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NFA Comment on Dibden Bay

The perennial threat of development of Dibden Bay by Associated British Ports (ABP) for a container port appears to be back on the table according to stories yesterday from both the BBC and the Southampton Daily Echo, with ABP complaining of limited capacity and Chancellor of the Exchequer, Phillip Hammond saying he would support the development which would no longer be subject to a local planning inquiry, but would be considered a National Infrastructure Project.

Our Chair, John Ward, has commented:

Dibden Bay at Low Tide - geograph.org.uk - 386918
The harmful impacts to wildlife and to the landscape of the New Forest that would be caused by developing Dibden Bay as a container port would be no less today, tomorrow or in the coming decade than they would have been in 2004 when a lengthy planning inquiry led to the rejection of a similar proposal.

The one thing of major significance to have happened since then has been the designation of the New Forest National Park, recognising that in addition to its massive importance for habitats and wildlife the New Forest is one of ‘the finest landscapes in England’. Government national planning policy emphasises the great weight that should be given to conserving the landscape and scenic beauty of National Parks.

Dibden Bay is immediately adjacent to the boundary of the New Forest National Park. There is no hinterland, no buffer zone. At present on one side of this line there is Forest heathland and trees and on the other the environmentally important marsh and reclaimed land of Dibden Bay. Apart from the destruction of valuable habitat, a container port would bring vast cranes reaching far into the sky, 24 hour intensive lighting and greatly increased traffic not just from transporting containers but serving all of the ancillary activity that would spill out across surrounding areas.

The west side of Southampton Water is already a busy area jostling against the fragile special qualities of the New Forest. It is no place for further major development.

Fracking the Forest?

With the Government taking the decision on fracking away from Lancashire County Council on 6th October 2016, this brief review of our position and the possibility of hydraulic fracturing in this region could be of use.

The NFA support the position of the Campaign For National Parks, that fracking in or under our National Parks has significant environmental impacts – polluting groundwater, damaging the landscape and ruining tranquility, and is inappropriate for the setting.  While we’ve been given to understand that the New Forest’s geology would not be attractive to fracking, we do not want to see this for any of our National Parks or other protected areas. Additionally the precedent it establishes for putting supposed infrastructure demands over these designations is truly chilling. 33 years ago an application by Shell UK to drill for oil and gas in Denny Inclosure was seen off, a battle we shouldn’t have to fight all over again.

Last year, when the Government was in the midst of its U-Turn on a promise not to license fracking in National Parks (eventually arriving at the position that they would allow drilling from just outside National Parks to go under them), Durham University published an article ranking the Parks likelihood for hydraulic fracturing.

New Forest National Park: (Geology: http://bit.ly/1zPvEi0)
A relatively young geology and the rocks close to the surface have no shale gas, shale oil, or coal bed methane potential. Oil and gas have been found in rocks beneath areas close to the New Forest, and there has been exploration in the national park, but there is no evidence of any oil- or gas-bearing shales that would be of interest to fracking companies.

The Briefing Note puts the Forest in its middle Amber (fracking unlikely) category (along with Brecon Beacons, Exmoor, and Northumberland).  It listed four national parks as Red (fracking possible): North York Moors, Peak District, South Downs, and Yorkshire Dales (rocks of possible interest to companies looking to frack for shale gas, shale oil, or coalbed methane).

Whilst researching other goings on at the Verderers Court, this item from 2014 popped up that suggests that fracking could come closer to the Forest than we had supposed:

2014/
7364
HAMPSHIRE MINERALS & WASTE – OIL AND GAS DEVELOPMENT – REPORT ON MEETING ON 5TH JUNE 2014

Mrs Westerhoff attended the meeting on behalf of the Court. The discussion centred around fracking. Two areas have been identified as potential sites, one being The Weald (as far west as Winchester) and the other is in Dorset reaching east to Thorney Hill adjacent to the New Forest. Whilst the New Forest could be fracked in the future, Mrs Westerhoff understood it would only happen under exceptional circumstances and would be subject to the European legislation protecting the SAC.

–Verderers Minutes June 2014
DISCHARGE

With the unknown shape of the Brexit plan, the reassurance of protection from the SAC (Special Area of Conservation, a European designation), is under threat unless those protections are formally and thoroughly back-stopped in UK legislation and policy.

The most recent Hampshire Minerals and Waste Plan was adopted in 2013, before the more recent changes in policy and legislation. Subsequently, December 2015 they updated the On-shore Oil & Gas FAQs  (60 pages) and in February 2016 the Hampshire Authorities adopted the Oil and gas development Supplementary Planning Document (SPD) (90 pages).  From the FAQ:

Oil and gas exploration in National Parks

There are known oil and gas resources within Hampshire’s two National Parks and exploration already takes place within the South Downs National Park. There are other examples nationally of where oil and gas development takes place within designated areas. This includes western Europe’s largest oilfield at Wytch Farm, Dorset and sites in Surrey all of which are located within designated areas for nature conservation. The potential impact of a proposal on designations will be taken into account in detail at the planning application stage. The Government has recently announced new planning guidance on unconventional oil and gas development in areas of designation such as National Parks, AONBs and heritage sites (see question 23). There are also policies in the adopted Hampshire Minerals & Waste Plan in relation to minerals developments in designated areas (including Policy 4: Protection of the designated landscape) which will be used to guide whether planning permission should be given in such locations.

In December 2015, there was a vote in the House of Commons regarding hydraulic fracturing in National Parks. MPs voted in favour of allowing hydraulic fracturing to take place 1,200 metres below National Parks and Sites of Special Scientific Interest, as long as the drilling (and associated infrastructure) takes place from outside the designated areas.

There are no licences in the New Forest National Park administrative area.

The Weald in the South Downs National Park is a target for fracking, and would be a potential testbed for the 1200 metre rule.  In September 2016 their Authority rejected a plan for horizontal drilling with hydraulic fracturing.  The applicant believes “this proposal would be supported by the Planning Inspectorate or the Secretary of State in the event of an appeal.”  Given that the British Geological Survey (BGS) estimate 2.2 and 8.6 billion barrels of shale oil beneath the Weald Basin, that appeal could be in with a chance as that may be deemed nationally significant.  We may need to lend our support to our neighbours should this go forward.

The “Reverse the decision to allowing fracking under our national parks.” parliament petition closed on June 19th 2016, with just 38,732 signatures, not enough to be granted a debate(>100k), but enough (>10k) to trigger a Government response, which includes these provisos about protected areas that leave us feeling much less protected:

The protected areas in which hydraulic fracturing will be prohibited have been set out through the Onshore Hydraulic Fracturing (Protected Areas) Regulations, which were formally approved by both Houses of Parliament in December 2015. These regulations ensure that the process of hydraulic fracturing cannot take place above 1200 metres in National Parks, the Broads, Areas of Outstanding Natural Beauty (AONBs), World Heritage Sites and areas that are most vulnerable to groundwater pollution.

Rather than enabling operations in protected areas, these regulations introduce an additional protection to our most sensitive areas and complement the strong protections already provided by the planning system. Moreover, it is worth emphasising that the regulations do not in themselves grant any form of permission for “associated hydraulic fracturing” to take place under any of these sites. They simply establish the principle that hydraulic fracturing should be prohibited by legislation in the specified areas and down to the specified depth. A company looking to develop shale will still need to obtain all the necessary permissions, like planning and environmental permits – and any proposals will necessarily be subject to further detailed consideration and scrutiny under our legal and regulatory regimes.

Orwellian newspeak at its finest “an additional protection to our most sensitive areas”, these sensitive areas would not need additional protection, if they weren’t under threat from this activity in the first place.  They should simply be removed from the equation entirely.  Putting an arbitrary depth of 1200 metres also ignores the fact that those 1200 metres (and the water table) will be drilled through to get to that level, that hole, however well engineered will be connected to the area into which fracking fluid will be pumped at high pressure.  What could possibly go wrong?  Fracking was temporarily suspended in 2011 after earthquakes were caused near Blackpool.

In the 16th December 2015 vote on the Onshore Hydraulic Fracturing (Protected Areas) Regulations 2015 — Extension of Prohibition of Shale Gas Extraction, New Forest East MP Dr. Julian Lewis spoke against the regulation publicly, but abstained from the vote. New Forest West MP Desmond Swayne voted with the Government to allow fracking under National Parks. This is all the more troubling as the west of the Forest is in closest proximity to proposed sites, as noted by David Harrison, Lib Dem councillor, member of the New Forest National Park Authority, “I imagine the west of New Forest will be mainly affected.”

The NFA discussed fracking issues at the November 2015 Council meeting, and although it is unlikely that the Forest’s geology would attract fracking per se, we’re completely against this approach both in principle, and the possibility that it would open the door to similar exploitation. These fights are perennial and ongoing.

The protections offered to designated landscapes and habitats, National Parks and SSSI, et.al. must  be honoured and remain meaningful.

Cables Buried At Buckland Rings


There….

Buckland Rings is an Iron Age Hillfort (and modern day informal BMX track) situated on the National Park’s border with Lymington.  To its south and east ran a 33v overhead cable which spoilt  the setting of the fort from the adjacent open access.

The cable has now been buried as part of Scottish and Southern Electricity Networks £15m project to underground 90km of overhead lines in AONB and National Parks in North Scotland and Central Southern England.  A few weeks after the burial no evidence of the work can be seen on the ground.

… and gone.

NFA are now championing the burying of the cable from Hicheslea west along the old Ringwood train line via Slap Bottom to Bagnam.  If anyone out there has an overhead cable in the New Forest National Park they particularly dislike, they should should contact planning@newforestassociation.org

— Graham Baker, Chair, Planning Committee

(web editor’s note: perhaps we could reduce our planning committee’s workload by only notifying them of any overhead cables anyone is actually fond of….)

Material World

Warwickslade Cutting, infilling of minor drain - geograph.org.uk - 1464070One concern I think we all share about the Latchmore Brook project is the transport of the infill materials.  This is due to cause a certain amount disturbance and inconvenience to those residents and visitors along the delivery routes, as well as valid questions about the safety for both road and Forest users, man and beast.   I’ve already had a private go at the FC and LUC over their need to provide concise and useful figures for the public to properly convey the size of the issue.  Here I attempt a stop-gap.

Movement of materials to the nine stockpiles to service nine different project areas is due to run over four different access routes in two or three of the four years of the overall project.  Two of these access routes are via relatively well used roads, the B3078 Roger Penny Way from either Godshill or Brook to Telegraph Hill, and the turning from the A31 to Stony Cross, then the turning towards Slufters and Cadman’s Pool, followed by the turn towards HighCorner /Linwood, almost immediately turning off onto the Forest Track to Holly Hatch / Alderhill.  The more problematic routes go through the village / cul de sac Fritham, home of the Royal Oak pub, which some consider the unofficial office of the NFA, the other through the village of South Gorley and Ogdens. 

As you drive northeast up the unnamed road towards Ogdens, many of the houses grow larger. You’ll pass Fir Tree Farm, one of the best placed and few remaining commercial stables on the Forest, its manège is only a fence and a few feet away from the narrow lane, riders in the school may not appreciate the extra challenge to their control and aid skills as their mounts react to passing tipper lorries.  After the stables, the road becomes a forest track, with more modest dwellings fronting directly and quite closely to the road.

Naturally we have every sympathy for those who may be effected.  All the more reason to get at some realistic, and relate-able numbers.

I’ve seen and heard alarming figures, 70HGV movements a day or 44000 HGVs over the course of the project, which I’ve discovered to be ridiculously overblown.  Not that I blame anyone for getting this wrong as the planning documents do not lay out the information in a helpful way. I had to bounce around four or five of the submitted statements and appendices to pull this together.

1.3 The works are anticipated to last for approximately 4-12 weeks (July-September) per year over a period of 4 years. If weather conditions are poor (wet), works may halted temporarily to protect ground conditions.

4.9 The highest maximum number of deliveries for each route to the site per day has been calculated as follows:

  • Ogdens – 25 HGVs and 4 tractor/trailer deliveries per day.
  • Alderhill – 25 HGVs and 4 tractor/trailer deliveries per day.
  • Fritham – 25 HGVs and 4 tractor/trailer deliveries per day.
  • Telegraph Hill – 25 HGVs and 4 tractor/trailer deliveries per day.

4.10 In addition to the HGV movements set out above, there will be approximately six employees on site associated with the restoration works (i.e. total 12 movements per day).

In two of the planning documents we are only given maximums or ranges, we’re told a maximum of 25 HGV deliveries per day per route, a window of 4-12 weeks in each of the four years, this last is the beginning of distortion as only the 2019 Phase is 12 weeks July to September the other three are 4-8 weeks August-September.

Back to one of the numbers being bandied about by alarmists.  70 HGV’s per day.  If someone has quoted this figure at you, they are either lying, or unknowingly passing on an intentional lie.  The only way one could arrive at the number 70 is to take the maximum 25 HGV deliveries, the 4 tractor/trailer, plus up to 6 staff vehicles for a total of 35 roundtrips = 70 movements, only 50 movements are HGV (still not a small amount, but smaller, and a maximum, averages may be lower).  As we’ll note later, despite the stated maximum of 4 tractor/trailer deliveries per day conjuring an equal level of traffic, the number bale deliveries becomes negligible very quickly.

Here’s the initial information I pulled out of the “Appendix 4.1: Estimated Restoration Material Quantities and Transport Movements Data” (a diabolically poorly laid out document in which every 2 out of three tables has a single line, in some case, a single cell).  The 22 separate tables are easily and more usefully aggregated into three tables, the first gives us Material Quantities, the primary information we need to derive the number of deliveries, the other two Maximum number of deliveries per day clay/gravel/hoggin and heather bales respectively (plus Delivery timescale for HGV loads).   You’ll forgive the small size required to squeeze this in here.  The more important summary tables that follow will be suitably legible.

Table 1: Estimated Material Quantities

Project Area Stockpile Lorry Route Hoggin & Washed Gravels (tonnes) Clay (tonnes) Minimum Tipper Deliveries Minimum Tipper Days _ Heather Bales Minimum Tractor Deliveries Minimum Tractor Days
Islands Thorns Picket Corner Telegraph Hill 10004.6 4001.8 702 29
1815 7 2
Islands Thorns Islands Thorns Fritham 5002.3 2000.9 352 15
1815 7 2
Islands Thorns Fritham Bridge Fritham 5002.3 2000.9 352 15



Thompson’s Castle: Hampton Ridge Telegraph Hill




460 2 1
Thompson’s Castle: Ogdens Car Park Ogdens 2071.0 829 146 6



Latchmore Mire: Hampton Ridge Telegraph Hill




1944 7 2
Studley Wood: Claypits Telegraph Hill 5860 2344 411 17
986 4 1
Studley Wood: Picket Corner Telegraph Hill 5860 2344 411 17



Ogdens Mire: Ogdens Mire Ogdens




2280 8 2
Ogdens Mire: Ogdens Car Park Ogdens 99.75 39.9 7 1



Amberwood and Alderhill Inclosures: Fritham Bridge Fritham 9662.43 3864.97 678 28



Amberwood and Alderhill Inclosures: Alderhill Inclosure Alderhill 9662.43 3864.97 678 28
1920 7 2
Sloden: Sloden Inclosure Alderhill 5671.5 2268.6 398 16



Watergreen Bottom: Alderhill Inclosure Alderhill




500 2 1
Latchmore Shade: Ogdens Car Park Ogdens 9755.4 3902.16 684 28














TOTALS

68651.71 27461.2 4819 200
11720 44 13

I have added four columns of calculations, number of both deliveries and days for each material.  In each case all numbers are rounded up to the nearest whole number before being used as a factor in the next calculation.  These are based on both the optimal 100% load capacity and the maximum number of deliveries per day, and so derive the minimum number of deliveries necessary for each location/phase/route of the project.  Depending on your point of view, this is perhaps the best case scenario, the maximum amount of disruption each day, but the fewest number of days.

Table 1a1: Estimated Material Quantities by Route by Year HGVs

Year Lorry Route Hoggin & Washed Gravels (tonnes) Clay (tonnes) Minimum Tipper Deliveries Minimum Tipper Days
2019 Alderhill 15333.93 6133.57 1076 44
2020 Alderhill
2017 Fritham 10004.60 4001.80 704 30
2019 Fritham 9662.43 3864.97 678 28
2017 Ogdens 2071.00 829.00 146 6
2018 Ogdens 99.75 39.90 7 1
2020 Ogdens 9755.40 3902.16 684 28
2017 Telegraph Hill 10004.60 4001.80 702 29
2018 Telegraph Hill 11720.00 4688.00 822 34
TOTALS 68651.71 27461.20 4819 200

If the lorry loads are always at fullest capacity, than the number of deliveries remains constant.  That’s the minimum number of deliveries that would have to happen, you could have them in the fewest number of days if the maximum deliveries per day is reached, but more likely you may want to spread that pain.

 Table 1b1: Estimated Deliveries/Days by Route by Year and Comparison to %90 Capacity / 20 deliveries/day snapshot

Year Lorry Route Minimum Tipper Deliveries 90% Capacity Tipper Deliveries Minimum Tipper Days 90% Capacity 20 Max Tipper Days
2019 Alderhill 1076 1195 44 61
2020 Alderhill
2017 Fritham 704 780 30 40
2019 Fritham 678 752 28 38
2017 Ogdens 146 163 6 9
2018 Ogdens 7 9 1 1
2020 Ogdens 684 759 28 38
2017 Telegraph Hill 702 779 29 39
2018 Telegraph Hill 822 914 34 46
Totals 4819 5351 200 272

For a lesser case scenario, I tweaked numbers for HGV loads at 90% of Capacity, which would increase the number of deliveries required, and thus the number of days, and further increased the number of days by decreasing the maximum deliveries per day to 20.  This makes for some useful comparisons.

Table 1a2: Estimated Material Quantities by Route by Year Tractor/Trailer

Year Lorry Route Heather Bales Minimum Tractor Deliveries Minimum Tractor Days
2019 Alderhill 1920 7 2
2020 Alderhill 500 2 1
2017 Fritham 1815 7 2
2019 Fritham
2017 Ogdens
2018 Ogdens 2280 8 2
2020 Ogdens
2017 Telegraph Hill 4219 16 5
2018 Telegraph Hill 986 4 1
TOTALS 11720 44 13

Heather Bales will by delivered by tractor/trailers with a capacity of 300 Bales per  delivery.  We’ve also been told there’s a maximum of 4 deliveries per route per day.  It’s tempting to simply add that to the other numbers of daily deliveries, but the problem with that is that there are not that many deliveries of bales needed compared to the other infill materials.  At maximum capacity, there would need to be 44 deliveries for the entire project, not per year, not per route, the whole bale of wax.  If you were to spread those evenly by year by route that’s less than 3.  I can’t conceive that 3 extra tractor trailers per YEAR would be noticeable on even the quietest routes.  For our lesser case scenario, we run at ¾ full, and that ups the total deliveries to 58.

 Table 1b2: Estimated Deliveries/Days by Route by Year and Comparison to %75 Capacity snapshot

Year Lorry Route Minimum Tractor Deliveries 75% Capacity Tractor Deliveries Minimum Tractor Days 75% Capacity Tractor Days
2019 Alderhill 7 9 2 3
2020 Alderhill 2 3 1 1
2017 Fritham 7 9 2 3
2019 Fritham
2017 Ogdens
2018 Ogdens 8 11 2 3
2020 Ogdens
2017 Telegraph Hill 16 21 5 7
2018 Telegraph Hill 4 5 1 2
Totals 44 58 13 19

Of course it’s not that evenly spread, as we see when we look at the data, but the Fritham and Ogdens routes would need 7 and 8 deliveries respectively for the whole project.  It gets better than that, the number of bale deliveries coming by road routes might be nil:

For the purposes of the assessment it has been assumed that the heather bales will be transported from outside the catchment via the four routes listed below, thereby assessing a worst case scenario in terms of potential effects. However, it is more than likely that the heather bales will be harvested from within the open forest areas near to the Latchmore Catchment and public roads will not be needed to transport them to the areas of the proposed works.

Table 1c: Total Estimated Deliveries/Days over course of whole project by Route and Comparison to Worst Case snapshot (in combining Days for both Infill and Bale Delivery, overlap has been accounted for.)

Lorry Route Minimum Deliveries Worst Case Deliveries
Minimum Days Worst Case Days
Alderhill 1085 1207 45 62
Fritham 1389 1541 58 78
Ogdens 845 942 35 48
Telegraph Hill 1544 1719 63 85
Totals 4863 5409 201 273

It is also important to note that some mitigation measures are already in the plan which include: The same drivers will be used, and will be made aware of the “possible pedestrians, cyclists and livestock in the carriageway”, there will be “speed restrictions for delivery vehicles;” – 15mph on the Forest gravel tracks, 5mph under the ordinary 20mph restriction under the byelaws, and “traffic management with radios on the Ogdens route” as well as term time restrictions for school run to local schools.  For those concerned about the condition of their roads, there will be a survey of the local highway network before and after the restoration phase to identify and agree any remedial works reasonably attributable to the restoration activities.  (Full list in ES Vol 3 Appendix 4.2 Construction Traffic Management Plan Section 5).

We hope that this analysis goes a little way to giving a realistic scale to the potential problems.  Even if some may still want to scare monger, at least they should have more realistic numbers.  But we don’t want fear, we want sensible and proportional discussion.  And no, we don’t expect that this solves any remaining concerns – whether or not conditions are placed on the planning application to suggest further mitigation, there may still be work needed by both the Forestry Commission and local residents to accommodate each other fairly.

Presentment: Latchmore Brook: Part 2: Wildlife, Materials and Beauty

In a feat of both irony, and good timing thematically, the presenter met the five minute limit for Presentments, and was cut short. The first part was an apology from the New Forest Association for not displaying our support for the Latchmore project “often enough, publicly enough, or possibly well enough.” allowing snide comments and poor treatment of the Verderers, Forestry Commission and National Park Authority to stand.

The second part shifts emphasis to addressing areas that concern all of us about the project, Wildlife, Material Delivery Routes and Beauty.

…I won’t make up for lost time now.  I have a critique of more than ten errors on just one of their webpages which I’ve sent separately to the Verderers (on our news page).  But I beg the courts indulgence to address a few points.  Amongst the more emotive subjects, the potential disturbance to and loss of wildlife in the implementation itself.  Of course this is of concern, but there’s a reason why we view the end-of-days prognostication of those opposed as baseless conjecture.

2119.  Two thousand One Hundred and Nineteen.  This is the non-exclusive number of completed River Restoration projects in the UK since 1994 listed in the database of the River Restoration Centre.   Some smaller, some larger: the Cumbria River Restoration Strategy (CRRS) a partnership project between Natural England, the Environment Agency and the Rivers Trusts of Eden, West Cumbria and South Cumbria won the 2016 UK River Prize. They restored 14 km of river across the three catchments to a more natural form.  Not all restore meanders, only 1593 had Habitat objectives, some were done for Flood Risk, Fisheries, etc. 120 are listed as a result of Community Demand.  But all would have had the issue of disturbance to wildlife.  Projects including hundreds of Rivers Trusts, Catchment Partnerships, private estates, the Royal Parks, the National Trust, amongst others.  When the RSPB, and the Wildlife Trusts, and their ecologists support the Latchmore Brook project and other Forest wetland restorations, they do so with their experience, including many projects on the land they manage.  If the consequences, in 22 years and 2119 projects, were as dire as the leaders of the opposition contend, I should think we’d have heard about it by now, or certainly their researches would have brought this to our attention.

We do all share concerns about the project.  The New Forest History and Archaeology Group have raised issues with the survey, we believe they are surmountable and encourage all interested parties to work towards a solution.

Movement of materials to the site may cause disturbance and inconvenience to those along the delivery routes.  I’ve seen and heard alarming figures, 70HGV movements a day or 44000 HGVs, which I’ve discovered to be ridiculously overblown.  Not that I blame anyone for getting this wrong as the planning documents do not lay out the information in a helpful way.  I’ve already had a private go at the FC and LUC over their need to provide concise and useful figures for the public to properly convey the size of the issue.  The route through Ogdens, for example, we’ve been told this will be used in three years of the project, which is worrying, but hazard a guess at how many days would be necessary for deliveries through Ogdens in 2017 – 6, 2018 – 1, that’s right in 2018 they only need to make approx 7 deliveries on that route that year, 2020 – 28, of course that will bear more discussion, but it brings perspective. For the entire project all routes all years combined there will be fewer than 10k HGV movements, fewer than 11k in the worst case scenario we’ve run.  I’ll be putting up our numbers on our newspage later today, available to all, even if you want to scare people with numbers at least you can use realistic figures.

Finally, many are rightfully concerned about the future beauty of the Latchmore Brook.  Walking along Latchmore Shade, you will clearly see the original meanders.  In some cases you will see this as gently undulating curves written as a gentle scar in the landscape, it is easy to imagine a pleasant stream flowing along this course.  Elsewhere the meanders have been eroded into unattractive ruts, and in other places the area between the current water course and the meanders become a quagmire when the drains rush water into the area, the flood in the now dysfunctional flood plain is partially contained by the meander, not allowing much onto the adjacent grazing.  Fixing this will not make the area any less beautiful.  I spoke of the prizewinning project in Cumbria, which we may begrudgingly agree is also an iconic landscape.  That project was twice the size of Latchmore.

Look at Warwickslade Cutting and Fletchers Thorns amongst many of the completed restorations which have bedded in, they look absolutely lovely now.  There are many to choose from, but don’t impatiently show up moments after the diggers left and expect an instantaneous transformation.  Give nature time to do its magic.  After all nature took its time creating those meanders before they were ruined.

— Brian Tarnoff, Chair, Habitat and Landscape Committee
New Forest Asssociation

While this second part was not read in the open court, the full presentment was distributed in written form to the Verderers, as well as the Annotated Fact Check of the Latchmore Crowdfunding Page.

Much of this half of the Presentment was repurposed in the Public Questions section of the subsequent National Park Authority meeting, with an emphasis on addressing the PR problem now faced by Wetland Restorations in the wake of the leaders of the opposition to Latchmore’s concerted campaign of misinformation, misrepresentation, hyperbole and pseudoscience.

Presentment: Latchmore Brook: Part 1: An Apology

As the Latchmore Brook planning application may be decided before the next month’s Verderers Court.  The NFA find that we owe everyone an apology.

We’ve never made a secret of our support for the Forestry Commission’s wetland restorations.  But clearly, in some areas, we haven’t made our case often enough, publicly enough, or possibly well enough.  For that we must apologize to the whole of the Forest.

We apologize to the Verderers, I know you don’t need anyone to leap to your defence, but you have been impugned, under the snide accusation that everyone involved in, or indeed supporting the project, would knowingly harm the Forest.  The Verderers who many of us regard as the conservative line in the sand, that we are so fortunate have powers granted by the New Forest Acts.  You have supported this project in the various forms its taken when it has come before you.

This is one of the Leaders of the opposition’s most poisonous assertions, that the process itself, is somehow tainted by a cosy “partnership”.  The National Park Authority, Verderers and Forestry Commission are only “partners” in the project inasmuch as they are the statutory bodies obviously required to be on the project board.  It only benefits the FC as they fulfil their legal obligation to respond to the Natural England condition assessment of the SSSI, and only benefits the Park as it successfully fulfils their statutory purposes “to conserve and enhance the natural beauty, wildlife and cultural heritage of the area”.  The NPA is represented on the board by their Chief Exec Alison Barnes.

The NPA’s Planning Committee is made up of 14 of the 22 members of the Park Authority.  The Committee is mostly (12) local Parish, Town, District and County Councillors and 2 Secretary of State Appointees [through DEFRA].  As with any Planning Authority they have strict criteria they must adhere to, and whilst they may seek advice from the civil servant staff of the Authority including their own ecologists and the Chief Exec, the decisions are theirs.  No previous scheme has been refused because, like the present one, they are worthwhile restorations to improve the habitat, and have met the criteria for planning approval.  There is NO conflict of interest as the Chief Exec on the board of the project serves the members of the Authority, not the other way around.

We apologize to the Forestry Commission,  and other public servants that have had to bear the brunt of what many would call a hostile work environment.   I’ve heard hissing at Parish Council meetings.  I’ve seen ecologists aggressively berated at consultations and site visits, where they are merely doing their job and explaining, calmly, what the values of these projects are.  The NFA haven’t been able to be present at all occasions and have not intervened enough.  Not that I lay all bad behaviour at the feet of the Leaders of the opposition, but neither do they repudiate such behaviour.

We also apologize to the FC because while the NFA have campaigned for more monitoring built in to all these projects –  We didn’t insist enough to give everyone a larger more convincing body of evidence.

We apologize to the Friends of Latchmore.  Yes, we do. On one level we welcomed them, we disagreed with their conclusions, but a localized voice giving the Forestry Commission a hard time, could have been useful.  The NFA, covering more issues over the whole Forest, can’t be everywhere all the time.  But they are never sceptical enough with their own arguments, they don’t sort the wheat from the chaff, as a result we’ve heard a few valid points hidden amidst a white noise of hyperbole and pseudoscience.

But here’s where the NFA have done the leaders of the Friends of Latchmore and as a result many of their followers a true disservice.  We didn’t challenge them publicly often enough.  We thought there was no point in popping up doing tit for tat when the planning process would make the decision.  We limited speaking here at the Verderers Court mostly to key moments when the Verderers were to decide their views.  In some cases they may even have taken our silence for validation.

We’ve let them steal a march on us in the public perception, but in doing so they have spread an entrenched dogmatic view which stifles debate, because you can’t have a discussion where one side never concedes any of the many valid points that suggest that either this project is worthwhile, or that its challenges are proportionate.

I won’t make up for lost time now.  I have a critique of more than ten errors on just one of their webpages which I’ve sent separately to the Verderers (on our news page).  But I beg the courts indulgence to address a few points…..

— Brian Tarnoff, Chair, Habitat and Landscape Committee
New Forest Asssociation

In a feat of both irony, and good timing thematically, the presenter met the five minute limit for Presentments, and was cut short. The second part shifts emphasis to addressing areas that concern all of us about the project, Wildlife, Material Delivery Routes and Beauty.  The full presentment was distributed in written form to the Verderers, as well as the Annotated Fact Check of the Latchmore Crowdfunding Page.

The Presentment was preceded by a very short thank you to the Forestry Commission for their new Look, Don’t Pick Fungi policy.  We released a fuller response to the policy here.

Rumour, Wishful Thinking, or Fiction?

On August 30th, The Friends of Latchmore issued a press release.  It spoke of an independent review which would cause the Forestry Commission to immediately withdraw the planning application for the Latchmore Brook wetland restoration. It was all their Christmases come at once.  It was a complete fabrication.

Now, to be fair, it is possible, as we will see, that they were led up a garden path, rather than, as has often been the case, the leaders.

The August 30th Press Release Begins:

Representatives of the Friends of Latchmore are pleased to learn that the Chief Executives of the Forestry Commission and Natural England have agreed that there will be a full and independent review of the wetland ‘restoration’ proposals in the New Forest National Park, including Latchmore Brook. The review is expected to begin towards the end of this year as soon as suitable experts can be appointed.

We now know that, apart from the first nine words, this is untrue.  It then decends into a series of flights of fancy “Forestry Commission and Natural England officials are relieved at the decision, due to the range of complaints…” and “the Forestry Commission is expected to withdraw the Latchmore planning application”.  Then crows a “Spokesperson for Friends of Latchmore said “We are absolutely delighted with the announcement” “.

The alarm bells already ringing became a klaxon.  Much of what had already been said was out of character, to say the least, with what we knew about the resolute intentions of the Forestry Commission to see the planning application through.  But a reaction to an “announcement”?  What announcement?  There had been no announcement.  It appeared that FoL had published their “Press Release” with absolutely no corroboration.

Cue, half a day of tail chasing, FC and NE internally, and many of us on the outside trying to determine a) if there was a shred of truth to this b) where these notions originated.  We confirmed that it wasn’t true, there had been no announcement, and that the rumour would be addressed by the Deputy Surveyor at the Consultative Panel.

At the 1st September, New Forest Consultative Panel, Steve Avery, Executive Director Strategy and Planning for the National Park when asked about the alleged withdrawal of the planning application by the FC, “That hasn’t reached me, or my authority.  We have a live planning application that we will proceed to determine until told otherwise.”  The Deputy Surveyor, Bruce Rothnie categorically denied any intention of withdrawing the planning application or knowledge of an independent review.

[partial transcript of the Consultative Panel]
BR: There’s been a degree of misunderstanding, misinformation that has put out in the last few days and I want to clarify the position.  We remain fully committed to Latchmore Brook Restoration Project and believe the current planning process is the appropriate way to deliver that.  Some of you will remember that some time ago, and certainly before I returned to the Forest, it was agreed that this should be handled through the planning process because of the democratic process it brings.  And that we volunteered to produce an Environmental Impact Assessment which was not required but we felt responded to the concerns of communities around us.  Now we’ve completed that and it is our intention to see that process through.

[referring to the rumour of the independent review]
I have no information to me that there have been any discussions of chief executives coming down to me.  I’m intrigued as to where you got that information.  I have certainly not been able to find any other information provided, down to this level, about that, so perhaps you could explain wherever that’s come from.

[a Burley Parish Councillor, then pressed a leader of Friends of Latchmore, in attendance representing another organization, to make a statement ]

FoL: The information came from the top of Natural England. The press release was “passed”. It was understood that there was to be a joint statement today from the Forestry Commission and Natural England, that there would be a review. There’s obviously some confusion somewhere. I’ve no idea quite how why what’s occurred there, but that’s where the information has come from.

BR: Through what channels …?

FoL: Board of Natural England.

BR: And how was that released to you, your knowledge?

FoL: Through somebody that is in touch with them, and released through the environmentalist that’s been advising them, which I gather Steve’s had a letter from telling him all about it. So I was a little bit surprised that Steve said he didn’t know anything about it so there’s obviously confusion. Let’s say that. I can say no more, that’s the information I’ve had.

[shortly afterwards, Steve Avery was asked for a final comment]
SA:  In the last week, out of 283 representations we received, one of them was from a gentleman called Tom Langton who referred to an imminent review of the scheme and withdrawal of the application, but it’s not grounded or sourced at all as to where that information has come from. The document is on our website, for everyone to see. But, like Bruce, I’d be interested to know where that information has come from, whether from the Forestry Commission or Natural England as alleged.

Tom Langton is the Consulting Ecologist that the Friends of Latchmore hired for their “rapid review” (as we know, rapid is how all the best science is done). After the Consultative Panel closed, panel members speculated that it was possible that either Langton or the Friends of Latchmore had become confused about the review of the New Forest Wetland Management Plan 2006-2016.

The New Forest Wetland Management Plan 2006-2016 published in April 2006, is (and was already at the time of these events) undergoing its end of term review.  The big clue is in the “-2016”.  The review is being done internally within Natural England with the participation of the Forestry Commission.  The Management Plan is available on the New Forest HLS website. It’s difficult to conceive that the leaders of Friends of Latchmore would not be aware of this important document.

In Tom Langton’s letter to the Planners he sites “threats to geological SSSI features and Odonata interests of international importance”, strange when you consider that the British Dragonfly Society (the Odonata in question) support the project. 

It is my understanding that the Chief Executives of the FC and NE have agreed in recent days to undertake an independent inquiry/review of the Latchmore and other restorations and that this will be put in place later this year. …

I think you may agree on reflection that, in any case, the need for a review in effect casts sufficient doubt over the Latchmore plans.

It would be helpful if the application is withdrawn before this Friday 2nd September, the close of the consultation period.

He doesn’t seem to be at any pains to explain how he reached his “understanding”, and at no point does he, in the words of Steve Avery, ground or source his statements.  The actual review is a standard end of plan exercise, not caused by a negating “need”, and as it is a review of the work carried out under the management plan 2006-2016, it won’t include Latchmore as that hasn’t happened yet.  His strangely presumptive sign off continues his baselessly strong suggestion that the application be withdrawn.

On 17th of September, FoL issued a further press release which attempted, poorly, to reconcile statements, allegedly from the statutory bodies.  Strangely it shows that they don’t know the difference between an independent review (denied) and an internal assessment (confirmed).  They seem to be happy that the fact the word “review” was used at all somehow corroborates their original fantasy.  The Lymington Times of 17th September published a story that partially continued to credit the refuted press release, and the Salisbury Journal ran an article which quoted much of it word for word.

On the 19th September a Forestry Commission Communication Manager confirmed several things to us:

  1. The statements about the alleged agreement to an independent review between the Chief Execs of FC and NE, and the withdrawal of the planning application in the Friends of Latchmore 30th August 2016 press release are total fiction.
  2. The Forestry Commission had further denied the statements directly to the reporters from the Lymington Times and the Salisbury Journal before their deadlines for the pieces that ran anyway erroneously continuing to credit those statements.
  3. The New Forest Wetland Management Plan 2006-2016, as mentioned, has already been in preparation — but there has been a decision to speed up finalising this document so that it is done in the next two weeks.  It will then get an extra peer review, as described below:

Statement from Natural England:
Over 140 wetland restorations have been undertaken in the New Forest since 1997. Ongoing reviews of evidence, experience and lessons learnt are an integral part of any long term nature conservation project such as this.

During the past 12 months, Natural England has been working on an Assessment of the evidence supporting wetland restoration projects in the New Forest.

The Chief Executives of the Forestry Commission and Natural England recently agreed to prioritise finalising this Assessment.  The next stage for the Assessment is an independent peer review through Natural England’s Science Advisory Committee.  The objective is to ensure that the evidence and justification for wetland restorations reflect the most recent developments and that any gaps in our knowledge are identified. 

The draft Assessment has been authored by Natural England staff, including a Senior Freshwater Ecologist and Senior Wetland Specialist.  Scoping and commission of the peer review is about to commence and we expect it to be completed during October.  Once completed, the Assessment will be published on the Natural England Access to Evidence website.

Unfortunately this leaves us with some speculation as to how they arrived at this, it looks like Tom Langton may have heard about the existing review of the wetland management plan, put two and two together and came up with five. Then either he potted it up as truth which he presented to his one time masters who embraced it as a dream come true, or passed it on as rumour which the leaders of FoL felt no compunction in passing off, uncorroborated as truth.

Even had an independent review been in the offing, would the leaders of FoL have been happy with any result that didn’t go their way?  As far as we can tell, this project has received more scrutiny than any other project of its kind.  The voluntarily done Environmental Impact Assessment shows the planning authority how well the application fits the required criteria.  The leaders of the FoL won’t be happy with anything except stopping the project.

What’s so dangerous about either of the speculative scenarios is that they both point up the leaders of the Friends of Latchmore “special” relationship with the truth.  We’re used to their lack of fact checking, their disproportionate elevating of minor issues into cause célèbre, and general hyperbole that sadly obscures the few valid points they may raise.  We have, and will continue to point these out here and elsewhere.  But this feels like new territory, releasing uncorroborated rumours as Press Releases, with their usual unearned authoritative tone, and even after public denial, getting two local media outlets to swallow this guff.  That’s steering towards the land of fabrication.

That brings us onto a third possibility.  They intentionally cooked this up with their lackey Langton, to press for what didn’t already exist, and perhaps lead everyone on a merry chase.  Are they that calculating, canny?

So you judge, Rumour, Wishful Thinking, or Utter Fiction?

(although noted within the text, speculative passages have been italicised)

Fact Checking Our Friends

The Friends of Latchmore have created a Crowdjustice crowd funding page to fund future legal challenges to the restoration project at Latchmore Brook.  It contains some of their most problematic statements to date.  The Crowdjustice site have told me that they do nothing to verify any case promoted through their “platform”, that this is entirely up to the claimants and their legal representatives.

Some of these mistakes might be forgiven in a neophyte, but the authors of these pronouncements have been dogmatically stating their version of this case for several years, clearly having time and motivation to properly research, so we must take some of these as wilful misrepresentations.  Given that their page is asking people to donate money to their cause, I should hope that the more sensible leaders of the Friends of Latchmore ought to feel a little bit queasy over these inaccuracies, which could lead to allegations of a scam.

While we don’t believe there is malicious intent, even the possibly unintentional errors have the feel of those grasping at straws for virtually anything that supports their case, whilst systematically ignoring everything that doesn’t.  We leave it up to you, dear reader, to decide how innocent these mistakes are.

[What follows is the text taken from the site as seen on 18th September 2016, highlights in bold and numbered annotations are ours.]

Stop destruction of New Forest habitat

 The Forestry Commission, New Forest NPA and the Verderers are spending EU money infilling Forest streams and destroying protected wildlife.

Why this case matters

The Verderers of the New Forest, The National Park Authority and the Forestry Commission have formed a partnership and obtained significant funding running into millions of pounds from the EU to ‘Restore’ wetlands under the Higher Level Stewardship Scheme which is an Agricultural subsidy meant to help British farmers(1), The partners described the whole New Forest National Park as a ‘farm’ in order to claim this money(2) but it has turned into a massive engineering project infilling many streams with waste products(3) in a misguided attempt to restore them, despite their having a wonderful biodiverse habitat supporting many of our rarest and most protected wild species(4).

(1)   The Higher Level Stewardship Scheme is an Environmental subsidy, the key give away is the word Stewardship which indicates a range of Environmental Stewardship programmes.  Entry Level Schemes include subsidy to farmers laying hedgerows, or planting wild flowers beneficial to wildlife on fallow fields.

(2)   The partners would not need to describe the National Park as a “farm”.  The HLS is eligible to both farmers and land managers.  Common land is eligible. The HLS Scheme for the New Forest only applies within the perambulation of the common land, and so does not include the whole National Park.  DEFRA does occasionally treat the New Forest Common lands as one unit, but this is for things like the Single Farm payment scheme (an actual Agricultural subsidy) and to make the cattle movement rules practical for commoning (movement restrictions which apply elsewhere to prevent spread of TB and other vectors would cripple the relative freedom of the cattle on the commons and their movement back to nearby free holdings).

(3)   “Waste products” – this is an utter misrepresentation – the materials for infill include hoggin, washed gravel, clay and heather bales.  The materials used must be approved by Natural England.  Elsewhere the FoL refer to the material as “alien”, the gravel is taken from the same geological strata (on earth) as that on which the New Forest rests.  If we’re being charitable (why shouldn’t we be?), they may have taken the term “rejects” as applied to some of the gravel.  This refers to gravel not pretty enough to be sold in garden centres, but perfectly beautiful enough to be used for infill.  This tabloid culture of infill shaming must be stopped.

The Forestry Commission have just submitted a Planning Application for Latchmore Brook, 3 miles from Fordingbridge, to carry out major works involving 7 km of the stream and importing nearly 100,000 tonnes of infill material.  This area is an SAC, SPA, RAMSAR and SSSI site and thus should be afforded the highest level of protection(4) but the New Forest National Park Planning Authority has not refused any of the previous Planning Applications for these engineering works, as it is one of the partners of the scheme.(5)

(4)    The project is being done at the behest of and with the approval of Natural England.  The Forestry Commission as the land managers of the New Forest SSSI are obligated to remedy the Condition Assessment prescribed by Natural England, part of their duties to monitor and protect SSSI.  Natural England are then asked to give consent to the proposed solution, there is no guarantee of this as the proposal must pass another set of criteria on top of addressing the underlying problem.  Natural England support the project.

(5)    The National Park Authority, Verderers and Forestry Commission are only “partners” in the project inasmuch as they are the statutory bodies required to be on the project board, and only benefits the Park as it successfully fulfils their statutory purposes “to conserve and enhance the natural beauty, wildlife and cultural heritage of the area”.  The NPA is represented on the board by their Chief Exec Alison Barnes.
The NPA’s Planning Committee is made up of 14 of the 22 members of the Park Authority.  The Committee is mostly local Parish, Town, District and County Councillors (12) and 2 Secretary of State Appointees (through DEFRA).  As with any Planning Authority they have strict criteria they must adhere to, and whilst they may seek advice from the civil servant staff of the Authority including their own ecologists and the Chief Exec, the decisions are theirs.  No previous scheme has been refused because, like the present one, they are worthwhile restorations to improve the habitat, and have met the criteria for planning approval.  There is no conflict of interest as the Chief Exec on the board of the project serves the members of the Authority, not the other way around.

The Forestry Commission still uses the same methods for each new project despite substantial evidence of serious adverse effects(6) on the biodiversity of large areas caused by previous failed restoration attempts(7).

(6)    They do not have substantial evidence, in fact, in this short a time after the completion of previous projects, results are promising, but there is no substantial amount of data, which would require years of monitoring to support claims.  An encouraging independent study by the River Restoration Centre and Jonathan Cox Associates, The New Forest Wetland Restoration Review, surveyed post restoration sites from 2004.
(7)    This is one of the laziest and unsubstantiated claims, none of these are considered failed.  Where they claim restorations are failed they provide no evidence or relevant criteria to make this claim.  The best they seem to be able to do, is to take photos of a dry stream bed before the project has finished bedding in and ignore that this is not its constant or eventual state.  Not to mention that Ditchend Brook is situated in a valley where streams notoriously run dry in Summer (oh, we did mention that).

Ditchend Brook in normal conditions
photo courtesy of the Forestry Commission
CAPTION: “Failed Restoration” [Friends of Latchmore photo of Ditchend Brook as a dry stream bed, looking like a gravel path, above you will see instead a less shocking photo of Ditchend Brook.  An NFA member reported a visit from earlier this year finding numerous small fish, newts and tadpoles in the very spot of the FoL photo. ]

It’s not just the fragile ecosystem which is at risk, but there are also precious archaeological sites(8) as well as significant geological areas, not to mention the serious knock-on effect the works will have on tourism and local businesses as well as the lives of local residents – massive tipper lorries each carrying in excess of 30 tonnes of material will be driving down narrow Forest lanes(9), putting the lives of the ponies and cattle at risk(10), as well as walkers, horse riders and cyclists, not to mention the potential for structural damage to properties(11) adjacent to the planned routes.

(8)   The New Forest History and Archaeology Group have raised issues with the archaeological survey conducted to support the Environmental Impact Assessment.  We believe these concerns may be mitigated and rectified, and we would support all interested parties to achieve this.

(9)    Slight error, the tipper lorries proposed have a maximum load of 20 tonnes.  Odd though, as if their weird claim were true, it would mean at least 33% fewer HGV movements.

(10)    The same drivers will be used, and will be made aware of the “possible pedestrians, cyclists and livestock in the carriageway”, there will be “speed restrictions for delivery vehicles;” – 15mph on the Forest’s gravel tracks, 5mph under the ordinary 20mph restriction under the byelaws, and “traffic management with radios on the Ogdens route” as well as term time restrictions for school run to local schools.  Consider the number of large scale refurbishments to properties along the route, which would have had none of these extra precautions taken for their HGV movements, and no protest over these.

(11)    Vibration study was carried out as part of EIA.

How you can help
We need your help to stop what Sir Desmond Swayne MP calls ‘state-funded
vandalism’ (12)

(12)    This quite vocal campaign group is in his constituency.  His views about protecting the Forest though are inconsistent.  In early 2011 at the time of Env. Minister Caroline Spelman’s disastrous proposal to sell off the public forests, only one of the two New Forest Conservative MPs (plus one from nearby Romsey) rebelled against their party.  It was Rt Hon Dr Julian Lewis, not Desmond who opposed the sell off.

We are crowdfunding to pay for legal representation and expert opinions to
mount significant legal challenges and if necessary to support a possible Judicial Review. We hope to challenge the legality of whole scheme and require the Authorities to put a stop to interference with balanced ecosystems (13) on this massive scale.

(13)    The ecosystem is not balanced, it was broken when Victorian engineers diverted the watercourse away from the natural meanders into artificial straight drains.  The project seeks to undo this damage to bring balance back to the ecosystem of the area.

[for space we’ve omitted two paragraphs, one about their legal firm, and one about the author of the page]

Fast facts
– one of the most iconic and beautiful streams in the New Forest will be
irreparably damaged (14)

– the Forestry Commission have just submitted a Planning Application to the New Forest National Park Authority

(14)    Clearly the author does not understand the difference between fact and unsubstantiated conjecture.