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Local Development Framework Consultation

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Responses to Development Management Policies DPD - Publication Stage
4 responses from Mrs Sylvia Woodhead, Cumbria GeoConservation
1. Mrs Sylvia Woodhead, Cumbria GeoConservation   :   28 Nov 2017 10:17:00
Policy Reference
DM1 - General Requirements for all development
1.1 Do you consider the DM DPD to be legally compliant?
Yes
1.3 Do you consider the DM DPD to be sound?
Yes
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Cumbria GeoConservation is a voluntary geological conservation group working to record and protect important Local Geological Sites (LGS) in Cumbria, formerly Regionally Important Geological Sites (RIGS). Cumbria GeoConservation seeks to make LGS better known to the public, and to ensure that their geological interest is not lost due to development and/or infilling.
We believe that this Plan is sound and legally compliant. However we believe that the changes requested below would strengthen the Plan.

We note with some concern that protection of geological sites is mentioned only on page 9, under Policy DM1, whose purpose is ‘to maintain, protect and promote the district’s environmental (and other) qualities’. While point 6 refers to ‘protection of biodiversity and geodiversity assets’, the lack of further mention in the Plan does little to help promote the area’s distinctive geological sites. While this policy should adequately ensure that geological sites are properly taken into account, we fear that this might not be happening.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
2. Mrs Sylvia Woodhead, Cumbria GeoConservation   :   28 Nov 2017 10:21:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes.
Appendices, Glossary or other
Appendix 2 - Kendal Canal Head Area Designations
1.1 Do you consider the DM DPD to be legally compliant?
Yes
1.3 Do you consider the DM DPD to be sound?
Yes
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Cumbria GeoConservation is a voluntary geological conservation group working to record and protect important Local Geological Sites (LGS) in Cumbria, formerly Regionally Important Geological Sites (RIGS). Cumbria GeoConservation seeks to make LGS better known to the public, and to ensure that their geological interest is not lost due to development and/or infilling.
We believe that this Plan is sound and legally compliant. However we believe that the changes requested below would strengthen the Plan.
As mentioned above, RIGS are now termed Local Geological Sites (LGS). We would be pleased if you could make this change in Appendix 2, in ‘land to be safeguarded’, under Environmental and Heritage Designations. If LGS could be added to the Glossary this would further help recognition of the need to protect geological sites.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
3. Mrs Sylvia Woodhead, Cumbria GeoConservation   :   28 Nov 2017 10:22:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes.
Appendices, Glossary or other
Glossary
1.1 Do you consider the DM DPD to be legally compliant?
Yes
1.3 Do you consider the DM DPD to be sound?
Yes
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Cumbria GeoConservation is a voluntary geological conservation group working to record and protect important Local Geological Sites (LGS) in Cumbria, formerly Regionally Important Geological Sites (RIGS). Cumbria GeoConservation seeks to make LGS better known to the public, and to ensure that their geological interest is not lost due to development and/or infilling.
We believe that this Plan is sound and legally compliant. However we believe that the changes requested below would strengthen the Plan.
As mentioned above, RIGS are now termed Local Geological Sites (LGS). We would be pleased if you could make this change in Appendix 2, in ‘land to be safeguarded’, under Environmental and Heritage Designations. If LGS could be added to the Glossary this would further help recognition of the need to protect geological sites.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
4. Mrs Sylvia Woodhead, Cumbria GeoConservation   :   28 Nov 2017 10:23:00
Appendices, Glossary or other
Other - misc
1.1 Do you consider the DM DPD to be legally compliant?
Yes
1.3 Do you consider the DM DPD to be sound?
Yes
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible. If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Cumbria GeoConservation is a voluntary geological conservation group working to record and protect important Local Geological Sites (LGS) in Cumbria, formerly Regionally Important Geological Sites (RIGS). Cumbria GeoConservation seeks to make LGS better known to the public, and to ensure that their geological interest is not lost due to development and/or infilling.
We believe that this Plan is sound and legally compliant. However we believe that the changes requested below would strengthen the Plan.
1.6 Please set out what modification(s) you consider necessary to resolve your objection and make the DPD legally compliant or sound, having regard to the matter(s) you have identified above. (Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination). You will need to say why this modification will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording on any policy or text. Please be as precise as possible.
There are 31 LGS in the SLDC areas but we fear that SLDC may not be using the latest GIS planning layer showing the boundaries of these areas, in order to recognise their existence for planning applications. Our full data and planning layer are no longer held by CCC, but instead are available from the Cumbria Biodiversity Data Centre (CBDC) in Carlisle. We would urge SLDC to access this information. We have recently had to archive a LGS, designated in 2014 for 3 ponds which are kettle holes, left by stagnant ice at the end of the Ice Age. Unfortunately the relevant fields have been drained and the ponds no longer exist. We fear that if SLDC had held the latest data this site might not have been lost.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
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