Copeland Local Plan 2013-2028

Site Allocations and Policies Plan Preferred Options

Summary of Consultation Responses

November 2015

1 Contents

Executive Summary...... 3

1.0 Introduction ...... 4

2.0 The Consultation Process...... 6

3.0 Summary of Written Responses ...... 8

3.1 Contextual Background...... 8

3.2 Proposed Site Allocation Policies ...... 9

3.3 Sites Proposed for Allocation ...... 35

3.4 New Site Submissions ...... 44

3.5 Sustainability Appraisal ...... 44

Appendix One: Sites without responses ...... 46

Appendix Two: New Site Submissions ...... 50

Appendix Three: Site Allocations and Policies Plan Consultation Responses...... 53

2 Executive Summary Copeland Borough Council produced the Site Allocations and Policies Plan Preferred Options and associated Sustainability Appraisal consultation documents in January 2015. The purpose of the plan is to identify the extent and location of new development sites and related planning policies for the borough of Copeland to deliver the development plan in the adopted Core Strategy. The Sustainability Appraisal considers the broader environmental, social and economic effects of development potential proposed in the Site Allocations and Policies Plan. This report summarises the responses received as a result of the public consultation held between January and March 2015.

This Site Allocations and Policies Plan Consultation Responses summary report provides an overview of those written responses received relating to the following areas: . The proposed site allocation policies, which addresses a total of 47questions; . The sites which the Council has proposed for allocation; . The 55 new site submissions made by respondents; . Written responses to the accompanying Sustainability Appraisal document.

Key areas of comment relating to the proposed site allocation policies include suggestions around the wording of Proposed Policy SA1 ‘Principles for allocating land for development’; the support or objection to Policy SA3 ‘Settlement boundary review’; comment on the preferred options for the delivery of affordable housing, older peoples housing and housing to meet local needs; and comment on the preferred options for the amount of greenspace designated in the Local Plan.

Areas that generated the greatest response related to the sites which the Council has proposed for allocation refer to the allocation of WS4 Woodhouse Road/WS2 St. Bees Road in Whitehaven for Gypsy & Traveller use, housing allocations at Moresby Parks and Moor Row and the proposed Fr1 Lingley Fields Extension in Frizington.

Written responses relating to the Sustainability Appraisal (SA) mainly refer to the SA score that the Council has scored against 25 sites. This is on the basis that English Heritage consider that development would not harm any heritage resource relating to the 25 sites and rather, could be used to enhance the landscape/asset/setting significantly.

Detailed responses and proposals received to the Site Allocations and Policies Plan consultation, including a record of those sites which have not been commented on, can be referred to in the appendices attached to this report.

3 1.0 Introduction

1.1 In December 2013 the Council adopted the Local Plan 2013-2028 Core Strategy and Development Management Policies. To complete the Local Plan the Council is now producing the Site Allocations and Policies Plan. From 12th January 2015 Copeland Borough Council consulted on the Site Allocations and Policies Plan Land for development Preferred Options document. This plan was accompanied by the Sustainability Appraisal also out for consultation which, takes into account the broader environmental, social and economic effects of development potential. Consultation on both documents closed on Friday 20th March 2015 yet representations continued to be received until October 2015. Together with the adopted Core Strategy and Development Management Policies they will provide the basis for determining planning applications.

1.2 This Site Allocations and Policies Plan consultation follows on from the Issues and Options consultation, which took place between 28 May 2009 and 10 July 2009. The Issues and Options consultation report was designed to cover the Local Development Framework as a whole (i.e. the Core Strategy, Development Management Policies and site selection criteria for the Site Allocations DPD). The summary of responses to the Issues and Options stage can be found on our website: Copeland LDF Issues and Options Issues: Responses to Consultation – Summary Report 2009.

1.3 The Site Allocations and Policies plan sets out Copeland’s supply of development land to meet the borough’s needs and growth aspirations for the fifteen year horizon of the Local Plan from 2013 to 2028. The Core Strategy sets out the strategy for growth in the borough and the Site Allocations and Policies Plan will identify the pieces of land that will deliver this growth. Once adopted, they will replace the remaining allocations that have been saved from the Copeland Local Plan 2001-2016.

4 The Site Allocations and Policies Plan Preferred Options document invited respondents to comment on:

. Taking forward the strategic policies of the Local Plan Core Strategy, adopted in 2013; . Choosing which sites in the identified supply are suitable to be allocated now for development over the next 15 years; . Evaluating the supply of land available for employment development; . Ensuring there is enough space and other recreational land to support a good quality of life and that it is protected from development.

1.4 This report summarises the representations received in response to proposals within the Site Allocations and Policies Plan, both through stakeholder consultation events and written representations. It considers each of the questions in the Site Allocations and Policies Plan in turn. The summary of written responses (section 3.0 of the report) are grouped and presented in the same order as featured in the consultation document. Each of the questions are outlined in turn, with a summary of responses for each question, followed by the number of responses received to that question. As the number of respondents to each question is a relatively low figure these have been expressed as numbers rather than percentages.

1.5 It should be noted that some respondents selected an option and then provided comments to explain their answer, others selected the option they supported without giving any additional comments, and other respondents made comments without indicating a preference from the options available. The comments in the main section of this report represent an overview of the responses made. All comments made are available to view in detail in a separate appendix of this report.

5 2.0 The Consultation Process

2.1 Between January and March 2015 letters were sent out to stakeholders notifying them of the forthcoming Site Allocations and Policies Plan consultation. Stakeholder meetings and events were held with statutory consultees, community locality groups and members of the public inviting comments about the policies in the consultation document along with the suggestion of any new sites that should be included.

2.2 During the consultation period the Council received over 450 responses including 55 New Site Submission forms, 411 Site Comment forms and 18 Questionnaires. Most responses to the questionnaire were from landowners and agents, local residents and community groups and local, regional and national agencies. A petition was also received from a community association. Below is a breakdown of the number of different types of stakeholders making comments to the Site Allocations and Policies Plan consultation document as a whole.

. Developers, landowners and agents . Parish Councils . Copeland Borough Councillors and Cumbria County Councillors . Local residents . Local, regional and national agencies

A detailed list of all those who responded to the Site Allocations and Policies Plan questionnaire can be found in a separate appendix of this report.

2.3 Key areas of comment under 3.2 ‘Proposed Site Allocation Policies’ cover suggestions around the wording of Proposed Policy SA1 ‘Principles for allocating land for development’; the support or objection to Policy SA3 ‘Settlement boundary review’; preferred options for the delivery of affordable housing, older peoples housing and housing to meet local needs; and preferred options for the amount of greenspace designated in the Local Plan.

Key areas of comment under 3.3 ‘Sites Proposed for Allocation’ cover the allocation of WS4 Woodhouse Road/WS2 St. Bees Road for Gypsy & Traveller use and housing allocations at Moresby Parks, Moor Row and the proposed Fr1 Lingley Fields Extension.

6 Key areas of comment under 3.5 ‘Sustainability Appraisal’ mainly refer to the SA score that the Council has scored against 25 sites. This is on the basis that English Heritage consider that development would not harm any heritage resource relating to the 25 sites and rather, could be used to enhance the landscape/asset/setting significantly.

2.4 Following consideration of the comments received as part of the Site Allocations and Policies Plan consultation process a draft plan for further public comments will be published which the Council hopes to achieve by late spring/summer 2016. The Council will then consider comments made once again and a final draft will be submitted to the Secretary of State for public examination. Prior to submission, the plan will be published and advertised so that anyone not happy with it can object to the Secretary of State and have their concerns considered by the Inspector appointed to examine the plan.

7 3.0 Summary of Written Responses

3.1 Contextual Background The Site Allocations and Policies Plan posed several questions to respondents around the issues and proposals being made. These questions were structured around the individual sections and proposed policies in the Site Allocations and Policies Plan and representations which, are summarised in sections 3.2, 3.3, 3.4 and 3.5 below. As the Site Allocations and Policies Plan document is part of the Local Plan respondents were also asked to consider the following questions before putting forward their representations:

. Does the plan meet the development strategy (and therefore, the Government’s national planning policy)? . Is the plan OK in terms of sustainable development (refer to the document’s Sustainability Appraisal)? . Will the plan help to meet the needs of the Borough and its communities, and provide a sound basis for economic growth?

Comments were received for some settlements but not all. Those settlements where no comments were made can be found in the separate appendices of this report.

8 3.2 Proposed Site Allocation Policies

This section summarises responses to each of the questions asked during the consultation, in turn.

Principles for Allocating Land for Development

1. Do you have any comments or suggested amendments to make regarding the Proposed Policy SA1: Principles for allocating land for development? Out of the 18 questionnaires three respondents support proposed policy SA1. One respondent suggested that the policy is unnecessary as it is not a review or an update of a previous policy. The remainder of the respondents offered suggestions around including emphasis on economic and viability impacts as well as social and environmental impacts. Specifically, it was suggested that criteria D and F should be elaborated upon or should comply with the National Planning Policy Framework (NPPF) more effectively. An additional criterion G was suggested to incorporate landscape character. It was also pointed out that Habitats Regulations Assessments (HRAs) have not been given enough emphasis and reference to such is made only in one paragraph. Overall, respondents’ comments suggest proposed Policy SA1 may need to be elaborated on further.

Total respondents 18

2. Do you have any comments or suggested amendments to make regarding the Proposed Policy SA1B: Principles for revoking an existing (Local Plan 2006) allocation?

Five comments of support were put forward for this policy with one suggestion that support will only be given to the de-allocation of sites where evidence is shown that there are issues with deliverability of the site. A further suggestion was made to include a further criteria F which focuses on green infrastructure. Two objections were put forward with one focusing on the de-allocation of site WP5 Newdale Yard, Low Road and the inconsistency of the policy being applied in this instance. The

9 second objection stated that the policy, as worded, is too narrow and specific in its focus and does not give due consideration to all factors that may be relevant.

Total respondents 8

3. Should we look to de-allocate any of the sites in Figure 3.1 ‘Sites allocated in 2006 whose retention is proposed?

Only three respondents commented on whether or not to de-allocate any of the sites in Figure 3.1 of the Site Allocations and Policies Plan. One respondent stated ‘no’ and supported only site E6 Leconfield Industrial Estate for retention. Two respondents stated yes: one for support of E10 Egremont North as a de-allocation as it is felt to represent an unacceptable extension of Egremont towards Woodend and the second, to de-allocate land at Sneckyeat Road as employment due to aspirations to utilise the currently leased temporary car parking site for a permanent car parking site for West Cumberland Hospital.

Total respondents 8 Yes 6 No 2

4. Should any of the sites proposed for de-allocation in Figure 3.2 ‘Sites where rescinding of 2006 allocation is proposed’ be retained as allocations?

Four respondents think that yes, some sites should be retained as allocations including: . WP5 Newdale Yard, Low Road as it is considered that this brownfield land is a logical extension to local housing stock with few constraints to deliverability . HA19 Station Road, Rowrah and land around Rowrah Hall as development is essential to the support and retention of local essential services . E5 Red Lonning, Whitehaven (Harras Moor) to allocate as housing if it was near to a small industrial estate.

10 Three respondents think that sites should not be retained as allocations due to reasons of protecting green infrastructure; being a generally sensible approach if development on these sites has not been possible to date or being of no relevance to merit further comment.

Total respondents 8 Yes 4 No 3 General comments 1

Issues relating to land for housing

5. Which option of three do you support regarding the distribution of executive housing (p18)? 6. One respondent gave preference to option 2 to encourage more executive housing development in villages together with completion of existing estates e.g. Rheda. The respondent further stated that development in the towns for executive housing is unlikely as it does not offer an adequate land use response to demand. Seven respondents favoured option 3 to stick with the overall targets and distribution in the Core Strategy as this aligns with the borough’s economic aspirations and development proposals can be considered on a case by case basis which conforms further with the flexible nature of the NPPF.

Total respondents 10 Option 1: Allow executive-style ‘key worker’ developments in the countryside 0 Option 2: Encourage more executive housing development in villages 1 Option 3: Stick with the overall targets and distribution in the Core Strategy 7 General comments 2

11 7. Which option do you support regarding the delivery of affordable housing (p19/20)?

One respondent did not support a preferred approach but stated that the Council’s aim to minimise unrealistic expectations and negotiate appropriate level of provision is welcomed. Five respondents favoured option 2 to set targets for each allocated site on the basis of flexibility and being responsive to need. Two respondents supported option 3 to not set a policy target but to use the Core Strategy’s figure when negotiating planning conditions on individual developments, for the reasons outlined in the plan and that the option offers a degree of flexibility.

Total respondents 11 Option 1: Set a standard borough-wide quota of 15-25% 0 Option 2: Set targets for each allocated site 5 Option 3: Do not set a policy target but use the Core Strategy’s figure when 2 negotiating planning conditions on individual developments General comments 4

8. Which option do you support regarding the delivery of housing for older people (p20)?

One respondent commented that option 1 to identify sites specifically for older people is the preferred approach in order to keep elderly people in the areas appropriate to them. Three respondents favoured option 2 to let the market decide and three respondents preferred to rely on planning obligation on selected sites as long as there is good access to local services essential for older people.

Total respondents 11 Option 1: Identify sites specifically for older people 1 Option 2: Let the market decide 3 Option 3: Rely on planning obligations on selected sites. 3 General comments 4

12 9. Which option do you support regarding the delivery of housing to meet local needs (p21/22)? Three respondents favoured option 1 to use the Lake District definition for the reasons set out in the Site Allocations and Policies Plan and suggest that a consistent approach being used across Copeland would be welcomed. Two respondents opted for option 2 to use a less prescriptive definition. One respondent opted for option 3 to not define it in the plan but to apply it to developments on their merits. One respondent opted for option 4 yet provided no reasoning behind this preference.

Total respondents 11 Option 1: Use the Lake District definition 3 Option 2: Use a less prescriptive definition 2 Option 3: Don’t define it in the plan but apply it to developments on their merit 1 Option 4: Allow complete freedom of choice and abandon local occupancy 1 conditions General comments 4

10. Which option do you support regarding the Council’s duty to provide for identified need for Gypsies and Travellers (p23)? One respondents suggests that option 1 is the preferred approach by not making any policy provision but to work in partnership with the neighbouring local authorities to propose a joint site away from residential areas. Six respondents stated option 3 as their preferred approach as, a clear policy led approach is recommended in order to provide greater certainty while making the appropriate provision due to the contentious nature of these sites. A petition was also received from a community association comprising 60 signatures objecting to the option of using the planning process to select a site or sites.

Total respondents 9 Option 1: Make no policy provision 1 Option 2: Make no allocation but rely on criteria-based policy to judge 0 proposals when they come forward Option 3: Use the planning process to select a site or sites 6 General comments 2

13

11. Which option do you support regarding the delivery of self-build housing (p25)?

One respondent stated that option 2 to allocate sites for self-build is the preferred approach as it is felt there is no need to differentiate due to planning approval being required regardless. Six respondents stated option 3 to encourage self-build in appropriate locations as the preferred approach due to the reasoning provided in the Site Allocations and Policies Plan. One general comment suggested that it is not considered necessary to allocate specific self-build sites as such developments would arise through appropriate windfall sites and would also need to comply with other policies set out in the Local Plan.

Total respondents 8 Option 1: Allocate sites for self-build 0 Option 2: Permit self-build in principle on any site 1 Option 3: Encourage self-build in appropriate locations 6 General comments 1

12. Do you have any comments of suggested amendments to make regarding the proposed Policy SA2: Strategic principles for housing development? Of the nine respondents commenting on this question there was a mixed reaction to proposed policy SA2. There is some general support for the policy but with a suggested need to emphasise within the policy that all ‘windfall’ development sites within settlement boundaries should be considered on their merits. Furthermore, it is suggested that the windfall element of the policy is not specific enough in regard to the term ‘excessive size’, or any justification as to why there is a presumption against windfall sites. It is stated by one respondent that the provision of a Gypsy Traveller site on WS2 Woodhouse Road and WS4 St. Mary’s School is inappropriate and it is considered that any requirement for such a site should be met in a more appropriate location. One respondent is disappointed to see the policy at all, yet there is also strong support of the overall distribution in this policy and for paragraph three of not encouraging excessive growth in individual settlements. However, it is felt that this is undermined

14 by the potential allocations for both Cleator Moor and Egremont that are suggested to be above the higher ambitious housing target requirements. A separate respondent suggests that some comments mentioned previously regarding affordable housing site specific targets, older people and travellers need to be addressed to enable Policy SA2 to be considered sound. In other comments supporting the policy it is stated that it is vital that the Council allocates enough land to meet the boroughs’ housing need over the whole plan period. As such, it is important for the Site Allocations and Policies Plan to reflect the proportions regarding distribution as identified in the Core Strategy (albeit it is acknowledged that these figures are not ceilings). Here, there is continued support for windfall sites and that the housing types, tenures and sizes are assessed on the merits of each individual site, taking into consideration the deliverability and viability of each site. It is also put forward that robust design guides should be sought.

Total respondents 9 Support 2 Object 1 General comments 6

12/13. Is there a need to allocate more land in the plan for any of the following non-housing specific uses? Only two respondents commented that more land needs to be allocated for business and leisure. It was felt there is a need to allocate more sites in and around Cleator Moor Town Centre in order to aid regeneration in this location. In terms of land allocated for leisure it is suggested that the Council actively engage with the local community to identify suitable sites on the back of the Open Space Study 2011. One respondent stated that open space is vital to local people’s health, mental well-being and quality of life and this would accord with the positive emphasis in Policy ST1, B, iii regarding Green Infrastructure.

Total respondents 2 Business 1 Retail 0

15 Commercial 0 Leisure 1 Other 0

Settlement Development Boundaries

14. Which option(s) do you support regarding the directions of growth for Whitehaven (p31/32)? Three respondents suggest that option 1 to concentrate development within the existing boundary would be the preferred approach as this aligns with Local Plan policy and ensures sustainable development objectives are met. The preference would be to allocate more sites within the existing settlement boundary although it is highlighted that Harras Dyke Farm (WH11, WH12 and WH13) should not be allocated as constraints exist with the site and would be contrary to the strategic growth direction for the town. Furthermore, it is suggested that WE10 Egremont Road would harm the potential wildlife corridor and undermines the separation of Whitehaven, West Lakes and Moor Row.

Three respondents suggested a combined approach of options 1, 2 and 3 as is felt that a joined up approach should be taken to meet the strategic housing requirements of Whitehaven although, it is suggested here also that WE10 land North of Egremont Road represents a natural growth area.

Total respondents 6 Option 1: Concentrate development within the existing boundary 3 Option 2: South Whitehaven 0 Option 3: South East (north of Egremont Road) 0 Option 4: North East (Harras Dyke) 0 Option 5: North (Bay Vista/Brisco Bank) 0 Combination of 1, 2, 3 3

16 15. Which option(s) do you support regarding the directions of growth for Egremont (P33/34)? Three respondents suggested that option 2 to concentrate extension in particular directions is the preferred approach with the release of greenfield land to enable adequate sites to deliver the town’s housing requirements. One respondent reiterated that they are against the allocation of EG10 Egremont further north as it would be an unacceptable northern extension of Egremont towards Woodend and does not fit with the organic growth of the settlement pattern of the town.

Total respondents 2 Option 1: Continue the approach of the 2006 Local Plan 0 Option 2: Concentrate extension in particular directions 2 Option 3: Look for a package of sites distributing development around the 0 town General Comments 0

16. Which option(s) do you support regarding the directions of growth for Cleator Moor (p35/36)? Two respondents preferred option 1 to allocate a package of sites in and next to the existing built up area and support the green gap recommendation to ensure Cleator and Cleator Moor remain separate physical settlements. For one respondent option 1 is the preference to closing the Jacktrees Road link to Cleator. The respondent further states that part of CM1/CM2 land adjacent to Mill Hill phase 1 and 2 is a reclaimed waste tip and should not be disturbed. One respondent suggests option 2 to accept allocations of land along Jacktrees Road/Cleator Gate, connecting Cleator Moor to Cleator as the preferred approach as it is acknowledged that this area is most likely to be developed in the future. One respondent suggests a combination of options 1 and 2 as it is felt that a planned approach should be taken when providing housing within Cleator Moor. Again it is put forward that established boundaries would ensure separation is maintained between Cleator Moor and Cleator without any visual cohesion occurring. Furthermore, it is suggested that the proposed Green Gap should be amended to address site specific comments made in relation to sites.

17 Total respondents 5 Option 1: Allocate a package of sites in and next to the existing built-up area 2 Option 2: Accept allocations of land along Jacktrees Road/Cleator Gate, 1 connecting Cleator Moor to Cleator Option 3: Extend the development boundary towards the River Ehen 0 Option 4: Extend westwards towards Galemire Combination of 1 & 2 1 General Comments 1

17. Which option(s) do you support regarding the directions of growth for Millom (p36)? Two respondents commented on this question with the first putting forward option 3 ‘moderate expansion’ as the preferred approach stating that the proposed moderate expansion of Millom will require all the housing sites identified to be delivered, including sites MM2 land adjacent to Lowther Road Estate and MM3 Moor Farm. Whilst offering no preference around options the second respondent made a general comment about ensuring the protection of hedgerows which lie within the proposed development sites.

Total respondents 2 Option 1: Continue with the previous policy 0 Option 2: Concentration 0 Option 3: Moderate expansion 1 General Comments 1

18 18. Which option(s) do you support regarding the directions of growth for Arlecdon/Rowrah (p37)? Two respondents commented on this question with one having no objections to the allocations put forward and the second stating that option 3 to allocate selectively, giving potential for growth should be considered as, option 1 to allocate land only within the 2006 settlement boundary is deemed to be too restrictive.

Total respondents 2 Option 1: Allocate land only within the 2006 settlement boundary 0 Option 2: Allocate all the land that has been proposed for development and 0 meets the requirements to make it suitable for development Option 3: Allocate selectively, giving potential for growth 1 General Comments 1

19. Which option(s) do you support regarding the directions of growth for Beckermet (p37/38)? No preferred options are proposed for Beckermet although one comment stated no objection to the housing allocations proposed, but do not support the possibility of the employment allocations SES3a/SES3b Beckermet Industrial Estate as this is deemed an isolated location in attractive open countryside. It was also highlighted that an allocation here would be contrary to Core Strategy Policy ST1.

Total respondents 1 Option 1: Allocate sites within the village boundary 0 Option 2: Allocate Be2 additionally 0 Option 3: Allocate Be6 (probably in part) if its constraints can be dealt with 0 General Comments 1

19 20. Which option(s) do you support regarding the directions of growth for Cleator (p38)? Two respondents support option 1 to allocate the sites as proposed, with development on the Kangol land as, this is deemed to be good use of brownfield land and viable housing sites. It is felt that this chapter was overtaken by other events, e.g. Planning permissions granted at Cleator Mills and was noted that any larger scale of development in Cleator would undermine the sustainable approach for larger settlements and would be contrary to the adopted Core Strategy and NPPF. Option 3 to retain the existing settlement boundary around Jacktrees Lane is the preferred option for Cleator Moor Town Council who suggested that councillors wish to preserve the green space between Cleator Moor and Cleator on Jacktrees Road and do not wish to see the areas joined by development. One respondent opted for option 4 to release more land as the preferred approach stating that the ‘Possible Green Gap’ should be retained if it does not restrict development on Site CL2 Jacktrees South by the incorrect positioning of this designation. Furthermore, it is put forward that the boundaries of the Green Gap should be reconsidered and either be moved north to follow the development limits of Cleator Moor or be reduced in size to allow further development on sites such as CL2.

Total respondents 5 Option 1: Allocate the sites as proposed, with development on the Kangol land 2 CI3 Option 2: Restrict development in the Cleator Mills area to the existing 0 brownfield sites Option 3: Retain the existing settlement boundary around Jacktrees Lane 1 Option 4: Release more land 1 General Comments 1

20 21. Which option(s) do you support regarding the directions of growth for Haverigg (p38/39)? No preferred options were submitted for Haverigg by respondents although one comment supports the Council on its position on the two sites (Ha2 Adj. Cricket Club and Ha3 Allotment, Willowside) not being suitable for allocation due to their location within flood zones 2 and 3.

Total respondents 1 General Comments 1

22. Which option(s) do you support regarding the directions of growth for Lowca (p39)? One respondent commented stating no objection to the proposed allocation but did not select a preferred option.

Total respondents 1 Option 1: Allocate this site 0 Option 2: No allocations 0 General Comments 1

23. Which option(s) do you support regarding the directions of growth for Moor Row (p23)? One respondent stated that they have no objections to the housing allocations proposed but with the exception of Mr6 North Station Yard stating that the development of this greenfield site with wet flushes is unacceptable in landscape terms. It was also stated that given the expansion of the West Lakes Science Park proposed allocations and its proximity with Moor Row, development any further north than the brownfield site would be detrimental to the village’s distinctive identity. In terms of the proposed expansion of West Lakes it is recommended by one respondent that allocation MR10 Adjoining Scalegill be excluded again to avoid merging with Moor Row.

21 Total respondents 1 Option 1: Small scale growth 0 Option 2: Medium growth 0 Option 3: Major growth 0 General Comments 1

24. Are there any other Local Centre villages that you think are suitable for small scale growth? Four respondents commented with general support for not allocating the listed areas for small scale growth although one respondent commented that Frizington requires additional housing to support local services. One respondent suggested that Th1 South of Thornhill is acceptable around the playing field, but in landscape and scale terms is considered to be unacceptable in the second field to the south east of the existing settlement and as such, is recommended that this site be reduced in size and area accordingly. A further comment made suggested that some growth should be allowed within smaller settlements in order to ensure that they maintain the services and cross-section of age groups ensure to their viability and vitality going into the future. A more detailed response focused on Ennerdale Bridge and St. Bees whereby it is suggested that any development in both locations should be restricted to within the existing settlement boundary.

Total respondents 4

25. Should any of the following alternatives be considered rather than extending settlement boundaries? Of five respondents one suggested that option 1 Summergrove/Galemire area could be an alternative as there are no advantages in additional development in the Galemire area. Three respondents suggested that option 3 to utilise unused employment land would be a suitable alternative as brownfield development should be utilised as far as possible. A further comment recommends greater focus is placed upon re-using previously developed land (Policy ST1, iv) and Strategic Objective 20) for the next stage of allocations.

22 Total respondents 5 Option 1: Summergrove/Galemire area 1 Option 2: The area West of Moor Row 0 Option 3: Utilise unused employment land 3 Other 0 General Comments 1

26. Do you have any comments or suggested amendments to make regarding the proposed Policy SA3: Settlement boundary review? Ten respondents put forward comments with the majority in support of proposed Policy SA3 but with suggested amendments. One respondent suggested that boundaries should not be altered until development has reached capacity within the settlement boundary. A second respondent suggested that windfall development sites within settlement boundaries should be considered on their merits. A suggestion was made by a separate respondent stating that the ‘possible green gap’ should be retained if it does not restrict development on site CL2 Flosh Meadows 2 and that the boundaries of the green gap should be reconsidered to allow further development on sites such as CL2 Flosh Meadows 2. Another respondent put forward that the land to the south east of Whitehaven represents a natural extension to the urban area and the need for a specific wildlife corridor should be assessed. It was suggested that provision should be made to allow development to support Local Centre Villages, which would be more than just exception sites, for the purpose of encouraging a mix of housing types to meet the needs of residents. Two respondents suggest that the proposed review is considered limited as it only seeks to provide sufficient development land until the end of the plan period and that this does not provide any long-term certainty for the community or development industry. The respondents propose that additional land should be considered to provide development opportunities beyond the lifetime of the plan. A final comment suggests that Egremont could accommodate a number of sites to help meet the borough’s housing needs and demands before the Council will need to ‘look elsewhere’ for development opportunities.

Total respondents 10

23 Ensuring a steady supply of housing 27. Which option do you prefer regarding the release of land for housing (p43/44)? Of nine respondents one suggested that option 1, overall phasing by year or plan phase, would be the preferred approach as it offers the Council more control. Five respondents preferred option 2 of no phasing as it is suggested that house builders are best placed to manage housing delivery rate on development sites and that such flexibility will allow developers to respond to market signal and will not needlessly constrain housing delivery. The general comments put forward by respondents broadly agreed with option 2 and reiterated that housebuilders are best to dictate housing delivery.

Total respondents 9 Option 1: Overall phasing by year or plan phase 1 Option 2: No phasing – allow developers to develop sites as they please 5 Other 0 General Comments 3

28. Do you have any comments or suggested amendments to make regarding the proposed Policy SA4: Phasing of land release for housing delivery? One respondent offered full support for the proposed policy with four respondents in general agreement but with suggestions including rewording or additions to the policy around meeting housing requirements; release of affordable housing at a rate comparable to the development; monitoring; and the suggestion that producing an Supplementary Planning Document (SPD) would be inadvisable and contrary to the National Planning Policy Framework.

Total respondents 5

24 29. Which option do you prefer regarding flexibility of uses when allocating sites (45/46)? Of six respondents who submitted comments one respondent preferred option 1 to allocate all sites for a specific use for the reasons outlined in the Site Allocation and Policies Plan. Two respondents preferred option 2 to allow a mixed use anywhere as it is considered that there is no need to restrict uses of sites. Other comments suggest that option 2 should be the preferred approach where developments do not compromise the ability of a settlement to fulfil its contribution to maintaining local housing supply and that mixed use should exclude housing in town centres as it could make town centres less viable.

Total respondents 6 Option 1: Allocate all sites for a specific use 1 Option 2: Allow mixed use anywhere 2 Other 3 General Comments 0

30. Do you have any comments or suggested amendments to make regarding the proposed Policy SA5: Mixed Use development? Three respondents commented here stating that option 2, to allow mixed use anywhere, is generally supported but that mixed use should exclude housing in town centres as it could make town centres less viable. In a separate comment a conflict is identified within the plan: by including a general reference to ‘Opportunity Sites’ there are only some of these sites which are suitable for a particular use or quite narrow range of uses especially regarding Tourism Opportunity Sites. It is also considered that criteria D can and should be removed from the policy as relevant guidance is given in Figure 3.4 and is cross-referenced in Policy SA6.

Total respondents 3

25 31. Which option do you prefer regarding the allocation of sites as Opportunity Sites (p48)? Four respondents agreed with the Council’s preferred approach of option 2 no use- specific allocations – make all sites ‘Opportunity Sites’ as it is considered that these sites need to be improved and upgraded.

Total respondents 4 Option 1: No opportunity sites 0 Option 2: No use-specific allocations – make all sites ‘opportunity sites’ 4 Other 0 General Comments 0

32. Should we look to specify a particular use for any of the Opportunity Sites in Figure 3.4 ‘Proposed Opportunity Sites’? Two respondents commented that yes, the plan should specify a particular use for any of the Opportunity Sites including CMC Market Street site as Cleator Moor should not be allocated as housing as there is no economic argument for flats or homes at this location. It is recommended to allocate sites WT51, WT52 and WT53 Bus Depot and Station for leisure, restaurants and retail to provide a mix of things along the harbourside and the entrance into town. One general comment was put forward that any future development of the opportunity sites must respect adjacent land use and should be designed to complement existing development and allocated sites. One respondent suggested that no, particular uses should not be specified and that any improvements should be looked into e.g. a hotel and cinema is required for the town.

Total respondents 5 Yes 2 No 1 General Comments 2

26 33. Are there any additional sites that should be allocated as Opportunity Sites in Figure 3.4 ‘Proposed Opportunity Sites’? Two respondents proposed additional sites with the first focusing on the re-allocation of a de-allocated site WP5 Newdale Yard, Low Road and the second respondent suggesting land off Jacktrees Road incorporates the council car park and the old garage site and that the adjacent land should be a car park to support business and retail growth in the town centre.

Total respondents 2

34. Do you have any comments or suggested amendments to make regarding the proposed Policy SA6: Opportunity Sites? There is general support for this proposed policy from the four responses received and it was put forward by one respondent that CMC Market Street in Cleator Moor should not be allocated as housing due to there is being economic argument for flats or homes. A second respondent stated that due to the potential viability implications associated with the delivery of Site EG10 Egremont further north: a mixed ownership site, it may be considered beneficial to support the future development of the site for a range of uses. St Bees Parish Council put forward a general comment in response to this question stating that a cinema complex is needed as well as a good quality hotel. Total respondents 4

Tourism

35. Which approach do you support regarding Tourism Opportunity Sites (p49)? Of five respondents two opted for option 1 to increase the range of uses that could be encouraged for the Tourism Opportunity Sites, for the reasons outlined in the Site Allocations and Policies Plan. Two respondents preferred option 2 to do without Tourism Opportunity Sites yet one respondent made reference to West Lakes Extreme as it is a site now agreed in principle with an option to purchase. It was also stated that the name Tourism Opportunity Sites in itself is somewhat confusing as they mostly cover areas, are not site specific and rural tourism opportunities are often

27 enjoyed without the need for ‘development’ subject to planning permission. It is suggested therefore that in the absence of specific proposals Tourism Opportunity Sites should not be included within the allocations plan. One general comment was submitted highlighting an inconsistency with reference to Site C – the Whitehaven Coastal Fringe as, despite what is mentioned in the plan there has been significant progress with achieving the aims of the Colourful Coast in respect of Site C.

Total respondents 5 Option 1: Increase the range of uses that could be encouraged in the TOSs 2 Option 2: Do without TOSs 2 General Comments 1

36. Do you have any comments or suggested amendments to make regarding the proposed Policy SA7: Tourism Opportunity Sites or the special character of the Tourism Opportunity Sites?

Two respondents agree with the content of the policy and one respondent recommends that the policy is deleted but does agree with the safeguards in this policy to protect the special character of these areas as well as the exclusion of open market and having business use development. It is also suggested that sustainable modes of travel are a necessary addition to the wording of the policy given the nature of tourism/leisure uses and which would help achieve Policy ST1. A further objection to the policy is based on the policy suggesting that the three bullet points at the end apply equally to all of the four Tourism Opportunity Sites. However, it would be inappropriate to consider rural exception housing development or business use for Site C the Whitehaven Coastal Fringe for example. Furthermore, it is stated that whilst it is recognised that a wider range of uses might be possible on the former Marchon part of Site C, the distinction should be made clear in the policy wording itself.

Total respondents 4

28 Retail and Town Centres 37. Which option do you support regarding Whitehaven town centre (p52/54)? One respondent suggested option 3, to extend the boundary to take in North Shore Road, as the preferred approach but offered no explanation as to why. Three respondents opted for option 4 to extend the boundary southwards, as it is felt that the town centre is too constricted. One respondent suggested a combination of both options 3 and 4 - option 3 as, whilst the Council’s preferred option is option 4, it is believed that the transformation of Whitehaven needs to be driven and encouraged by providing appropriate inward investment opportunities at both its northern and southern gateways.

Total respondents 4 Option 1: Consolidate by drawing in the town centre boundary 0 Option 2: Leave the boundary as it is 0 Option 3: Extend the boundary to take in North Shore Road 1 Option 4: Extend the boundary southwards 3 Option 5: This area could, alternatively, be designated as a ‘town centre 0 fringe’ zone Combination of 3 & 4 1 General Comments 0

38. Which option do you support regarding Cleator Moor town centre (p54/55)? Two respondents support the Council’s preferred option 1, to leave the boundary as it is, for the reasons outlined in the Site Allocations and Policies Plan. One respondent preferred option 2, to consolidate by drawing in the town centre boundary, as it is felt that the existing boundary is not fit for purpose and has too many vacant shops suggesting an oversupply which should be rationalised and some uses to be restricted.

Total respondents 3 Option 1: Leave the boundary as it is 2 Option 2: Consolidate by drawing in the town centre boundary 1 Option 3: Extend the boundary 0 General Comments 0

29 39. Which option do you support regarding Egremont town centre (p55)? Two respondents commented that option 1, to leave the boundary as it is, would be the preferred option for the reasons outlined in the Site Allocations and Polices Plan.

Total respondents 2 Option 1: Leave the boundary as it is 2 Option 2: Consolidate by drawing in the town centre boundary 0 Option 3: Extend the boundary 0 General Comments 0

40. Which option do you support regarding Millom town centre (p55/56)? One respondent supported option 1, to leave the boundary as it is, yet offers no explanation of why this is their preferred option. A second respondent supports the Council’s preferred option 2 to, consolidate by drawing in the town centre boundary, for the reasons stated in the Site Allocation and Policies Plan.

Total respondents 2 Option 1: Leave the boundary as it is 1 Option 2: Consolidate by drawing in the town centre boundary 1 Option 3: Extend the boundary 0 General Comments 0

41. Do you have any comments or suggested amendments to make regarding the proposed Policy SA8: Town Centres and retail development? did not have anything to add here and one respondent commented that there is nothing to add based upon the adoption combining options 3 (to extend the boundary to take in North Shore Road) and 4 (to extend the boundary southwards) for the extension of Whitehaven Town Centre.

Total respondents 3

30 Green Infrastructure

42. Which option do you support regarding the amount of green space designated in the Local Plan (p58)? The preferred option for four respondents is to retain the existing supply of protected green space as the green space allocations in the 2006 Local Plan have proved sound; is of particular value to the quality of life of both residents and employees and; enhances the character of several Copeland settlements. It is also suggested here that more green space be designated where it can support wider functions e.g. as part of a network of green infrastructure. Three respondents preferred the approach to designate more protected green space particularly in areas such as Cleator Moor and Cleator and three respondents prefer the approach of releasing some protected green space for development as flexibility to deliver much needed growth should not be constrained by rigid protection of all green space.

Total respondents 11 Retain 4 Designate 3 Release 3 General Comments 1

43. Do you support the principle of Green Gaps? Three respondents suggest that yes, the principle of Green Gaps at Cleator Moor/Cleator only is preferred for the reasons stated in the Site Allocations and Policies Plan. Two respondents agreed to Green Gaps at additional locations as there is concern that, with the exception of Cleator Moor/Cleator, the allocations plan as a whole has not evaluated green gap provision more strategically and it is considered that this approach has considerable merit in maintaining the separate identity of different settlements and ensuring that they do not merge into one another. One respondent preferred for the idea of Green Gaps to be abandoned as the extent of Green Gap proposed at Cleator Moor would adversely affect the provision of a sustainable extension to the settlement. Whilst the principle of some Green Gap is not objected to the extent proposed, it is suggested, needs to be reassessed as

31 existing features suggest a smaller area would achieve the policy objective whilst also enabling an appropriate form of development. One respondent states that there is no justification available as to what land should be included in the Green Gap to help the respondent understand the Council’s justification for the current boundary.

Total respondents 7 Yes, at Cleator Moor/Cleator only 3 Yes, at additional locations 2 No 1 General Comments 1

44. Do you have any comments or suggested amendments to make regarding the proposed Policy SA9: Green Infrastructure?

Three respondents supported the proposed policy stating that this approach has considerable merit in maintaining the separate identity of different settlements and ensuring that they do not merge into one another. One respondent objected because it is considered that the extent of Green Gap proposed at Cleator Moor adversely affecting the provision of a sustainable extension to the settlement. Other more general comments on the proposed policy state that it should be revised to allow for flexibility in approach reflecting the need for a reasoned release of green space where appropriate and the policy wording should include reference to wildlife corridors.

Total respondents 8

32 Infrastructure

45. Which opinion do you support regarding safeguarding/reserving land for the provision of infrastructure (p60)? One respondent suggested that option 2, to abandon the proposal, is their preferred option as the road proposal is felt to be highly unlikely to be confirmed in principle with no funding commitment and therefore should not be included within the plan or be material in identifying potential land allocations in this part of Whitehaven. Four respondents’ preferred approach is option 3 to provide for other infrastructure projects in this policy as improvements are welcomed and it is considered key to improve the A595.

Total respondents 5 Option 1: Redraw the road line 0 Option 2: Abandon the proposal 1 Option 3: Provide for other infrastructure projects in this policy 4 General Comments 0

46. Do you have any comments or suggested amendments to make regarding the proposed Policy SA10: Reservations for infrastructure proposals? One respondent agreed to the inclusion of the policy for the reasons outlined in the Site Allocations and Policies Plan. Another objected to the inclusion of the policy and recommended its deletion. General comments submitted related to the policy not reflecting the preferred option in Q45 above as it offers no flexibility within the policy along with the suggestion that there is a need to develop and improve the Cockermouth to Egremont Road to relieve traffic.

Total respondents 4

33 Other issues/comments 47. Do you have any final comments? One respondent commented on coal resources and coal mining legacy which is referred to in the Core Strategy and Development Management Policies document and the NPPF but which, specifically the matter of unstable land and mineral sterilisation, is not referred to in the site allocations sustainability appraisal. A second respondent identified inconsistency in a number of the proposed allocations in that in some of the settlements, proposals are noted as being too small for allocation yet sites of the same size or smaller have been accepted elsewhere. Two comments were made on the arrangement and consistency of the plan in terms of incorrect referencing which makes the plan confusing when looking at site allocations. Furthermore, that there are a number of omissions from the Site Allocation and Policies Plan which should be considered in the next stage of work towards the adopted plan. These include consideration around St Bees Heritage Coast; a comprehensive plan for Whitehaven; the undeveloped coast; marine conservation zone; the draft West Whitehaven SPD; biodiversity; objectives for environmental protection and enhancement; the Shoreline Management Plan (SMP); and coastal access. One respondent identified that reference is made in the plan to the use of the Lake District definition “that is in the context of a policy environment where only affordable housing is permitted…” which is incorrect. The Authority’s approach to housing provision seeks to address identified housing market imbalances by maximising the opportunities presented by individual development sites to provide local needs and local affordable needs housing. One suggestion related to those sites with existing or previous expired/extant permissions which should be subject to additional analysis, as market interest is an important factor in delivery and should not be underestimated. Finally, a suggestion was made to allocate the West Cumberland Hospital site, including the land off Sneckyeat Road, to support the continued investment in the hospital as well as the redevelopment of some land to the south west of the site which is expected to become surplus and would be most suited to a mix of uses from retail to residential.

Total respondents 11

34 3.3 Sites Proposed for Allocation

The sites listed in the Sites Proposed for Allocation chapter of the Site Allocation and Policies Plan consultation document have been identified through the following processes:

. Previous allocation in the 2006 Local Plan . The Strategic Housing Land Availability Assessment (SHLAA) . Separate proposals by developers, landowners and others . In Whitehaven, sites referred to in Supplementary Planning Documents (SPDs)

The chapter asked respondents which of the sites are the most appropriate sites to meet the needs of Copeland’s communities over the next 15 years. The recommendations for each site are explained in the Site Assessment Reports accompanying this Development Plan Document which can be found on our website Site Assessments.

411 Site Comment Forms were submitted to the consultation and the paragraphs below provide a summary of the comments submitted on those sites proposed for allocation. Areas are split into town centres, local centres, smaller villages, other proposed employment/economic development and sites in small villages and countryside.

The following provides a very brief indication of the comments received for individual sites in each of the settlements in turn.

WHITEHAVEN

Strategic Sites

. General support for employment generating development with one objection regarding the presence of two listed buildings.

Employment Sites

. Comments received referred to sites including or being close to Scheduled Ancient Monuments and/or listed building/s. . OS3 Hensingham Common: forms part of the proposed electricity infrastructure – North West Coast Connections Project.

35 Whitehaven Pow Beck

. There was an objection to the de-allocation of WP5 Newdale Yard Low Road as it is considered that the site, largely brownfield, provides a logical extension to the local residential housing stock, is relatively unconstrained and development would not affect cultural assets.

Town Centre

. Sites include or are close to Scheduled Ancient Monuments and/or listed buildings and within the conservation area. Support is shown for redevelopment of town centre uses for the bus depot, bus works and bus station.

Whitehaven West (Kells)

. WW5 Former Rhodia Offices: support, subject to the alteration that the southern and northern part of the site should be allocated with roll out between 0-5 years and to ensure the continued protection of the Colourful Coast at WW4 St Mary’s School.

Whitehaven South (Woodhouse/Mirehouse)

. WS2 Woodhouse Road: one comment from a housebuilder supporting the site for housing as it is viewed that the site provides a logical extension to the local residential housing stock and is in an accessible and sustainable location. . WS3 Old Welfare Home: one comment of support from a housebuilder supporting the allocation of the site for housing as it is considered that the ‘brownfield’ site provides logical extension to the local residential housing stock and is in an accessible and sustainable location. . WS4 Woodhouse Road WS2/St. Bees Road: a large number (65) of objections were received to the allocation of this site for Gypsy & Traveller use due to reasons of gradient of land; access; environment; crime; impact upon local services; perceived surplus council tax costs; proximity between two existing housing estates; community unrest; lack of evidence; impact upon tourism; and the site being too close to the St. Bees Heritage Coast.

36 Whitehaven East

. WE10 Egremont Road: forms part of the proposed electricity infrastructure – North West Coast Connection Project route. One comment was received in support of the allocation subject to a proposed alteration to include the land beyond the southern eastern boundary of Whitehaven within the allocation.

Whitehaven Highlands

. WH11 Harras Dyke Farm 2: concern from 13 respondents around the impact upon existing scenery; potential general disruption and the suitability of the ground; continued access to and availability of an existing footpath; extension into the countryside; threat to biodiversity, impact upon service infrastructure; impact upon the character of the area, safety, drainage and transport.

Whitehaven North

. WN1 Adj. Bay Vista Elizabeth Crescent (WN1): an objection was raised concerning continued safe access on perceived unsuitable narrow and steep residential roads. An additional comment was put forward relating to the perceived ambiguity of the consultation document. . WN2 North East Bay and WN3 Adj. Bay Vista Victoria Road: objection as to why one site is allocate when the other is not. It is stated that there are similar constraints affecting both pieces of land. . WN3: suggestion that the site be re-considered as a possible housing allocation. . WNY7/WN9 Brisco Bank, Quality Corner (Rannerdale Drive): objection on the grounds of the site being substituted with WN1 Adj. Bay Vista Elizabeth Crescent, with perceived less landscape impact and being more compliant with the objectives of the Core Strategy.

CLEATOR MOOR

. CM13 Leconfield Industrial Estate: employment generating site supported but also with an objection due to the site being opposite a listed building which is on the at risk register. . CMC Market Street: objection due to the site being near a listed building. . CM6 Dentholme Road: objection due to the site being near a listed building. . CM7 Market Street: objection due to the site being near a listed building.

37 . CM9 High Street: objection stating that the allocation should not be changed from being available to develop on its own merits to possible urban greenspace protection.

. CM10 Ex allotments at Crossfield Road: boundaries are unclear and question as to whether the whole site is allotment or green field agricultural land. . CM13 Leconfield Industrial Estate: one objection due to the site being near a listed building as well as general support. . CM14 Frizington Road West: objection with a recommendation that a Geological survey be undertaken before any development should be considered. . CM20 Ennerdale View: support for allocation. . CM30 Land off Trumpet Road: two objections stating that this site is suitable for housing and should be allocated as such, as the reason for unsuitability relating to landscape is perceived incorrect due to landscape assessments which have been undertaken on this site suggesting otherwise. . CM31 Jacktrees North: support subject to alteration as the land shown is perceived to be more extensive than identified by the Council. . CM32 Jacktrees South: support subject to alteration as the land shown is perceived to be more extensive than identified by the Council. . CL2 Flosh Meadows 2: objection to the allocation of ‘possible green gap’ for the site on the basis of the site previously being deemed developable. It is considered that the exclusion of all parts of Site CL2 from the Site Allocations Plan removes a valuable housing site.

EGREMONT

. EGB Chapel Street: objection due to being located within a conservation area. . EG1 Gillfoot Mansion: extensive flood alleviation would need to take place and due to drainage concerns the site should only be subject to limited development. . EG3 How Bank Farm A: is considered unclear whether the site is to be allocated or excluded. . EG4 How Bank Farm B and EG5 How Bank Farm C: support as a logical extension of the town with attention drawn to extensive flood alleviation work that would need to be undertaken. . EG6 How Bank D, EG7 E and EG8 F: all with comments regarding perceived issues with non-allocation in terms of critical mass of development. It was put forward that the sites are logical extensions of the town with no constraints.

38 . EG9 Ashlea Road: no play area here, as stated in the consultation document. Possibly just green space. . EG10 Egremont further North: a known contaminated site . EG11 Land adjacent to Toll Bar House: ownership requires clarification. . EG12 St. Thomas’s Cross: accessibility of the site should be considered further as it does not look feasible in this location. . EG20 Sandholes East: potential access issues. . EG22 adjacent to Daleview Gardens: support for the most part but was noted that any development here could impact upon the setting of neighbouring Egremont Castle. . EG23 Gulley Flatts East: support on the basis that EG22 adjacent to Daleview Gardens is promoted for delivery in the plan period of 0-5 years and sites EG23 and EG24 Gulley Flatts West to follow in plan period 5-15 years allowing for continuity in supply. . EG31 Clintside near Egremont: three self-build sites opposed.

MILLOM (WITH HAVERIGG)

. MM2 Lowther Road Estate: support as development would represent a discrete extension to the settlement with no impact on the wider setting. . MM3 Moor Farm: National Grid wish to be kept informed of any development potential. Support is given to the allocation as it represents a discrete extension to the settlement with no impact on the wider setting. . MM4 CG Ashburner Compound: objected to on the grounds that the land is being used for 12 private garages. . MM17 Crook Field: support although confirmation is being sought from EA regarding flood zone risk.

LOCAL CENTRES:-

ARLECDON/ROWRAH

. Ar2 Arlecdon Road: consider allocation of site for housing to represent the most appropriate option to serve the settlements of Arlecdon and Rowrah during the plan period. . Ar3 Arlecdon Parks Road: support given as the site is viewed as a deliverable site with good access. . Ar7 Parks Road: objection on the ground of access; the A506; drainage/surface water and potential contamination.

39 . Ro2 Rowrah Hall Garage: concern raised as to why the site hasn’t been put forward in the site allocation and policies plan. It was also requested that the site be brought back into the village boundary. . Ro5 Chapel Row, Rowrah: support for the allocation of this site.

BECKERMET

. Be2 Crofthouse Farm: support given for allocation. . Be3 Hunter Rise: site is near a listed building and within a conservation area. . Be4 Adjoining Crofthouse Farm: support given for allocation . Be5 Barwickstead: accessibility should be considered fully before allocating this piece of land, land which is also opposite two listed buildings and within a conservation area.

BIGRIGG

. Bank End View (Bi2): no support for this sites but with suggestion that Bi3 W. extension Jubilee Gardens could be allocated to align with the boundary with Bank End View and Croftlands and allow for minimal development.

DISTINGTON

. Di1 Distington Hinnings Farm: the site is opposite two listed buildings and within a conservation area. . Di2 Distington Ennerdale View: support given for allocation. . Di3 Distington Kilnside: currently being used as public open space and any redevelopment should take this into account. . Di4 Distington Ennerdale Road/Barfs Road: support given for allocation. . Di11 Castle View: suggestion that the development boundary is redrawn to include Melrose land in order for it to be built on a windfall development in the future. . Di12 Former Concrete Depot: support given but conversely, a separate objection was received on the basis of further consideration required in terms of remediation requirements and impact on viability. . DiB Rear of Central Garage: land owner discrepancy. . DiC Furnace Row: support given for allocation.

40 FRIZINGTON

. Fr1 Lingley Fields Extension: five objections received on the basis of consequent increased house prices; wild life; greater flood risk; access concerns; trees, public transport; stability of existing housing and loss of privacy/overlooking and the impact upon the village.

LOWCA/PARTON

. Lo3 Solway Road: support for allocation. . Pa3 Whites Row: support for allocation.

MORESBY PARKS

. Mp1 High Moor Road, Mp2 Former housing Walkmill Close, Mp3 Bonny Farm, High Ghyll Bank, Mp4 Walkmill Close, Mp5 Dent Road, Mp6a Round Close (reduced site), Mp7 School Brow: all objected to on the basis of concerns around access; increased traffic and number of residents; flooding; drainage and sewage; impact upon views; impact upon primary school; extending into the greenbelt/loss of agricultural land and urban sprawl, although individual support was also given for most of the sites listed above too.

MOOR ROW

. Mr2 Rear of Clarack House, Mr3 Rear of Social Club, Mr5 Adjoining Scalegill Road, Mr6 North Station Yard, Mr7 Adjoining Scalegill Hall, Mr8 Allotments rear Penzance Street and Mr9 Scalegill: all objected to on the basis of concerns around access; increased traffic and number of residents; flooding; drainage and sewage; impact upon views; impact upon primary school; extending into the greenbelt/loss of agricultural land and urban sprawl, although individual support was also given for sites Mr2 Rear of Clarack House, Mr3 Rear of Social Club and Mr6 North Station Yard also. . Mr4 Hollins Farm: the site is included in the draft final SHLAA (2013) but does not appear in the preferred options plan anywhere without any explanation provided. Furthermore, the site is not suitable for agricultural yet is suitable for a single storey dwelling. . Moor Row: a general question was posed asking how the plan addresses the difficulties of Moor Row and the why the changes in allocations map of 2006 allocation plan on page 6 have not been explained.

41 SEASCALE

. Se1 Links Crescent: support for allocation. . Se7 Black How: support for allocation. . Se2 Town End Farm East: support but with suggestion that the site should be a priority for any sheltered housing plans. A separate objection due to lack of direct access onto the public highway. . Se3 Croft Head Road: noted that the site was given planning permission in 2008 yet without any delivery on site and, as such, marketability of the site is questioned. . Se5 Fairways Extension: reference made to foul drainage issues yet Persimmon Homes, Lancashire, being the freehold owners of the site, are not aware of any such obstacles.

ST. BEES

. Sb3 Abbey Road 2: noted that land coloured red here is incorrect and should be allocated as housing land with planning permission. . Sb8 Abbots Court Field: support given subject to the alteration that the land is appropriate as a short term development opportunity and should be brought forward for this purpose. A separate comment stated that the development of the land offers the opportunity to provide housing land attractive to the market with no technical issues precluding the development of land.

THORNHILL

. Th1 South of Thornhill: question was raised about what “only part” of refers to and that support for development should only be allowed on the premise that the site would only extend to a point in line with the southern boundary of the playing field. In separate comments received issues were raised around the impact of local services in isolated areas such as Thornhill, in terms of losing such services as the volume of users will not be high enough to support them even with further development.

OTHER PROPOSED EMPLOYMENT/ECONOMIC DEVELOPMENT

. SES3a Beckermet Industrial Estate and SES3b Beckermet Industrial Estate: objections on the basis of development here being too large; out of proportion and incongruous with the surrounding rural landscape; remote from public transport and accessed at an unsafe part of the A595. It was put forward that existing buildings on the estate

42 have already had a severe detrimental effect on the landscape and has resulted in an increased volume of traffic. . WA Haig Enterprise Park: objection due to proximity to a scheduled ancient monument and a listed building. . CMA Leconfield Industrial Estate: support and objection with the latter concerning proximity of the site to a listed building which is on the at risk register. It was proposed that site assessments identify the historic environment here and proposals mitigation measures to minimise harm. . CMC Market Street, TOS3 Whitehaven Coastal Fringe and WT12 YMCA/Steve’s Paints: also noted for proximity to a number of listed building and their location within a conservation area and again, as such it is suggested that site assessments should identify the historic environment and proposals to minimise harm. . T0S1 Hodbarrow and T0S4 Lowca: the full site boundary of these sites have not been able to be located and therefore comments cannot be presented either for or against. . WT24 Cockpit, WT25 BT Depot, WT33 Harbour View and WT34 Rosemary Lane: support given for allocation of all sites.

SITES IN SMALL VILLAGES AND COUNTRYSIDE

. OC18 Land North West of existing development bound by the Rheda estate boundary and OC19 Rheda Park Frizington: it was highlighted that the sites are shown not to be allocated in the plans attached to the document but are referenced in Appendix 1. . VS6 Land at Low Moresby: objection due to the reasons for exclusion of the land including access and landscape access being considered unjustified. It is argued that appropriate access can be achieved and that development on the site would pose no/limited landscape impact.

43 3.4 New Site Submissions 55 new sites were submitted: 21 from private landowners, 15 from a public land owning body, 10 from planning consultants, 3 from developers and 6 from others. Of the 55 responses 35 respondents stated that they own the site, 14 stated that they did not own the site and 6 respondents did not state whether they owned the site or not.

The majority of respondents stated a proposed preferred use followed by a proposed alternative use for their new site submission. Housing is a common theme throughout the site submissions under the ‘proposed preferred use’.

New site submissions are available to view in detail in the separate appendices of this report.

3.5 Sustainability Appraisal English Heritage was the only respondent commenting on the Sustainability Appraisal (SA) consultation document and, for the most part, their comments were to disagree with the SA score given to allocated sites.

The SA score of 25 sites (including SES1 Westlakes Science and Technology Park; TOS3 West Whitehaven Tourism Opportunity Site; WA Haig Enterprise Park; WT12 YMCA/Steve’s Paints; WT15 Former Foundry; WT16 Timber Yard/TA Centre; WT31 Car Park Quay Street East; WT32 Car Park Quay Street West; WT41 Mark House; WT42 Marlborough Street; WT43 Duke Street/Tangier Street; WT51 Bus Depot; WT52 Bus Works; WT53 Bus Station; WT61 Garage and Workshops; WT62 Cumbria Electrical; CMA Leconfield Industrial Estate (also CM13); CMC Market Street (see also CM7); CM6 Dentholme Road; CM7 Market Street; EGB Chapel Street; EG22 Adj. Daleview Gardens ; BE3 Hunter Rise; BE5 Barwickstead; and Di1 Distington Hinnings Farm) were disagreed with and considered that development would not harm any heritage resource and could be used to enhance significantly the landscape or an asset or its setting. It was also stated that each proposed allocation had not been accompanied by identification of heritage assets, an assessment of the historic environment and the impact that the proposed allocation will have on its significance.

English Heritage also suggested that the proposed policy SA1 does not ensure that the allocation of sites is in accordance with adopted strategic policies and will safeguard the significance of heritage assets and their setting through ensuring their conservation and enhancement. Furthermore, as with the above proposed allocated sites, the Plan has not been accompanied by identification of heritage assets.

44 A general statement on surface water and water quality was added advising that the preferred options process provides an opportunity to explore strategic infrastructure requirements with the aim of limiting environmental issues at the project stage and that if further detail on expected infrastructure can be provided at this stage it would help to provide certainty that housing can be delivered during the plan period.

Further engagement with United Utilities, the Environment Agency and Cumbria County Council is encouraged with respect to proposed growth and required infrastructure; further clarification is required to rule out effects as a result of water pollution and that the unresolved uncertainties in the SA should be explored further in the next iteration of the SA as avoidance and/or mitigation measures may be required in order to reduce harm to the environment.

Finally, it is proposed that the SA should ensure that all effects are adequately assessed (including cumulative), and any additional effects arising from the site selection process that may not have been covered at the higher level in the Core Strategy SA are taken into account.

45 Appendix One: Sites without responses A number of sites have been considered within the Site Allocations and Policies Plan yet not all sites have received responses to. The tables below makes reference to those sites without responses.

Whitehaven Employment Sites Whitehaven Town Centre OS1 Ginns WT17 Joinery Works OS2 Pow Beck WT23 Former Sidings, Coach Rd WB Sneckyeat Road Whitehaven West (Kells) WC Red Lonning (excl. football pitch) WW1 Pondfield Garage WP1 Corkickle Goods Yard WW2 Kells School WP2 Recreation Ground WW3 North Row a WP3 Meadow View Whitehaven East WP3 Meadow View WE1 Garage Site Rutland Avenue WP4 Pottery Road WE2 Chapel House Whitehaven South (Woodhouse/Mirehouse) WE3 Egremont Road WS1 Land south of Marchon Car Parks WE4 Land at Overend Road WS5 Valley View Road WE5 Industrial Estate Sneckyeat Road WS6 Opposite Lakeland Avenue WE6 Homewood Road WS7 POS Woodhouse WE7 Sekers Factory Site WS8 POS Loweswater Road WE8 Moresby Parks Road WS9 Howgill Quarry WE9 New Monkwray WS10 Playground Whitehaven Highlands WS11 Greenbank P and M Club WH1 Harras Moor Stage 3 WS12 Wastwater Road, Woodhouse WH2 Red Lonning Stage 6 WS13 Land adj Kirkside Road WH3 Red Lonning WS14 Pillar Road/Steeple Close WH4 Standing Stones Whitehaven North WH5 Laurel Bank WN4 Play Area WH6 Highfields WN5 Alder Close Rannerdale Drive WH16 Highlands WN6 Rosemary Close WN7 Land to north east of Rannerdale Dr. WN8 East of Bay Vista WN10 Brisco Bank Farm WN11 Victoria Road/Red Lonning

46 Cleator Moor CM1 Adjacent Mill Hill (phase 1) CM25 Bowthorn Road CM2 Adjacent Mill Hill (Phase 2) CM26 Leconfield Extension CM3 Birks Road CM27 Whinney Hill north CM4 Garages, Jacktrees Road CM28 Whinney Hill south CM5 Ehenside School Site CM29 Adj 20Threaplands CM8 Methodist Church CM33 Mill Hill West CM11 Holden Place C1 Flosh Meadows CM12 Todholes Farm C3 Cleator Mills CM15 Columba Club C4 Kangol Land CM16 Adj. Job Centre, High Street C5 Former Kangol Works CM17 Conservative Club, High Street C6 Ehen Bank CM18 Frizington Road East C7 Adj. Ennerdale Hotel CM19 James Street Allotments C8 Croft House CM21 Vale View C9 Hilden Road CM22 Land by factory, Birks Road C10 Main Street CM23 Land at Aldby Place C11a Church Street CM24 Rear of Crossings Close C11b Cleator Gate Egremont

EGA Bridge End Extension EG19 Bridge End EG2 Former Orgill School EG21 Sanholes West EG13 Brisco Mount EG25 Egremont furthest south EG14 Chapel Street Car Park EG26 Land at Woodend EG15 High Mill EG27 Adj. Market Hall EG16 Former Council Depot, Chapel St EG28 Adj. Council Chambers EG17 Beck Green EG29 Rear of 33 Main Street EG18 Wyndham Terrace EG30 North of Pickett How

47 Millom (with Haverigg) Sites in small villages and countryside MMA Mainsgate Road Extension OC1 Field 5264, Waterloo Trc nr. Arlecdon MMB Devonshire Road OC2 Opposite St Johns Church nr. Bigrigg MMC Millom Pier OC3 Land ADJ. Shaw Farm nr. Bigrigg MM1 Devonshire Road OC4 Parkside nr. Cleator Moor MM5 Former Highways Depot, Millom Rd OC5 North Millhill Farm MM6 Adj. St Georges Hall OC6 Land at Galemire MM7 1-3 Market Square OC7 Adjacent to Couldeton Village MM8 Rear of Crown St Church OC8 Howgate site 1 MM9 Former Council depot Millom Road OC9 Howgate sites 2 MM10 Former Council Deport Holborn Hill OC10 South Park, Rheda nr. Frizington MM11 Adj Boundary Lane, Mainsgate Road OC11 Rheda Home Farm MM12 Mainsgate Road OC12 Rheda North Park MM13 Foundry Road Garage, OC13 Former opencast access, Round Close MM14 Bay Beck View OC14 High House/Brackenthwaite Wilton MM15 Stella Terra OC15 Moss Drift, Wilton MM16 Adj. Marsh House, Holborn Hill OC16 Cobra Castle, Wilton MM18 Rear of Fire Station VS2 Wray Head, Drigg MM19 Queen Street VS3 Beck Brow Farm, Haile MM20 Borwick Rails VS4 Land at Homrook MM23 Back of Gammerscroft VS5 Field 2271, Low Moresby Ha1 Poolside, Haverigg TOS1 Hodbarrow Other employment/economic development WB Sneckyeat Road WT11 Warehouse, Mill Street WT13 Albion Street WT14 Albion Street South WT63 Methodist Church Lowther Street WT63 Snooker Club WT65 Telephone Exchange

48 Local Centres Ar1 Garage Site Arlecdon Road Fr12 Rural workshops site Ar4 Adjoining Sun Inn Fr13 Allotments site, Frizington Road Ar5 Raltri (Barwise Row) Fr14 Lingla Bank Ar6 Arlecdon House Fr15 Lonsdale Farm Ar8 Off Arlecdon Parks Lo1 Allotments Solway Road Ro3 Pasture Road Lo2 Hodgson Pit Ro4 Chapel Row Pa1 Parton Brown Be1 Mill Lane Pa2 Fern Cottage Be2 Crofthouse Farm Pa4 Brewary Row Playground Be6 Off Braystones Road MP8 School Brown Be7 Sour Close Mr1 Station Yard Bi1 Adjoining Smithy Cottages Mr9 Scalegill Hall Bi3 W. extension Jubilee Gardens Mr10 Adjoining Scalegill Di5 Distington Barfs Road Mr11 Adj. Moor Row/Westlakes Di6 Distington Chapel Street Mr12 A595/Scalegill Road Di7 Distington rear of school Mr13 Land at Moor Row (Bline Lane) Di8 Distington 101 Main Street SeA Seascale Rural Workshops Di9 Distington Old Hall Se4 Swang Farm Di10 British Legion Car Park Se6 Rueberry Drive Ki1 Thistlegill Quarry, Kirkland Se8 Rear Wansfell Hotel FrA Frizington Road Workshops Se9 Cross Lanes Fr3 Opposite 187 Frizington Road Se10 Car Park, The Banks Fr4 Adjoining Avondale S21 Rear of Manx Horizon Fr5 Mid-Town Farm Sb2 Abbey Road 1 Fr6 Off Parks Street Sb4 Nethertown Road Fr 6 Garage site rear Council Sb5 Seacote Car Park Fr7 Council Chambers Sb6 Stonehouse Farm Fr9 Adjoining Glendarvel Sb7 Rear of Albert Hall Fr10 Chapel Autos Sb9 Fairladies South Fr11 Adj. 129 Main Street Th2 37 Thorntree Drive

49 Appendix Two: New Site Submissions

55 new site submission forms were submitted as part of the Site Allocations and Policies Plan consultation process with some those 55 respondents proposing more than one site. The table below makes reference to those new site submissions with detail on the preferred use and a proposed alternative use.

Location New Site Proposed Preferred Proposed Alternative Use Use Town Centres Whitehaven Land at West Cumberland Housing and/or None Hospital & Snekyeat Road, Employment and/or Retail and or other – car park Cleator Land off Crossfield Road Housing None Moor Land off Birks Road, Ennerdale Housing None View

Land at Montreal Street Housing Specialist Residential

Land Adjacent to The Ewe and Housing None Lamb, Padstow Land to rear of Birks Road Housing Specialist Residential

Land adjacent to Cleator Mills, Housing None Cleator Egremont Land off Gillfoot Park Housing None

Millom (with Land to the east of Moor Moss Employment and/or Tourism and/or Haverigg) Lane, Haverigg Tourism Education

Port Haverigg Car centre, Housing and/or Leisure and/or Haverigg Specialist Residential Community facilities

Poolside, Haverigg Road, Housing None Haverigg

Local Centres Arlecdon/ Land off Rowrah Road, Rowrah Housing None Rowrah Land adjacent to Housing None Raventsone/Copper Beeches, Rowrah

Beckermet Part Field No482 Beckermet Housing None

Sellafield, Land at Yottenfews Employment Other – Development Opportunity/Windfall Site

50 Location New Site Proposed Preferred Proposed Alternative Use Use Bigrigg 4 sites at Springfield Farm, Housing None Bigrigg, (field refs: 0655, 2540, 8435 and 9671

Parcel 1/2, Bankend View, Housing Specialist Residential Bigrigg (Land adjacent to 34 Bankend View) Parcel 2/2, Bankend View, Housing Specialist Residential Bigrigg (Land to front of 22 & 24 Bankend View) Distington Land at Hinnings Road Housing Specialist Residential

Car Park, Main Street Housing Specialist Residential

Frizington Land opposite Parkgate, Housing Specialist Housing Frizington Road and/or Employment and/or other – inclusion within the settlement boundary Land adjacent to Glendarvel and Housing Specialist Residential the bungalows, Frizington Road Kirkland House farm, associated Housing None outbuildings, farm buildings and adjoining land Fourmart Hill - Beak House Housing None enclosed Mill Yeat Lowca/ Land at Main Street, Parton Housing Specialist Residential Parton Land at Parton Brow Housing Specialist Residential

Land at East Road Housing Specialist Residential

Moresby Land High Moor Road Housing Specialist Residential Parks

Moor Row Former railway land Housing None

Land off Woodend Road Housing None

Land rear Dalzell St Housing Specialist Residential

Land to north east of Montreal Housing None Place Land to east of Montreal Place Housing None

Seascale Land adjacent to Seascale Housing None Workshop Land adjacent to Seascale Housing and/or None Workshop Employment

51 Location New Site Proposed Preferred Proposed Alternative Use Use Swang Farm, north west Seascale Housing None Land north of Acrelands, Housing None Seascale Wayside north east Seascale Housing None

Land adjacent to Bailey Ground Housing None east Seascale Land south of Seascale, adjacent Housing None to Coveness Bank Land at Bailey Ground Farms Housing None

St. Bees Slattery Lonning, High House Housing None Farm, High House Road

Quarry Field, High House Farm, Housing None High House Road Agricultural farm buildings and Employment Housing or Retail yard, High House Farm, High House Road Rear of Fairladies housing estate Housing None

Land Adjacent to Abbots Court Housing None

Foreshore car park and unused Housing Specialist Residential boundary land and/or Tourism Sites in small villages and countryside Lamplugh Land at Woodend Housing None

Land adjacent to Murton Farm, Housing None Crossgates

Land adjacent to Wood Beck, Housing None Crossgates Land to rear Lamplugh Tip Housing None

Land to South East of Crossgate Housing None

Land to South East of Mill House Housing None

Land adjacent to field ref: 8640 Housing None

52 Appendix Three: Site Allocations and Policies Plan Consultation Responses

To follow…

53