Cumbria LNRS Consultation Response

Scoring the Cumbria Local Nature Recovery Strategy Public Consultation

The Cumbria Local Nature Recovery Strategy (LNRS) team established a detailed process for managing and scoring the responses from its six-week public consultation, which ran from 12th May to 22nd June 2025. The goal of this process was to ensure all feedback was objectively assessed and used to create a further refined, data-driven Statement of Biodiversity Priorities and Local Habitat Map. The revised LNRS is still subject to further review and to be presented to the Supporting Authorities (Natural England, Cumberland Council, Lake District National Park Authority, and Yorkshire Dales National Park Authority) for final approval before being submitted to Defra (Department for Environment, Food and Rural Affairs) later this year. 

Westmorland and Furness Council are the Responsible Authority appointed by Defra to develop the collaborative LNRS on behalf of Cumbria.

Process for Managing Responses

The process was divided into two main phases: an initial sift and a detailed scoring panel.

1. Initial Sift

Responses were extracted from the Citizen Space platform on a weekly basis. The Cumbria LNRS Core Team, which included representatives from all Supporting Authorities and Defra arms-length bodies, performed a preliminary assessment. This initial sift used a simple Yes/No assessment based on a set of eight screening questions to determine if the feedback was relevant enough to proceed. Responses that answered "Yes" to these questions were passed to the scoring panel.

Screening Questions (Y/N Assessment)

  1. Is it within the remit and scope of the LNRS? (Does the feedback directly relate to the objectives and strategic boundary and/or remit of the LNRS?)
  2. Does it add additional value to the content already addressed within the LNRS? (Does the feedback provide new insights, data, or perspectives beyond what is currently included or considered?)
  3. Does it meet the requirements of the regulations and statutory guidance? (Is the feedback aligned with the legal and procedural frameworks governing LNRS development?)
  4. Does it focus on restoring or enhancing locally important habitats or species, or wider environmental benefits? (Does the feedback contribute to the core aims of nature recovery, including the referenced wider benefit measures?)
  5. Is it backed up by sufficient evidence, data or expert knowledge? (Is the feedback supported by credible information or referencing sound evidence which may have been omitted?)
  6. Is it realistic and achievable for the next 3-10 years? (Is the proposed action or suggestion practical for implementation within the strategy's timeframe?)
  7. Is it at a realistic and achievable scale for the LNRS? (Is the scope of the suggestion appropriate for the LNRS's regional focus?)
  8. For location-specific comments: Do they have control of the land they are suggesting changes on? (This question is crucial for actionable, site-specific feedback and should be evidenced by land ownership details.)

2. Detailed Scoring Panel

The Cumbria LNRS Scoring Panel, made up of members from the Steering Group, met on 2nd July 2025 to conduct a more detailed assessment. The panel was guided by a conflict-of-interest policy, which required any member with a vested interest in a particular response to declare it and refrain from influencing the final decision.

This panel applied a granular 0-3 numerical scoring system to each of the same screening questions used in the initial sift. The scoring scale was:

  • 0 = No / Not Applicable: The response does not meet the LNRS criteria or is irrelevant to it.
  • 1 = Partially / Limited: The response partially meets the criteria or offers limited value/evidence.
  • 2 = Mostly / Good: The response largely meets the criteria, providing good value/evidence.
  • 3 = Fully / Excellent: The response fully meets the criteria, offering significant value, strong evidence, and clear alignment.

The scores for each question were then summed to create an overall score, which helped in prioritizing the most impactful and relevant feedback.

“I am staggered by the quality and depth of expertise shown within the Cumbria Local Nature Recovery Strategy. A superb piece of work.” 

Analysis of Consultation Feedback

The consultation collected both quantitative and qualitative data, which required different analysis techniques.

Quantitative Analysis: Questions with pre-determined answers, such as Likert scales (e.g., "Strongly agree"), were analysed using a tolerance percentage. For instance, if the combined percentage of "Strongly agree" and "Mostly agree" responses were over 75%, it indicated a strong consensus. Conversely, a combined agreement below 60% or disagreement above 25% flagged an area for closer review and potential amendment.

Qualitative Analysis: Open-ended questions were subjected to a thematic and sentiment analysis. The team identified recurring themes, key issues, and suggestions within the text responses.  Location-specific comments with grid references were reviewed to assess their feasibility, before being passed to Cumbria Biodiversity Data Centre (CBDC) to include in the Local Habitat Map.

Demographic information was also collected to ensure the representativeness of the consultation, though this data was used for reporting purposes only and not shared with the scoring panel.

Following completion of the scoring process a number of recommendations were made to inform the amendments to both the Statement of Biodiversity Priorities and Local Habitat Map.

The attachment below contains all responses from the Cumbria LNRS Public Consultation. Please note that all personal and contact information has been removed to comply with data sharing rules.

Cumbria LNRS Public Consultation responses.

Consultation Review and Feedback

After receiving a total of 82 responses during the public consultation, suggested changes are underway to both the Statement of Biodiversity Priorities and the Local Habitat Map.

Please note: all amendments detailed below are subject to change and require further review and approval by the Responsible Authority and Supporting Authorities during the 28-day Pre-Publication period before the final Statement of Biodiversity and Local Habitat Map will be presented to Defra.

Amendments to the Local Habitat Map

Through the public consultation, a total of 46 comments were received which met the screening criteria and against which a change to the Local Habitat Map would be considered. These were grouped into nine recurring themes which are summarised below:

Creation of a built environment network

Description

Multiple respondents expressed concern over the lack of opportunities mapped within urban areas, and the miss-match between 6 habitat themes in the document and 5 on the map.

Number of suggestions

10

Summary of suggested changes

Creation of a built environment ‘network’ that shows:

  • existing open mosaic habitats
  • existing publicly accessible greenspace 

Existing swift hotspots (decision to not map as data shows location of active swift groups, not necessarily the most suitable buildings across Cumbria. If was felt the swift measure would have a greater impact on planning policy if it is to be considered everywhere)

Expansion of the grassland network

Description

Multiple responses related to the grassland network, either observing that opportunities were too few, they couldn’t find any in their area, or there appeared to be an emphasis on opportunities for other habitats when they felt grassland restoration would be more appropriate in their area.

Number of suggestions

7

Summary of suggested changes

Reinstating Network Enhancement Zone 1 from the network model to the grasslands and limestone pavement layer.

Mapping measures to areas that are important for the in-bye suite of wading birds

Description

Raised by North Pennines National Landscape but was also touched on by other respondents. NPNL included a proposal to amend the wording of M57 and then extend the area to which this was mapped.

Number of suggestions

3

Summary of suggested changes

Extend the area of measures that are mapped to benefit breeding waders by:

Extending the coverage of M57 to include:

  • areas that are adjacent to the existing moorland, heathland and montane network
  • classed as less favoured areas by the RPA
  • within zones 4 and 5 for curlew on the Wader Zonal Map

Extending the coverage of M95 to include:

  • areas that are adjacent to the existing wetland and freshwater network
  • classed as less favoured areas by the RPA
  • within zones 4 and 5 for curlew on the Wader Zonal Map

Change to the mapped measure on canals

Description

One respondent commented that the measure mapped to canals is not appropriate, and the map would be enhanced if a canal-specific measure was developed and mapped to these areas.

Number of suggestions

1

Summary of suggested changes

Develop a canal-specific measure and map this to canals.

Refinements to the coastal and estuarine network

Description

Two respondents suggested comparing the coastal and estuarine network against the Shoreline Management Plans to refine the mapping around key infrastructure etc. 

Number of suggestions

2

Summary of suggested changes

Refine the coastal and estuarine mapping by:

  • reviewing create areas against the Shoreline Management Plan (not carried forward as data was not compatible to improve the quality of the LNRS mapping)
  • refining the mapping of saltmarsh creation against the EA ReMeMaRe dataset

 

Review of mapping on irreplaceable habitats

Description

Two respondents suggested comparing the coastal and estuarine network against the Shoreline Management Plans to refine the mapping around key infrastructure etc. 

Number of suggestions

2

Summary of suggested changes

Revisit rules around measure mapping and exclude creation/restoration measures from other habitat networks on:

  • Coastal sand dunes
  • Ancient woodland

Review of wider benefits layers

Description

A number of requests were made for additional layers to be added to the non-statutory layers part of the local habitat map at different points throughout the consultation process, including the UNESCO GeoPark and Raise Community Forest.

Number of suggestions

2

Summary of suggested changes

Limit additional layers to statutory designations/legally recognised areas and those that deliver wider benefits. Remove World Heritage Sites and Registered Parks and Gardens from the list as these are managed for historical/cultural value and not biodiversity value, and are not necessarily all accessible (related wider benefit).

Manual changes

Description

Eighteen requests were made for site specific manual changes to the map that won’t be captured by the wider revisions suggested above.

Number of suggestions

18

Summary of suggested changes

Make site specific changes to the map where: 

  • there is a detailed site plan with relevant permissions/funding in place​
  • Shapefiles are provided in polygon format​
  • Results in the creation of wildlife-rich habitat​
  • Additions are adjacent/spatially linked to current network​
  • Changes are non-commercial / not solely linked to the aim of increasing BNG units available

Function and clarity

Description

Nine respondents provided actionable comments on the function or clarity of the map most of these can be addressed by reviewing the text in the document.

Number of suggestions

9

Summary of suggested changes

Address comments by:

  • reviewing clarity of text in document
  • reviewing functionality options including linking directly to measures and searching by measure, once all other changes are made

“Thank you for involving us all in this difficult and complex process, and for listening to what we've had to say!  We appreciate it.”

Amendments to the Statement of Biodiversity Priorities

Revisions will be applied to the Statement of Biodiversity Priorities. Although no fundamental changes are necessary, contributions from the public consultation will be used to further strengthen the document. 

The information below provides a summary of the suggested changes and amendments. Please note that this is not an exhaustive list but a guide to the general updates being made.

General and Structural Changes

  • Executive Summary and Sector-Specific Versions: To improve readability and focus, we'll create a clear executive summary for the main document. We're also exploring the possibility of producing supplementary versions of the LNRS tailored for key sector groups to better support their engagement with the strategy.
  • Geodiversity: The document will be updated to more accurately reflect geodiversity—the natural and man-made processes that shape the landscape. This includes adding bullet points to the text. Note that we will not include Local Geological Sites (LGS) in these updates as they are not featured on the APIB map.

Appendix C: We'll add new documents to Appendix C, including links to National Planning Policy/Guidance, Local Plans, or National Park and National Landscape Management Plans.

Specific Section Updates

Woodlands

  • Woodlands Vision: The vision for the Woodlands Section will be updated to include "and connected" alongside "well managed," strengthening the focus on connectivity as a key priority
  • Grey Squirrel Management: We will add grey squirrel to the woodland management measure to expand on grey squirrel management as a way to improve woodland conditions

Hedgerows

  • Target and Commitment: We will update the document to reflect the hedgerow Environmental Improvement Plan (EIP) target: restoring and establishing 2,000 miles of hedgerows by 2050
  • Management Practices: We will include appropriately timed hedge laying by skilled professionals in addition to planting new hedgerows
  • Boundary Replacement: We will reference replacing fences with hedges, not just historical field boundaries

Limestone Pavements

  • Enhanced Descriptions: We will update the description of limestone pavements to better reflect the reality that they are not always flat.
  • Legal Definition: A legal definition of limestone pavement will be added to the glossary section.
  • "Where to See" Section: We will add Great Asby Scar NNR to the "Where to See" section.
  • Geological Importance: Recognition of the geological importance of limestone pavements will be added to the limestone measures.
  • Pressures on Limestone Pavements: Additional information will be added to clarify that pressures on limestone pavements formerly came from the removal of their clints (limestone blocks) for sale as rockery stone, a risk that has been considerably reduced by Limestone Pavement Orders.

Grasslands

  • Habitat Condition: We will more clearly explain the disparity in the condition of coastal and floodplain grazing marsh and the resulting difficulties of its classification.
  • Farming Methods: The wording in the Grassland section will be reviewed to reflect different farming methods.
  • Productive grasslands: We will also reword the measure on arable land to include "productive grasslands" and will add this measure to the grasslands chapter.
  • Grazing Management: The grassland management measure will be updated to reflect the need for some management, such as conservation grazing.
  • Floodplain Meadows: We will remove the mention of drain blocking for floodplain meadows and instead refer to ‘restoring natural hydrology’. Will also add reference to reducing soil compaction.
  • Wetland and freshwater
  • Recreational activity: We will review the text to include greater reference to activities such as angling.
  • Stocking: We are reviewing the measures on stocking of rivers, lakes and ponds by seeking advice from Natural England.

Coastal and estuarine

  • Tidal islands and post-industrial habitats: we are strengthening reference to these habitats in the text, as well as the importance of saltmarsh for agricultural and recreational purposes.
  • Shoreline Management Plan: We are increasing reference to the Shoreline Management Plan

Built environment

  • Parks and gardens: we are increasing the reference to parks and gardens and including in our list of ‘where to see’.
  • Development: we will add in a reference to nationally set housing targets and the pressures this puts on our greenspaces.

Species Assemblages and Priority Lists

  • Farmland Assemblage Review: A review is being undertaken to check the farmland assemblage for barn owls. We are also reviewing species assemblages with experts to discuss Lichen and other plants that could be in the farmland assemblage, and we'll add common names to the list.
  • Priority List Amendment: We will amend the priority list to include golden plover, dunlin and ringed plover as they will benefit from bespoke interventions.
  • Discussions revealed that the existing data on swift nesting sites is limited where active swift groups exist. Mapping these sites would provide an incomplete picture and would not be sufficient for informing habitat restoration activities that could have a significant impact on the swift population. The unmapped approach aims to embed the need to protect swifts directly into planning policy. This means all future development and planning decisions throughout Cumbria will consider Swift conservation, rather than just in the previously identified areas. This is seen as a more beneficial long-term strategy for the species

“The Draft Cumbria Local Nature Recovery Strategy is a MAGNIFICENT ACHIEVEMENT, which has clearly taken a huge amount of work. It is a privilege to have had the opportunity to comment on this consultation draft.”

Thank you to everyone who took the time to submit a response to our public consultation. We hope the information above provides a clear summary of the further changes being made to the Draft Local Nature Recovery Strategy.

If you would like to discuss any aspect of the Consultation Scoring Process or arrange a brief call with the LNRS team to discuss your comments in more detail, please contact:  cumbria.lnrs@westmorlandandfurness.gov.uk