In the Q&A section of the Woking consultation document, one of the questions is (pg. 11):
"Does the proposed scheme risk contravening the legislation which protects GCN?"
The answer is as follows:
"As with any other protected species application, before an organisational licence is issued, the proposals will be assessed against the three legal tests required under in the Conservation of Habitats and Species Regulations 2010 (as amended) (the “Habs Regs”), namely:
Purpose (in this case: imperative reasons of overriding public interest including those of a social or economic nature and beneficial consequences of primary importance for the environment);
That there is no satisfactory alternative;
That the action authorised will not be detrimental to the maintenance of the species concerned at a favourable conservation status in their natural range.
Under the Habs Regs, Natural England is the competent licensing authority and will ensure that the three licensing tests are assessed objectively."
The consultation document defines FCS (pg. 14):
"a situation where a habitat type or species is doing sufficiently well in terms of quality and quantity and has good prospects of continuing to do so in future."
The current system of gcn licensing requires consultant ecologists to prepare a method statement that incorporates actions designed to ensure that the FCS test is met. NE review licence applications. If they are not satisfied that FCS will be met, the licence is rejected. The Woking pilot will require NE to grant Woking BC an organisational licence to implement the scheme.
You can therefore imagine my surprise when I read on pg. 30 of the Woking consultation document:
"This strategy does not seek to define a Favourable Conservation Status or Favourable Reference Values for GCN in the Borough..."
If the proposed strategy does not seek to define FCS for gcn in Woking, then how will the third test be met? Or have I missed something?