissions due to t heir close proximity to the access routes. Defra background 2018 annual mean PM10 concentrations are <24 µg. m-3 across the Copeland Borough Council study area, therefore the sensitivity of people who may be exposed to particulate matter emissions (PM10) associated with construction activities is likely to be low. Despite this sensitivity, Incrreases in NO2 and PM10 associated with emissions from construction vehicles are likely to be negligible and therefore no specific m itigation is required. 550) Standard good practice measures to mitigate dust emissions from the proposed development are included within the Construction Code of Practice (CCoP)to prevent or minimise the release of dust entering the atmosphere and/or bei ng deposited on nearby receptors. Particular attention would be paid to operations which must unavoidably take place close to the site boundary. Mitigation measures appropriate for the identified likely level of risk are outlined in the air quality assessment provided in the ES (IAQM, February 2014), and it is recommended that they are incl uded in the CCoP for the site, which should be agreed with the local authority. Effective implementation of a CCoP and incorporation of mitigation measures proposed s hould reduce all construction dust soiling and human health impacts to well within acceptable levels. 551) It is considered that with mitigation the Proposed Scheme would not give rise to unacceptable levels of air pollution and is in accordance with Paragraph 1 09 of the NPPF and Loc al Plan.

4.5 Consultation 552) Several phases of consultation have taken place prior to this planning submission. The first phase took place in summer 2014 following the EiP and this focused on raising the awaren ess of the scheme and developing options for the propose pipeline routes locations of the Water Treatment Works and Service Reservoirs. Thi s phase involved one to one meetings with the LPA’s, a publ ic exhibition in , exhibitions at country shows, leaflet drops and social media announcements and establishing a dedicated website and email for responding to questions. In total over 700 people attended these events with 168 specific responses received. Comments ranged from the principal of the scheme to sustainable mitigation. The SCI provides specific details of the stakeholder consultations which took place. 553) The second phase focused on gathering the views of the l ocal community, businesses and landowners taking into account feedback received in Phase 1. This took place from December 2014 to May 2015 and the applicant engaged with the local community and stakeholders through further public exhi bitions in Workington and Cleator Moor which were advertised extensively including on social media. Presentations to local councils ranging from parish councils to the County Council were undertaken and these were supported by tours of the route. Over 450 individu als or stakeholders attended these events with comments raised about potential disruption, impacts on local businesses, funding the scheme, employment opportunities and specific technical questions. 554) Using the feedback received at the second phase, the third phase in the run up to this planning application has concentrated on scheme specifics with one to one meetings (including landowners), interest group and a further round of exhibitions. Specific issues associated with the construction programme were discussed as well as compensation arrangements. The outcome of phase 3 was

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final changes to the design particularly around detailed route selection , remedial works and mitigation. 555) The outcomes of consultation and engagement have therefore fed into the proposed scheme which is subject t o this planning application. If planning permissio n is granted, the applicant would continue engagement and consultation activities through three more planned phases of consultation. These additional phases would focus on final definitive construction plans, mobilisat ion arrangements and post construction mitigation. This reflects the applicant’s commitment to work with the local community as a major service provider and custodian of the water supply 556) This reflects the applicant’s commitment to work with the local community as a major service provider and custodian of the water supply.

4.6 Design and Access 557) This Design and Access section demonstrates how site and context analysis has been used in design development to produce a sustainable and high quality infrastructure scheme. This sectio n focuses on the perman ent development of the surface facilities, which are as follows:

4.6.1 High Leys Service Reservoir and Pumping Station

Site Location and Surrounding Con text 558) High Leys SR and PS is located within Landscape Character Type 5, which is considered to be of high sensitivity, due to the strong intervisibility with the adjacent National Park Landscape Character Types. The landscape is typical of the component Sub-Typ e within the elevated location being open with few landscape features and gently rolling topography. The elevated location does allow for views towards the Lake District although these are long distance. The SR is located adjacent to an existing small service reservoir. 559) The proposed develo pment site itself is a greenfield site comprising four linked agricultural fields with a total area of approximately 1 4.7 ha. One very large field would be divided in two with a new boundary f ormed by extending an existing field boundary line. The site is bounded to the east by Pasture Road. Boundaries are defined by poorly maintained and overgrown hedgerows and stone walls. The site consists of open sem i improved grassland partially enclosed by hedgerow field boundaries. 560) The landscape asses sment recognises the sensitivity of the landscape to large scale development and it is noted that this kind of development is largely absent from the area. The assessment suggest impacts resulti ng from larger developments can be reduced by their careful location away from ridge tops and their scale and form respect local vernacular buildin g materials and character.

Design Evolution and Appearance 561) Service reservoirs are buried concrete structures that store water at the head of a distribution network. The top and bottom water levels in the reservoir are dictated by the need t o gravitate water into supply. In order to minimise the impact on the landscape the struct ure would be largely buried into the hillside with re-profiling around it such that only the valve house is exposed. Figure 4.1 is a photomontage which provides an illustrative example of how the service reservoir m ay appear following reinstatement of the site to final ground levels. 562) After a thorough Optioneering process which is detailed in Chapter 3 of the Environmental Statement, the High Leys site was chosen as the preferred location for the service reservoir. The site is at the optimum hydraulic location to minimise pumping and benefits from a good potential access. The Pumping Station to Kelton Fell can be accommodated to avoid the need for another development site. 563) The SR has been sited to minimise the cut and fill of excavated material with some spoil proposed to be used in a landscape mound.

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Figure 4.1 Photomontage of the new High Leys Service Reservoir (illustrative purposes only)

564) The design includes for:  External handrailing to the valve house woull d be black powder coated not plain galvanised steel to minimise landsca pe and visual impact  External walls and wing walls to the valve houses would be faced with local stone laid in a vernacular style appropriate to the local architecture  Visible element of the valve hou ses and wing walls would be minimised to reduce landscape and visual impact  Embankments woul d be profiled to ensure s uitable gradi ents for safe grass cutting maintenance, maximum 1:3 and s hall be slackened where possible to improve integration into the existing ground profiles and topography to minimise landscape and visual impact  Lighting would be low level and directional where possible and would be capable of being manually operated or motion sensor only, lighting shall not be in operation 24hrs  Existing dry stone walls and hedgerows would be retained wherever possible to retain existin g landscape features and minimise landscape character impact  The provision of a new access to Pasture Road  Landscaping within the site  Removal of the palisade fence at the existing service reservoir.

Access and Movement 565) The access to the High Leys site is via the A595 (Arlecdon Parks Road) or Pasture Road; which are a major public A-ro ad and a small village road. The Contractor shall maintain access for the public and the applicant. 566) Access follows the A5086 in adjacent agricultural fields to limit the impact on landowners and reduce the length of access tracks required into the working width.

4.7 Summary 567) The appli cant has developed the scheme over a number of years and has invested a significant amount of resources into consulting and engaging with its c ustomers, the community, statutory bodies, landowners and businesses prior to this planning submission. From the inception of the proposed scheme it has been recognised that this was a major linear project within a sensitive rural setting and therefore it has been designed as sensitively as practicable to reflect the built and natural environment which surrounds it. The assessme nt of the proposed scheme provided in this PDAS has demonstrated that through the design and mitigation it meets the objectives of the Local Plan.

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5. Sustainability Summary

5.1 Background 568) The contribution to sustainable development of the Proposed Scheme has been assessed and forms part of the accompanying Environmental Statement (Volume 2). 569) Key strategy and policy documents from United Utilities, Allerdale Borough Counci l, Copeland Borough C ouncil, Cumbria County Council and the Lake District National Park Authority were reviewed to identify common sustainability issues and targe ts. A series of environmental, economic and social priorities, determined from relevant strategies and policies for each of the local authorities, has been used to assess the Proposed Scheme. It is clear that United Utilities’ corporate aspira tions correlate closely to these priorities. The criteria have been split into the following topic areas:  Landscape  Water resources  Biodiversity  Built and historic environment  Waste management  Socio-economic  Community impacts  Air qual ity  Energy management  Climate change mitigation and adaptation  Sustainable procurement. 570) Evidence was sought to demonstrate how, as the Proposed Scheme has developed from a strategic option through to planning submission, sustainability has been considered during the development of the design The design of the Proposed Scheme is cons istent with the principles and objectives of sustainable developm ent, as defin ed in the 2005 UK Government Sustainable Development Strategy ‘Securing the Future’:  Living within environmental limits  Ensuring a strong, healthy and just society  Achieving a sustainable economy  Promoting good governance  Using sound science responsibly. 571) United Utilities has a clear sustainable vision and aspirations for its business. The Proposed Scheme would contribute towards that vision by providing essential infrastructure to meet existing supply-demand issues and future changes to existing abstraction licence s, all within a sensitive environme ntal setting. It has ensured that sustainable development has been considered at every step in the development of the Proposed Scheme to minimise potential negative effects and maximise potentially positive contributions that can be made to sustainable development. 572) This iterative process has been enhanced by the extensive consultation programme that has allowed all relevant stakeholders to contribute to the schem e development. 573) The design iterations have incorporated appropriate measures to minimise the negative effects of the Proposed Scheme on the local environments and communities. United Utilities has developed its procurement documentation to ensure that construction contractors will be bound by the high standards that this scheme requires.

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574) United Utilities has taken every opportunity to enhance the sustainability benefits of the Proposed Scheme and to ensure that its cont ractors deliv er those enhancements. The approach taken from strategic assessment through to planning submission, incorporating consultation feedback, has resulted in a scheme that has enhanced the sustainability b enefits where technically feasible. 575) The following summarises the findings of the sustainability assessment for each criteria.

5.2 Landscape 576) United Utilities has clearly set out its corporate aspirations for protecting, conserving and enhancing landscapes, recognising the potential significant impacts that could result from the construction and opera tion of any of its proposed infrastructure schemes. It has incorporated its vision into the strategic review of the Water Resources Management Plan that led to the Proposed Scheme being selected as the preferred option. 577) The ES Landscape and Visual Impact assessment has recognised that a number of significant effects would result from both the c onstruction and operation of the Proposed Scheme, through the introduction of new infrastructure into mainly rural landscapes. However, a series of measures have been identified to ensure that the impact of the Proposed Scheme on local landscapes is minimised. It concludes that the Proposed Scheme would be integrated into the local landscape over time.

5.3 Water Reso urces 578) United Utilities has corporate aspirations for minimising water consumption, protecting, conserving and enhancing the water environment and minimising the risks of and from flooding. 579) The EIA assessments have identi fied a series of mitigation measures to ensure that the impacts of the Proposed Scheme on water resources, the water environment and flood risks are minimised, and enhanced where possible. 580) It has recognised the role that its supply chain has in helping to achieve these aims and therefore has included appropriate requirements in its procurement documentation to ensure that impacts are minimised. United Utilities has defi ned requirements for the Contractors to provide evidence that these measures have been implemented and that performa nce is continuously improving.

5.4 Ecology and Nature Conservation 581) United Utilities recognises the value of the ecologically sensitive environments s throughout the area and the potential negative impacts, such as habitat los s and fragmentation, physical damage, pollution, direct injury/mortality to species and hydrological changes that the Proposed Scheme could caus e. Route planning has considered ecological constraints to ensure that sensitive areas have been avoided where technical ly practicabl e. 582) The EIA assessment has identified a series of measures, recommended as a resu lt of the impacts of the Proposed Scheme, which all contribute to preserving and enhancing biodiversity within Cumbria, during both construction and operatio n.

5.5 Built and Historic Environment 583) United Utilities has developed a c lear framework of mitigation measures and contractual requirements within the Cultural Heritage assessment to protect cultural and historic features. A number of archaeological surveys have taken place and a schedule of appropriate mitigation, including further archaeological investigations and a watching brief has been develo ped.

5.6 Waste Management. 584) United Utilities has set targets for waste diversion from landfill, including diverting 95 % surplus material generated by construction activities from landfill and the 90% reuse target for excavated materials. . 585) It has developed a framework of requirements to ensure that sustainable waste management practices are implemented across t he Proposed Scheme and throughout its supply chain. The contractors would be required to develop Site Waste Management plans to implement the waste

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hierarchy, reduce waste generation and enhance material reuse, as wel l as ensuring legislative compliance.

5.7 Socio-Econ omic 586) United Utilities recognises the pot ential economic benefits of the Proposed Scheme to the local area. It has defined measures to ensure that its employees and those of contractors are appropriately qualified for their roles. Environmental training needs and sustainability risks have been identified. 587) The Prop osed Scheme has been assessed as contributing an annual average of 223 directly employed jobs, of whic h 48 % are considered to be additional, and 45 average additional indirect jobs during construction. During operation, no additional workers would be required. The employment benefits of the Proposed Scheme are considered negligible, as they are such a small percentage change across the whole of Cumbri a.

5.8 Community Impacts 588) The comprehensive, proactive and well-timed public engagement approach adopted by United Utilities demonstrates a genuine commitment to make community engagement an important priority, and highlights United Utilities’ socially responsible approach to its day-to-day activities. Feedback has been used to inform the route development. 589) HGV traffic movements have been considered during the development of the Proposed Scheme, with United Utilities det ermining that the number of HGVs would not be a cause of congestion. However, the potential for nuisance to be caused has been identified and the implementation of a Traffic Management Plan would ensure that any impacts are minimised. 590) The operational traffic impacts are considered to be imperceptible aga inst backgro und levels. 591) No specific information is available on construction transport mode; however, United Utilities has specified that contractors must optimise transport efficiency and/or minimise transport distances . Transport by sea has been considered for some construction materials, with appropriate routes currently defined from Barrow-in-Furness port. Although not explicitly expressed, it is clear that sustainable transport modes and distances would be used where appropriate. Traffic impacts would be minimised through the implementation of best practice measures in a Traffic Management Plan. 592) Temporary closures of PRoWs would be kept to a minimum and there would be no permanent closures. 593) The Nuisance Manag ement Plan and other supporting documents set out the acceptable work ing methods to minimise negative impacts on the local communities. This is confirmed with the requirement to be a member of the Considerate Constructors Scheme or equivalent . There is a clear framework of appropriate actions to minimise noise and light pollution and any nuisance impacts and a well-defi ned approach for addressing complaints should they arise.

5.9 Energy Management 594) United Utilities has clear aspirations to minimise energy use, maximise renewable energy generation and use and reduce carbon impacts. It has considered these issues throughout the development of the Proposed Scheme for both construction and operational phases . Contractors are expected to make efforts to reduce their energy use and carbon emissions, and report on performance. United Utilities has pledged to use its supply chain process to specify energy efficient equipment. 595) United Utilities has defined a clear framework of expectations and measures to enable it to quantify and minimise energy use and maxim ise opportunities for renewable energy use.

5.10 Climate Change Mitigation and Adaptation 596) United Utilities has a clear vision for energy management and carbon neutrality, as it has recognised climate change as a strategic concern; its operations are an essential service. It has

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developed KPIs to enable it to measure progress on climate change impacts and has developed tools to help suppliers report on performance. 597) The Proposed Scheme has considered climat e change mi tigation and adaptation throughout its design, including the ai m to minimise pumping and to, build in resilience to extreme weather events and determine the embodied carbon of the proposed solution.

5.11 Sustainable Procurement 598) United Utilities has procedures in place to ensure that its contractors and its supply chain would meet relevant legislative standards and report ongoing performance. It expects env ironmentally responsible behaviour within its operations and has developed a framework to ensure best practice procureme nt practice. Certification schemes are used to support performance.

5.12 Compensatory Tree Planting 599) Ecological, landscape and arboricultural surveys have been undertaken to support the preparation of the ES for the scheme. Where practicable trees would be replanted within the working width to mitigate for those lost. Inevitably due to the restrictions on planting trees in close proximity to the pipeline there would be a net loss along the route. It is proposed to compensate for this loss in two ways:  To provide an area of woodland planting at the head of the Ennerdale Valley (see Figure 5.1). The land under consideration is part of the Ennerdale Valley Area, but not currently part of the Wild Ennerdale Stewardship Pl an. This wo uld be a new area of woodland funded by the West Cumbria Water Supplies – Thirlmere Transfer Project and developed in partnership with the Forestry Commission and the National Trust through the Wild Ennerdale Project, of which U U is a partner. This area was once woodland and there is remnant woodland ground flora still present meaning that the important soil fungi exists that allows woodland to colonise. This approach follows the principles of the Government’s Natural Environment White Paper which advocates ‘more, bigger, better and joined’ wildlife area s. General support to the proposals has been received from stakeholders and further discussions would take place to help develop the proposal further.

Figure 5.1 – Ennerdale Valley (proposed mitigation locations shown with green shad ing)

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 To set up a community fund to support tree planting proposals throughout the scheme area. It is anticipated that this would be managed on our behalf by a third party such that local groups can apply for funds to support small scale planting schemes. A similar scheme proved to be very effective on our West East Link Main project in the Merseyside area. The value of this fund, details of its management and the criteria by which funds would be allocated are all subject to further development with stakeholders.

600) These proposals are included in an emerging unilateral undertaking, the draft heads of terms are included as Appendix B, and which supports the planning application.

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6. Construction and Phasing of the Scheme

6.1 Construction Phases 601) It is proposed to phase the construction of the scheme, to minimise disruption on local communities and local environments. Construction is programmed to commence in 2016. For the purposes of construction the scheme has been subdivided into five main sections (refer to Drg. B2707061/S0/04 – Construction Programme Plan):  RWA Pipeline Section (from Bridge End WTW to new WTW - Spring 2017 to Summer 2020)  Network Pipeline (from new WTW to Quarry Hill WTW - Spring 2017 to end of 2018)  Network Pipeline Section (from new WTW to Summergrove SR– Spring 2017 to Autumn 2019 )  Network Pipeline (including sliplining) (from Broughton Cross to Stainburn SR - Summer 2016 – Summer 2020)  Network Pipeline (including sliplining) (from Southwaite Farm to Cornhow WTW - Autumn 2020 – Summer 2021). 602) Timescales for the main elements are detailed below:  Keswick Tunnel (Beginning 2017 – Autumn 2019)  Moota Hill Service Reservoir (Beginning 201 7 – Autumn 2019)  High Leys Service Reservoir and Pumping Station (Beginning Autumn 2016 – Autumn 2019)  Harrot Hill Pumping Station (Beginning 2017 – Autumn 2019)  Water Treatment Works (Autum n 2016 – Au tumn 2020). 603) These dates are approximate, but give an idea of the timeframe for the overall scheme. Construction Activities 604) A typical construction working width of 40 m is anticipated along the le ngth of the pipeline to facilitate safe working, storage and manoeuvring. This working width has been reduced in places to avoid particular sensitive receptors at particular points along the route, e.g. at watercourse and hedgerow crossings.  Working hours woul d typically be 08.00 to 18.00 Monday to Friday and 08.00 to 12.00 on Saturdays. There would be typically no working on Sundays or Bank Holidays. Any potentia l changes that would be required to these hours would be discussed with the relevant Environmental Health Officers  For tunnelling activities working hours would be 24 hours a day 7 days per week for the duration of the tunnelling activity. Once tunnelling co mmences it is not possible to stop once started  It is proposed that c onstruction activity throu ghout the Proposed Scheme is phas ed, to minimise disruption on local communities and local environments.

6.2 Standard Construction Techniques and Management

6.2.1 Enabling Works 605) Enabling works would consist of fencing off the working width with stock proof fencing and wire fence. Access points as agreed with the landowner would be provided for crossing the works using gates. The working width would be topsoil stripped and dra inage installed and vehicles would also make use of this width as access for the proposed scheme, which would help to minimise the impact of vehicle movements on the road. 606) The compounds and pipe laydown areas would be surfaced with teram or geo grid in accordance with site specific conditions. Temporary access to the compounds would be laid or resurfaced. Temporary site cabins would be brought to site for offices and stores an d laid on appropriate foundations, levelled and secured. The remainder of the compound would be split between car

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parking, plant and com mercial vehicle storage, material storage area and traffic circulation routes connecting and servicing these areas. 607) Task lighting and general lighting would be required to enable safe wo rking practices during the autumn/ winter period and would typically be trailer- mounted self-contained tower lights, which would be operated continuously. Lights would also be required on top of the site cabins. Such lights would be located and positioned so as to minimise the amount of light overspill onto adjacent land.

6.2.2 Open Cut Pipelaying 608) In standard non-constrained habitats, a working width of up to 40m would be subject to top soil strip with the top soil st ored within the working easement. On the twin pipes there a re single trench or double t rench options (see Drg. B2707061/S 4/06 & Drg. 07). The pipes would be laid within the trench and back filled with fill material, allowing a minimum depth of cover below ground level. Where possible, fill material would be that which has been excavated from the trenc h. Topsoil would be replaced once the trench is filled. 609) Work would typically be carried out in daylight hours to reduce the risk of light pollution. During winter there would be a need to extend the working day by utilising temporary lights. 610) The pipeline would be constructed through a number of major road crossings (refer to the Series 5 drawings). 611) It is proposed that major road crossings are undertaken during the winter months, to minimise disruption where possible, and minor roads crossings would take place outside the winter months. 612) A number of watercourses would be crossed using open cut techniques. Watercourse crossings would be agreed with the Environment Agency and Natural England and phased wh ere possible to minimise disturbance. Where open cut techniques are to be used, this would require the temporary diversion or culverting of the watercourse.

6.2.3 Trenchless techniques 613) At roads and watercourses, it is possible to install pipes through trenchless techniques subject to the ground conditions. A number of trenchless techniques are proposed for the scheme, including directional drill and, Tunnelling (refer to the Series 5 Planning Drawings)

Directional drilling and tunnelling 614) This involves the use of specialist drilling equi pment to create a tunnel through the underlying ground, through which the water main is installed by pulling the pipe through from one end to another. Launch and reception pits would be required at each end of the drill section. 615) In addition to directional drill, tunnelling techni ques would also be used at three locations. Typical arrangements for tunnels are shown in Series 5 Planning Drawings. 616) Tunnelling would take place 24/ 7 once commenced. Pipes and ducts would be installed once the tunnelling i s completed, the tunnel would then be grouted and the shaft backfilled. A concrete shaft cover would be placed at the top of the shaft.

Slip-lining 617) Slip-lining is a technique involving a continuous and fully structural polyethylene (PE) liner being pulled through a host pipe of larger diameter. The host pipe offers no structural support to the liner, as it simply acts as a conduit. 618) Launch a nd reception pits would be required to insert the liner into the host pipe and to receive the liner at the end of the section. They are typicall y located at bends in the existing pipe network. These pits would be excavated at points along the slip-lining section. 619) Typically launch pits are 10 min length by 2.5 min width and 2.5 min depth, although this is dependent on pipe diameter and depth. Reception pits would typically be 5 m in length by 2.5 m in width and 2.5 m in depth, although this varies depending on pipe diameter and depth. 620) Excavations would be required at all existing air valve, washout and other fitting locations along the length of the host pipe, in order to remove them prior to slip-lining. New fittings wou ld be installed

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once the slip-lining process is completed. These fitting excavation pits would typically be 4 min length by 2 m in width and 2.5 m deep. 621) The conti nuous liner is inserted from an excavated launch pit into the host pipe by either pushing, or pulling it through. The individual liner sections are plastic welded together to produce continuous sections. Once connected the liner is winched through the host pipe to the reception pit. 622) One completion of the slip-lining all excavation would be reinstated to match the surrounding environment.

6.3 Surplus Material 623) United Utilities is developing a Materials Management Plan (MMP), which would identify the quantities and types of materials that are generated, as part of the construction process, as the designs and construction programme details are refined. Notwithstanding this, it is proposed that topsoil would be segregated within the working width and re-used for final reinstatement, and that excavated subsoil would be temporarily stored within the working width for direct re-use as structural fill, backfill and landscaping. It is anticipated that any material that is surplus to requirements would either be taken to Lillyhall landfill or Moota Quarry for deposit for recovery activities (restoration).

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7. Conclusions 624) United Utilities has a statutory duty to produce a Water Resources Management P lan under the Water Act 2003. The Final Water Resources Management Plan was published in M arch 2015. The plan describes in detail an assessment of the available water supplies and the demand for water over the 2015 – 2040 period. The plan also sets out the proposed strategy for water resources and demand management to ensure that an adequate water supply is available to serve the region. 625) Within the Plan the forecast West Cumbria resource zone supply-demand balance showed a deficit of over 33 ML/day (mill ion litres/day) due to the revocation of Ennerdale Water abstraction licence. If a new water source is not delivered in advance of the licence revocation in 2025, at Ennerdale Water, there would be no legally available abstraction to provide public water supply to the population currently fed by Ennerdale Water. United Utilities would therefore be in breach of its obligations under the Water Industry Act 1991 to maintain a water suppl y system. 626) Ultimately the Water Resources Management Plan was subject to an Examination in Public called for by the Secretary of State. The Examination in Public process confirmed that the proposed scheme was accepted as the right solution to supply water in the West Cumbria Resource Zone over the next 25 years. 627) The proposed scheme has developed following a comprehensive Environmental Impact Assessment and in conjunction with extensive stakeholder and community consultation. Regular liaison has taken place with the local planning authorities and statutory consultees Three phases of public consultation have been held involving pu blic exhibitions, displays at agricultural shows, meetings with parish councils and other key stakeholders. This iterative consultation process has helped shape the proposal. 628) Although it is recognised that the construction of a project of this scale in an area such as West Cumbria and the Lake District National Park would involve a degree of disruption to both people and the environment, the development of the scheme along with the mitigation & compensation proposals ensure that the impacts are largely temporary and acceptable in planning policy terms. The proposals provide for a resilient, sustainabl e water supply to serve the needs of West Cumbria.

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Appendix A. Application Documentation

West Cumbria Water Supplies Project – Thirlmere Transfer Rev PLANNING DOCUMENTATION Planning, Design and Access Statement 1 Statement of Community Involvement 0 PLANNING DRAWINGS Drawing No. Rev. SERIES 0 ‐ OVERVIEW Project Overview B2707061/S0/01 A Overall Scheme Layout (showing extent/location of general arrangement A drawings) B2707061/S0/02 Construction Phasing Plan B2707061/S0/04 A SERIES 1 ‐ LOCATION PLANS Lake District National Park Authority Location Plan B2707061/S1/LDNP/01 A Allerdale Borough Council Location Plan B2707061/S1/ABC/01 A Copeland Borough Council Location Plan B2707061/S1/CBC/01 A SERIES 2 ‐ GENERAL LAYOUT B2707061/S2/LDNP/001‐ A Lake District National Park Authority General Layout Sheets 1‐28 028 Allerdale Borough Council General Layout Sheets 1‐27 B2707061/S2/ABC/001‐027 A Copeland Borough Council General Layout Sheets 1‐10 B2707061/S2/CBC/001‐010 A SERIES 3 ‐ FACILITES DRAWINGS Bridge End Connection (Lake District National Park Authority) Bridge End Connection Existing and Proposed Site Layout B2707061/S3/LDNP/01 0 Bridge End Connection Site Sections 1 of 2 B2707061/S3/LDNP/02 0 Bridge End Connection Site Sections 2 of 2 B2707061/S3/LDNP/03 0 Bridge End Connection Hydrogeneration House Elevations B2707061/S3/LDNP/04 0 Bridge End Connection Hydrogeneration House Section and Floor Plan B2707061/S3/LDNP/05 0 Bridge End Connection Control Kiosk Roof Plan and Elevations B2707061/S3/LDNP/06 0 Bridge End Connection Control Valve House Floor Plan, Roof Plan and Sections B2707061/S3/LDNP/07 0 Bridge End Connection Control Valve House Elevations B2707061/S3/LDNP/08 0 Bridge End Connection Water Quality Control Kiosk Roof Plan and Elevations B2707061/S3/LDNP/09 0 Bridge End Connection Proposed Temporary Pumping Arrangement and New 0 Meter Chamber Layout and Elevations B2707061/S3/LDNP/10 Water Treatment Works (Allerdale Borough Council) Water Treatment Works Site Layout B2707061/S3/ABC/WTW/01 0 Water Treatment Works Proposed Site Sections ‐ Sheet 1 B2707061/S3/ABC/WTW/02 0 Water Treatment Works Proposed Site Sections Sheet 2 B2707061/S3/ABC/WTW/03 0 Proposed Landscaping Strategy B2707061/S3/ABC/WTW/04 0 Water Treatment Works Control Building ‐ Roof and Floor Plans B2707061/S3/ABC/WTW/05 0 Water Treatment Works Control building ‐ Elevations B2707061/S3/ABC/WTW/06 0 Water Treatment Works Workshop ‐ Roof and Floor Plans B2707061/S3/ABC/WTW/07 0 Water Treatment Works Workshop ‐ Elevations B2707061/S3/ABC/WTW/08 0 Water Treatment Works Filter and Chemical Building ‐ Floor Plans B2707061/S3/ABC/WTW/09 0 Water Treatment Works Filter and Chemical building ‐ Elevations B2707061/S3/ABC/WTW/10 0 Water Treatment Works Filter and Chemical Building ‐Sections B2707061/S3/ABC/WTW/11 0 Water Treatment Works Service Water Kiosk ‐ General Arrangement Plan and 0 Elevations B2707061/S3/ABC/WTW/12 Water Treatment Works Lamella Clarifier Tank ‐ General Arrangement Plan and 0 Elevations B2707061/S3/ABC/WTW/13 Water Treatment Work Flocculation Tank Kiosks ‐ Roof Plan and Elevations B2707061/S3/ABC/WTW/14 0

Planning, Design and Access Statement

Water Treatment Work Flocculation Tank ‐ General Arrangement and Sections B2707061/S3/ABC/WTW/15 0 Water Treatment Work Inlet Control and Turbine Chamber ‐ General 0 Arrangement, Roof plan and Section B2707061/S3/ABC/WTW/16 Water Treatment Works Site – Block Plan B2707061/S3/ABC/WTW/17 0 Moota Hill Service Reservoir (Allerdale Borough Council) Moota Hill Service Reservoir Site Layout B2707061/S3/ABC/MH/01 0 Moota Hill Service Reservoir Floor Plan B2707061/S3/ABC/MH/02 0 Moota Hill Service Reservoir Roof Plan B2707061/S3/ABC/MH/03 0 Moota Hill Service Reservoir Elevations B2707061/S3/ABC/MH/04 1 Moota Hill Service Reservoir Landscape Plan B2707061/S3/ABC/MH/05 0 Moota Hill Service Reservoir Sections B2707061/S3/ABC/MH/06 0 Harrot Hill Pumping Station (Allerdale Borough Council) Harrot Hill Pumping Station Site Layout Plan B2707061/S3/ABC/HH/01 0 Harrot Hill Pumping Station Elevations B2707061/S3/ABC/HH/02 0 Harrot Hill Pumping Station Scheme Elevations (Sheet 1) B2707061/S3/ABC/HH/03 0 Harrot Hill Pumping Station Scheme Elevations (Sheet 2) B2707061/S3/ABC/HH/04 0 Harrot Hill Pumping Station Landscape Plan B2707061/S3/ABC/HH/05 0 Harrot Hill Pumping Station Floor Plan B2707061/S3/ABC/HH/06 0 Harrot Hill Pumping Station Internal Building Section (Sheet 1) B2707061/S3/ABC/HH/07 0 Harrot Hill Pumping Station Internal Building Section (Sheet 2) B2707061/S3/ABC/HH/08 0 High Leys Service Reservoir (Copeland Borough Council) High Leys Service Reservoir Site Layout Plan B2707061/S3/CBC/HL/01 0 High Leys Service Reservoir Floor Plan B2707061/S3/CBC/HL/02 0 High Leys Service Reservoir Roof Plan B2707061/S3/CBC/HL/03 0 High Leys Service Reservoir Elevations B2707061/S3/CBC/HL/04 1 High Leys Service Reservoir Landscape Plan B2707061/S3/CBC/HL/05 0 High Leys Service Reservoir Sections B2707061/S3/CBC/HL/06 0 SERIES 4 ‐ TYPICAL ARRANGEMENT DETAILS Raw Water Aqueduct Pipeline Cross Sections Through Working Widths B2707061/S4/01 0 Standard Details Air Valve B2707061/S4/02 0 Standard Details Line Valve and Cross Connection B2707061/S4/03 0 Standard Details Raw Water Aqueduct Line Valve and Kiosk Cover Slab B2707061/S4/04 0 Standard Details Raw Water Aqueduct Gravity Washout with Pumping Facility B2707061/S4/05 0 Networks Mains Pipeline Cross Sections Through Working Widths Details Sheet 0 1 B2707061/S4/06 Networks Mains Pipeline Cross Sections Through Working Widths Details Sheet 0 2 B2707061/S4/07 Gravity Washout B2707061/S4/08 0 SERIES 5 ‐ CROSSING POINTS DETAILS Raw Water Aqueduct Typical Open Cut Road Crossing Details B2707061/S5/LDNP/01 0 Raw Water Aqueduct Open Cut Minor Road Crossing Details B2707061/S5/LDNP/02 0 Raw Water Aqueduct Typical River Crossing B2707061/S5/LDNP/03 0 Raw Water Aqueduct Typical Culvert Crossing Details B2707061/S5/LDNP/04 0 Pipe Bridge/Supported Pipeline North of A66 B2707061/S5/LDNP/05 0 Ravine Crossing ‐ Gill Wood/Gill Beck Sections B2707061/S5/LDNP/06 0 River Greta Crossing B2707061/S5/LDNP/07 0 Proposed Details For Construction Through Shoulthwaite Moss (Sheet 1 Of 2) B2707061/S5/LDNP/08 0 Proposed Details For Construction Through Shoulthwaite Moss (Sheet 2 Of 2) 0 Plans And Sections B2707061/S5/LDNP/09 Network Water Main Pipeline River Derwent Crossing B2707061/S5/10 0 Network Water Main Typical Road and River Crossing Detail Horizontal 0 Directional Drilling B2707061/S5/11

Planning, Design and Access Statement

Network Water Main Typical Road and River Crossing Detail Micro Tunnelling B2707061/S5/12 0 Network Water Main Typical Road and River Crossing Detail Open Cut B2707061/S5/14 0 SERIES 6 ‐ Landscaping Reinstatement Strategy 0 Landscaping Reinstatement Strategy ‐ 40m Woodland Reinstatement B2707061/S6/01 Landscaping Reinstatement Strategy ‐ 20m Woodland Reinstatement B2707061/S6/02 0 Landscaping Reinstatement Strategy ‐ 20m Hedgerow Reinstatement B2707061/S6/03 0 Landscaping Reinstatement Strategy ‐ 20m Work Spanning Watercourses B2707061/S6/04 0 Landscaping Reinstatement Strategy ‐ 40m Woodland Reinstatement Single 0 Pipe B2707061/S6/05

Planning, Design and Access Statement

Appendix B. Unilateral Undertaking – Heads of Terms

Planning, Design and Access Statement

West Cumbria Water Supplies Project Thirlmere Transfer DRAFT Unilateral Agreement Compensation for Tree Loss Where practicable trees will be planted within the working width to mitigate for those lost. Inevitably due to the restrictions on planting trees in close proximity to the pipeline there will be a net loss along the route. It is proposed to compensate for this loss in two ways:

1. To provvide an area of woodland planting at the head of the Ennerdale Valley (see Figure 1). The land under consideratio n is part of the Ennerdale Valley Area, but not currently part of the Wild Ennerdale Stewardship Plan. This would be a new area of woodland funded by the West Cumbria Water Supplies – Thirlmere Transfer Project and developed in partnership with the Forestry Commission and the Nation al Trust through the Wild Ennerdale Project, of which UU is a partner. This area was once woodland and there is remnant woodland ground flora still present meaning that the important soil fungi exists that allows woodland to colonise. This approach follows the principles of the Government’s Natural Environment White Paper which advocates ‘more, bigger, better and joined’ wildlife areas. General support to the proposals has been received from stakeholders and further discussions will take place to help devel op the proposal.

Figure 1 – Ennerdale Valley (mitigation location shown with green arrow)

2. To set up a community fund to support tree planting proposals throughout the scheme area. It is anticip ated that this will be managed on our behalf by a third party such that local groups can apply for funds to support small scale planting schemes The value of this fund, details of its management and the criteria by whic h funds will be allocated are all subject to further development with stakeholders.