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Public consultation on proposed amendments

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									Public consultation on proposed amendments I am responding to the consultation paper dated 23 October 2006 on behalf of the Lake District Local Access Forum (LDLAF). The LDLAF only received notification of these papers in mid December due to an administrative oversight. My first point is that if you wish LAFs to work effectively, your Department must implement effective consultation procedures. I understand the document has already been the subject of consultations between Access Authorities and Natural England and therefore these authorities have already made a number of suggested changes. The Lake District Local Access Forum would support the views of the Lake District National Park Authority which have already been submitted to you. It would however wish to emphasis one point made by the LDNPA about the need for informal management. Many issues can and should be resolved by effective and proactive management combined with common sense. Whilst this is recognised in parts of the consultation paper, it needs to be an overriding presumption for all issues. Any regulation should reflect a positive approach with a presumption in favour of access, not the opposite. A number of members of the Forum commented that they found this consultation paper difficult to read especially as it did not contain questions for consideration. This may be due to the fact that it is a ‘second’ consultation, but the issue should be noted for future consultation exercises. An example of this is the comment by the LDNPA on paragraphs A1, A2, A3. Concern was expressed that a large number of issues were deferred i.e. in the paragraph 26, till 2007. Many of these are critical issues which need careful consideration, and it is hoped that consultation on these will be brought forward at an early date. I am aware that Cumbria LAF have commented that the ‘least restrictive principle’ is only mentioned in the deferred list (Paragraph 26) which illustrates the point. I understand that Cumbria LAF have commented on long term restrictions. The LDLAF would agree that the relevant heading (20) does still not recognise the key outstanding question about aggregation. This has been raised previously by the Cumbria LAF about the status of multi-year restrictions with a duration of less than six months in any one year, but aggregating over time to a period which – if it were a single restriction – would necessitate statutory consultation). Likewise the LDLAF would agree with Cumbria LAF that Local Access Forums should be an appropriate reference in order to ensure effective consultation. Local Access Forums must be consulted more widely and with greater frequency (i.e. not only when they must – by statute – be consulted). Charles Flanagan Chair: Lake District Local Access Forum


								
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