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Recreation Management Strategy and Solent Recreation Mitigation Partnership Strategy

Our representation to Public Questions from the January meeting of the New Forest National Park Authority. We point out flaws in the draft interpretation of last years Recreation Management Strategy Survey (which goes too far in over egging the results), and the undercooked Solent Recreation Mitigation Partnership Strategy (which doesn’t go nearly far enough).

Solent Recreation Mitigation Partnership Strategy

… is an important initiative, however it currently falls short by only considering SPA planning designations and not the full range of important coastal and international designations. As with much mitigation work, little has been done to scale the mitigation to the level of protected features (Thames Basin Heaths is a decent baseline, but has much fewer protected features than our coastline).[*] The Government’s new 25 Year Environment Plan seeks to boost conservation of both designated and undesignated habitats. With these shortcomings, and the new considerations of the recently minted 25 year plan, it would be premature to adopt. We hope you will seek a review and have the strategy amended accordingly.

Recreation Management Strategy

I have previously noted problems with the survey. It made far too much reference to the previous RMS, including out-of-context headings (not even explained as “Summary of 2010 actions”), which constrained much debate to those topics, and were seen as manipulative leading statements. The responses are from an unscientific self-selecting sample, and although the Findings Report admits this[†], it then characterizes some results as authoritative, an unwarranted exaggeration. I’ll give one example:

“Implement and promote the England Coast Path and associated access rights” was the survey summary for Coastal Access. This provided no explanation that the “Associated rights” included coastal margin / spreading room which would potentially turn 3500 acres of our most sensitive breeding and wintering bird habitats (with up to five overlapping layers of national and international designations including an Area of Special Protection) into access land. 23 respondents thought ”the route will attract people away from more sensitive inland areas” (a polar opposite of the truth). It is more than likely that few had heard of the ECP outside of the survey, or would have nominated it, if it hadn’t been mentioned. Yet the concluding report states “The consultation responses suggest that there is wide public support for the England Coast Path,”[‡] which is a very strong extrapolation of 22% of 1500 respondents[§]. If less than a quarter support a proposal, is that wide? If mooted, absent its implications, is that even valid?

Although I do not doubt the hard work, enthusiasm, and sincerity of those conducting this opinion poll. Please do not take as a referendum what has been a success of public engagement, but falls very short of providing anything more than the vaguest bellwether. The Recreation Management Strategy should be driven primarily by the need to fulfill the purposes and protect the special qualities of the National Park. It should focus on specific and practical steps for Management of Recreation not another list of aspirations promising delivery of recreation.

Unfortunately the format of Public Questions at NFNPA meetings limits each speaker to 3 minutes, even when speaking on multiple subjects. This requires a terse approach and presumption of knowledge of underlying reports (which NPA members ought to, but are not guaranteed to have read or digested). Further reading for the curious is noted below:

[*] NFNPA 538/18 – Solent Recreation Mitigation Partnership Strategy Adoption Annex 1 page 19 6.15 “The methodology used to calculate the figures is based on that developed by LPA’s within the Thames Basin Heaths mitigation scheme.”

[†] NFNPA 539/18 Recreation Management Strategy Annex 1 Findings Report “No attempt was made to limit participation in the consultation to a balanced and representative sample survey approach of the local (or wider) population.” page 3 para 8

[‡] NFNPA 539/18 – Recreation Management Strategy Annex 2 page 8, 3.7

[§] 528 (34%) responded to the “Coastal Access” heading, 343 (22%) supported the summary of the topic actions.

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100th anniversary of the Portuguese Fireplace in the New Forest

Bernard Hornung and Anglo-Portuguese Society group

Bernard Hornung and Anglo-Portuguese Society group

On 18th November 2017, eight members of the Anglo-Portuguese community came to the New Forest from London for a little ceremony to commemorate the arrival of a Portuguese contingent in the New Forest on 23rd November 1917 to help in the production of timber for the war effort. Some members of the Friends of the New Forest met the Portuguese party at the New Forest Inn at Emery Down for lunch and then accompanied them to the Portuguese Fireplace at Millyford Green, which had been decorated with Portuguese flags for the occasion. They were joined there by other members of the Friends of the New Forest, and their leader Bernard Hornung explained:

“There is currently no war memorial in this country to the Portuguese who died in WW1. The Portuguese Fireplace is the only memorial that exists and that is to non-combatants. This visit marks the start of the final phase of a fund-raising campaign for two Memorial Windows at the Roman Catholic Church of St James at Twickenham, which will be dedicated to the sacrifices of the Portuguese during the First World War and to the memory of the last King of Portugal.”

Richard Reeves, local historian and Friends of the New Forest council member, explaining the history of Portuguese workers
Then local historian and Friends of the New Forest Council member, Richard Reeves talked about the history behind the Fireplace and the difficulties that faced the Portuguese workers:

“From the start of the First World War, the war itself created an increased demand for timber while at the same time reducing those available to take on such work as they enlisted in the armed forces. The resultant shortage of labour was met to a certain degree by the formation of the Women’s Timber Service and Empire forestry units such as the Canadian Forestry Corps, formed in 1916. However, the need for labour was greater still and the Canadian Forestry Corps based at Millyford were joined by a Portuguese contingent of 100 men on the 23rd of November 1917.

The New Forest lumber camp became a significant settlement, covering around 4 to 5 acres. It was supported by a number of saw-mills and even a narrow gauge railway to transport the timber out of the Forest.

The Portuguese Fireplace is all that remains of this part of the war effort. The Fireplace was originally the fireplace of the camp’s cookhouse.”

Bernard Hornung presenting book to John Ward, Chairman of Friends of the New Forest

Bernard Hornung presenting book to John Ward, Chairman of Friends of the New Forest

Finally a toast was raised to the memory of the Portuguese workers and to the Anglo-Portuguese co-operation that they represented, Portugal being Britain’s oldest international ally. Some of the party then enjoyed a short walk in Holidays Hill Inclosure before they returned to London.

The Friends of the New Forest have just finished celebrating their own 150th anniversary with a year of events. Set up in 1867 to fight off serious threats to the Forest as we know it, the Friends (until recently known as the New Forest Association) are the only membership-based association in the New Forest that gives its members an effective voice on a wide range of New Forest issues. For 150 years their guiding purpose has been to protect, conserve and enhance the flora, fauna and heritage of the New Forest.
Portuguese fireplace, New Forest decorated with Portuguese flags

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Presentment: Recreation Events at Night


Last month the Commoners Defence Association noted problems with the planned 2nd December, Hampshire Maverick Silva Dark Series trail running event.  It is in early evening, but in hours of full darkness (starts an hour after sundown, and a quarter hour after end of twilight). It is sponsored by a headlamp manufacturer promoting a range of LED headlamps that emit 250 lumens over 65 metres [1] (The top of their current range outputs 1500-2000 lumens over 175 metres! [2]).

The nocturnal disturbance of both livestock (as noted by the CDA) and wildlife by a mass event on the Forest, alone, is of concern, but use of high powered LEDs will greatly compound that disturbance. The NFA object to the event as an inappropriate precedent for both reasons. This is, as well, a fundamental conflict with all aspirations to maintain tranquility within the Forest and night-time dark skies above it.

Research on light disturbance has shown bats, amphibians and plants affected by relatively low levels of light. The route comes as close to the A337 as 1500 metres, which could prove fatal to motorists if easily spooked deer bolt towards the road.

This event, if held in daytime, or more appropriately off the SSSI, would be relatively benign [3]. The Forestry Commission have clearly worked hard to mitigate a bad situation created by the event’s organizers, and their permission [4] explicitly states that this is a one-off and that “any future night time events would need to be run at other venues off the New Forest” suggesting Moors Valley as an alternative. Head torches are restricted to Max 250 lumens, max beam length 50m, and must be angled downwards.

A FC spokesperson informed me that the permission would not have been granted if the event were a later time in the evening, or if it was outside the short window of hibernation for many local species. Unfortunately, nature isn’t that simple. At least 11 bat species have been recorded in the route area, including some of the most light-averse. All these bats move in and out of hibernation November to March, rousing to feed when the weather is mild, with early evening as their peak time in winter [5].

The media have lost all the nuances: the route restricted to the gravel tracks in Inclosures (from original plan on open forest), limitations on lighting, and that the FC regard this as a one-off.  The reporting has oversimplified the FC assessment to suggest it “poses no negative impact on the SSSI”. A hard to support statement, which without the context of the prescribed restrictions, sends an erroneous, dangerous message.

This official FC permission will beget the expectation for more large scale after dark events, from the public unaware of even minimal limitations which should be observed, and encourage greater after dark usage both organized and unorganized, at even more damaging times of the year. Creating new unprecedented levels of disturbance on protected habitat at a time where there would be little or none is simply unacceptable.

The NFA hope the Verderers will join us in asking the Forestry Commission, and those who would sensibly enjoy the Forest, to let it, in the name of tranquillity, the livestock, and the wildlife, have a well deserved rest.

Annotations below refer to the bracketed numbers in bold above [n]….

[1] The event offers participants free test use of their previous slightly weaker range (170 lumens over 50 metres), which they no longer produce. The route starts and ends at Foxlease, goes through Clayhill and deep into Denny Wood, Parkhill and Standing Hat inclosures.
[2] That’s roughly the same as a single standard H1 Car head lamp on main beam. 12 Runners with the highest permitted beams will emit approximately as much light as a single car.
[3] …presuming it is well run, safe and considerate to other Forest users, and tidies up after itself.
[4] The Permission includes the following non-boiler plate requirements:

  • “Competitors will be restricted to using head torches with Led bulbs, Max lumens 250, max beam length 50m. All torches must be angled down. Marshals must keep lighting to a minimum as well as per runners.”
  •  “The permit is for this event only please note any future night time events would need to be run at other venues off the New Forest – we will look to offer Moors Valley as an alternative.”
  • “The route as agreed…. It is vital to keep to the tracks and paths as details on the maps provided.”
  • “All gates must be manned to prevent ponies and cattle going through and to ensure that there is no access by vehicles. Gate must be closed after use.”
  • “All litter must be cleared up and signs removed by the following day at the latest.”

[5] from nearby Busketts Lawn there have been records of at least 5 species in late December.

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Friends of the New Forest host national conference

National Parks Societies Conference 2017

The Friends of the New Forest recently hosted a three-day national conference at Balmer Lawn Hotel, Brockenhurst, which was attended by representatives from the other twelve National Park Societies in England and Wales. These Societies are charities which act as ‘critical friends’ to each government National Park Authority, and are the voice for their National Park – its friend and watchdog. Also in attendance were representatives from the Campaign for National Parks, National Parks England and local organisations including the Verderers of the New Forest.

After long journeys from the far corners of England and Wales, delegates met up over an excellent dinner after which Head Agister Jonathan Gerrelli and local photographer Barry Whitcher entertained them with a sparkling illustrated explanation of the role of the New Forest Commoners and the work of the Agisters including organising the annual Drifts to round up ponies.

The following morning was devoted to presentations on the history of the Friends of the New Forest, and the multi-agency ‘Our Past, Our Future’ Landscape Partnership, which is undertaking 21 projects to restore lost habitats, develop Forest skills and inspire a new generation to champion and care for the New Forest. Then delegates heard about the role of ‘Go New Forest’ in delivering marketing and promotional support for the New Forest destination and of New Forest Marque, whose accreditation scheme exists to develop and promote the production, processing and distribution of local produce from the New Forest. Finally there was a session about communicating your organisation’s aims in a ‘post-truth’ society.

Jane Overall talking about New Forest Marque

The delegates then stretched their legs and continued to learn on one of two study tours: a Forest walk to learn about combatting non-native species and stream restoration, and a boat trip to Hurst Castle followed by a sea wall walk to hear about climate change and its impact on the New Forest coast. Returning wind-blown and in some cases muddy, delegates had time to meet up and chat about their matters of mutual interest, with Brexit looming over all. Following another good dinner, they were entertained by a talk from Woodgreen artist Pete Gilbert who managed to tell them his exciting life story while producing a painting of a New Forest scene before their eyes.

Nick Wardlaw leading stream restoration study group

Catherine Chatters leading non-native species study group

The final morning involved further presentations on the New Forest Trust, Forest Design Plan, and the work and concerns of the Commoners Defence Association before Bruce Rothnie, Deputy Surveyor, tackled the thorny issue of recreation management and its relationship to the primary purpose of conserving and enhancing natural beauty, wildlife and cultural heritage. Alison Barnes from the New Forest National Park Authority gave an overview of current challenges; and finally Fiona Howie, Chief Executive of the national organisation Campaign for National Parks, summarised the many current problems being faced by National Parks, including the uncertain future for their farming and commoning communities, and the important role that their ‘critical friends’, the National Park Societies, have to play.

Delegates then set off to return to their homes as far away as Dartmoor, the Lake District, the North York Moors and the Broads, to name but a few.

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Public Pressure on the Forest : Presentment from the New Forest Young Commoners Group

Here we welcome a guest post from Oliver Cook, Chair of the New Forest Forest Young Commoners Committee, who gave this Presentment in this month’s Verderers Court.

As Young Commoners, we recognise the vital contribution that tourism plays in the local economy and through the very definition of “Commoning” we very much understand the concept of sharing this remarkable area that we are fortunate enough to live and work in with others.

Despite this we too are genuinely concerned by the effect that ever increasing public pressure is having on the Forest’s Landscape, ecology and traditional practices (particularly commoning). Greater visitor numbers is not something that is going to change, nor should it, however we believe that actions must be taken now to help manage the associated impact.

This is not the responsibility of any one body. We believe that it is the responsibility of all individuals and organisations that have a management role or other interest in the Forest. The commoning community is currently looking into how social media can help educate visitors of the Forest to ensure that they are better informed on how the commoning system works and how they can come and see our livestock without inadvertently putting themselves or our animals in danger. We are here today to call for support from the key Forest Authorities to assist us in our challenge, and we make the following four requests and recommendations:

  1. We believe that the quality of the experience for all users should be prioritised over the quantity of visitors that we can get to the Forest. Whereas other National Parks may struggle to attract visitors to support the tourism industry, our problem is how to manage the large volume of visitors that we already receive. Our first request therefore is that there is a shift in policy away from the Forest’s Authorities proactively marketing the New Forest as a tourist destination, which includes promoting arranged events/attractions.
  2. We echo the CDA’s concerns with the increasing number of organised events in the Forest and their impact on commoning activities. The difficulties of trying to navigate the Forest roads with a livestock trailer when there is yet another organised cycle event on or being prevented from “drifting” a particular area due to concerns that there is another organised event on or that there are simply too many people, are specific examples of activities which are collectively beginning to reduce the enthusiasm of the next generation of commoners to get involved. Clearly the implications of this do not need to be explained.We suggest that an effort is made to encourage organised events to take place on Private land which is not as environmentally sensitive and where events are not going to provide obstacles to commoning activities.
  3. We are very concerned by the lack of understanding that our visitors (from both nearby and afar) have about the New Forest. We feel there needs to be a greater effort to inform and educate people on the “do and donts” of our “working Forest”. We urge all Forest Authorities to be more proactive in this regard, whether it be at the Forest Campsites, carparks or on various social media platforms.
  4. The enforcement of the Forestry Commission’s bylaws should be a method of last resort, however, we believe that their profile should be raised and their messages promoted. Also, their enforcement must be one of the tools in the toolbox to be deployed in certain circumstances when there is a clear repeated breach due to a lack of respect for the Forest. We believe that there is currently an impression given that there is no will for them to be enforced, surely this is not a healthy impression to give.

Let me be clear, we are not asking to have the Forest to ourselves, we are simply asking for help with mitigating the impacts of a problem, which if not addressed, we believe will see a decline in the enthusiasm of the next generation of commoners to get involved.

Oliver Cook. a practicing Commoner, is Chair of the New Forest Forest Young Commoners Committee. This has been shared with his express permission, and represents the view of the New Forest Young Commoners Group.

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Recreational Harm : Presentment from the Commoners Defence Association

Here we welcome a guest post from Dr Tony Hockley, Chairman of the New Forest Commoners Defence Association, who gave this Presentment in this month’s Verderers Court.

The September court heard several presentments on pressures and abuse of the New Forest. The CDA supports such concerns.

Commoners have long been involved in educational efforts. But education alone will not suffice for companies that see the Forest as a profit opportunity, or for those who care only for their own entertainment.

Enforcement action is a sad necessity. In 2005 the Forestry Commission prosecuted one of the kite-buggy riders using Wilverley Plain*.  That sent a warning to others.  Similar resolve is needed on other routine breaches of the byelaws.

I would highlight two current issues that typify the challenges that can only be resolved by the Forestry Commission:

  • The Ordnance Survey, another public body, has started to facilitate mountain-bike trespass; allowing subscribers to its online mapping service to upload their routes for others to follow. The Forest is now covered with these unlawful routes.
  • On 2nd December the Forest will face its first commercial event in the hours of darkness. It is sponsored by a headtorch company, and hosted by Foxlease. For £30 entrants are offered the thrill of a night-time incursion into Forest. The company says that the racer will have: “a wealth of wildlife to keep your mind occupied”.  **

Both of these are abuses of the Forest that the Forestry Commission could and should stop. It seems that the tranquility of the Forest is being sold to anyone capable of making money from it whilst we all stand by. Our livestock and this special place deserve much better and we would urge to Court to do whatever it can to make this case.

Dr Tony Hockley is a Practicing Commoner and Chairman of the New Forest Commoners Defence Association.  This has been shared with his express permission, and represents the view of the CDA.

* Verderers Court minutes, January 2006 (item 2006/2082).
** This event is promoted by Maverick Race as part of their Silva Dark Series of night time trail running events, Silva is the headtorch sponsor.  http://www.maverick-race.com/races/silva-dark-hampshire-2017

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Saving the Future of the Forest: a Verderers Court Presentment

Here we welcome a guest post from one of our Members, Ian Thew of Burley, who gave this Presentment in this month’s Verderers Court.

Official Verderer, members of the Verderers Court, good morning and thank you for this opportunity to speak to you..My name is Ian Thew and I live deep within a New Forest Inclosure and for many years I have been an active New Forest Sporting Licencee; in consequence of which, I’m probably more aware of what is happening on the Forest than most people.

I am here today to express my fears for the future of this unique place that we call the New Forest. The New Forest National park is the smallest and in many ways the most fragile of all the National parks but contains more special designations protecting fauna and flora than any other. During the past few months, I have witnessed enumerable off-road and night-time cyclists; many, so called, wild campers; overnight camper vans in Forest car parks; several incidents of fly-tipping and on two occasions my wife and I have been subjected to, all night long, heavy base music bouncing across the Forest and, on another occasion, we had to deal with a party of rowdy scouts at 1.30 in the morning. I could go on but I do not wish to waste the time of this court; I am merely trying to demonstrate the enormity and the variety of the abuse that this Forest is being subjected to.

It is obvious, from the overflowing car parks and the masses of gazebos and tents that sprout-up like small villages across the Forest during the summer, that there are just too many visitors for this fragile environment to cope with. At the moment, recreation is taking precedence over conservation and protection of the environment which is in direct contradiction of the Sandford Principle.

There is no doubt that visitors are here to stay and, as one who makes part of his living from tourism, their business is welcome. But, for the sake of the future of the New Forest, their numbers must be limited to a sustainable level and their activities must be restricted to those that do not inflict harm on this very special environment. The ground rules should be clearly apparent to all who come here so that ignorance cannot be used as an excuse by those who offend and, similarly, it should be policed and there should be provision to enable those who are protecting the interests of the Forest to penalize or prosecute those who choose to ignore these rules.

Enforcement of the by-laws on the New Forest Crown Lands is the responsibility of the Forestry Commission who seem to be reluctant to prosecute offenders. Furthermore, we have been told that budgetary restrictions have reduced the numbers of front-line people on the ground. But this cannot be used as an excuse for the ruination of the New Forest and the necessary funds must be made available to enable sufficient policing and prosecution when necessary.

This budgetary shortfall is now common knowledge and I am often rendered speechless and helpless when informed by offending, anarchistic visitors that there is nothing I, or anyone else, can do about them. Surely it’s time that something is done, before it is too late, to stop these people, who are hell bent on destroying that which we all love and cherish and that which the majority of people come here to enjoy.

That his Forest is under threat is obvious to all; so what are we going to tell our grandchildren or our great grandchildren when they ask us why we didn’t do something to save it before it was too late?

I request that the Verderers use the authority of this court to urge the Forestry Commission to police the New Forest and enforce its by-laws and, similarly, to urge the New Forest National Park Authority to exercise their duties in accordance with the Sandford Principle.

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Presentment: Thanks to FC for continued Fungi policy / England Coast Path shortcomings

Fungi

The NFA hope the Verderers will join us in thanking the Forestry Commission for their continuing attempts to protect fungi vital to the habitat of the Crown Lands. As they did last year, the FC are still working to disrupt the illegal commercial picking and appealing to the public not to pick as well. In this, the Forestry Commission are fulfilling their legal duty as stewards of the Forest habitat.

The national code of conduct[*] says It is inappropriate to pick fungi from SSSI or National Nature Reserves – the Crown Lands have the Status of both. It is explicitly illegal on National Trust land under their byelaws, and would be illegal under the FC byelaws[†], but for the loophole created by reclassification of fungi as separate to the plant kingdom.  Under the Wildlife and Countryside Act 1981[‡] on SSSI’s “intentionally or recklessly destroying or damaging flora or fauna by reason of which land is of special interest” is an offence. The New Forest is one of the few SSSI’s so notified for the special interest of its fungi.

Picking any of the Red Band Rare Species of Fungi[§] is absolutely illegal by anyone, anywhere, and carries £5k fine per item with jailtime and vehicle forfeiture. The NFA believes that prosecution of these offenders would discourage commercial foragers more than lesser penalties under the Theft Act 1968.[**]

England Coast Path

I listed some of the England Coast Path’s shortcomings at the July Court, now a short update.

Currently the Natural England Coastal Team have offered a Sensitive Features Appraisal to determine exclusions for habitat, a very narrow consideration of features at risk. Unless this were to exclude the route, spreading and coastal margin from the highly protected areas out of hand, we should insist upon the more comprehensive, higher standards of a Habitats Regulation Assessment.

The new timeframe for the Consultation on the Highcliffe to Calshot stretch (set to begin between September 27th and October 19th ) unfortunately the majority of the consultation would fall before the next meetings of both the New Forest Consultative Panel, and the Local Access Forum, after next Monday’s meeting of the National Park’s Recreation Management Strategy Steering Group and with no planned meetings for the Advisory Group. This threatens to exclude any measured joint response from local stakeholders. As a member of the Steering Group, we hope the Verderers will join us in calling for an extraordinary joint meeting of both RMS groups to consider the consultation. Natural England are blaming their “parent” DEFRA for the time frame, and a looming March 2018 implementation date. We may need to remind both government departments that they should not be forcing a rush to judgement where disturbance to our most remote, isolated and protected coastal habitat is concerned.


[*] The Wild Mushroom Picker’s Code of Conduct 1998

[†] FC byelaws 1982, Section 5 Prohibited Acts: “No person shall in or on the lands of the Commissioners: … (vii) dig up, remove, cut or injure any tree, shrub or plant, whether living or not, or remove the seeds therefrom, …”

[‡] Wildlife and Countryside Act 1981 Section 28 (P)

[§] Schedule 8 Wildlife and Countryside Act 1981

[**] Given the indiscriminate harvesting by commercial pickers, it is likely that, if caught, their haul may include samples of rare species which may be used in evidence.

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England Coast Path: Our Letter to the New Forest Access Forum

England Coast Path

The England Coast Path (ECP) will create new non-historically based Rights of Way which may also join up existing Rights of Way, including the Solent Way. It will also provide spreading room in the form of the coastal margin defined between the route of the path and the water’s edge. This is particularly problematic as our coast includes a nearly uninterrupted series of highly designated and protected habitats of international importance alongside which the route will necessarily skew inland. The New Forest Association wish to raise concerns about the scheme, many of which will pertain regardless of the published route.

Increased use and disturbance:

New routes will impact on tranquility and habitat disturbance. Joining up of existing routes will increase their use and hence their impact. Spreading room applied to existing routes will create new access which will also cause disturbance to areas those routes avoided. With no funding for mitigation and parking infrastructure; some stretches, near or on small country lanes in the most remote parts of our coast would exacerbate the verge parking problem.

Coastal Margin:

Whilst Natural England’s powers to exclude areas from the coastal margin include habitat considerations under Section 26 of the CROW Act, the protective measures are paltry (minimal signage and barriers) and the Ordnance Survey’s depiction of all potential coastal margin as one colour shading without differentiating or delineating the exclusions will mislead many into protected areas. Worrying precedents have been seen: the published proposed Portsmouth to South Hayling route appears not to have any habitat exclusions under S26, this leads to glaring omissions of vulnerable wader roosts on vegetated shingle beaches (Consultation ending Sept 13th 2017).

There are weak provisos that the OS will claim covers the depiction issue (see figure). These do not even mention exclusions for habitat protection. There is no guarantee that this language will even be included on all relevant OS maps, nor that they will be featured at any remarkable scale for legibility. Excluded areas should be the majority of the margin along our coast, and should either be shown accurately, or not shown as access land at all.

The coastal margin / spreading room model is wholly inappropriate for our coast. Setting exclusions at mean high water mark could allow access into neighbouring excluded area at all times outside of high tide. Intruders can simply walk across from adjacent accessible foreshore. Additionally as the crossing point for rivers are necessarily sufficiently inland, the model becomes unworkable, complicated by different handling of “rivers” and “estuaries” and the length of a piece of string debate as to where one definitively leads to the other.

According to the NE Coastal Team “Discussions regarding the representation of the coastal margin were held with a national stakeholder group, this involved NE, NFU, RSPB, CLA, National Trust and the OS amongst others – this representation is not within our remit.” Despite this, NE still have the obligation to protect the coastal habitats that may be trespassed upon as a consequence of the depiction issue.

Weak Habitat Protection:

There is little or no serious consideration of sea level rise and effects of erosion. Where present, again ignores coastal habitat value and frames issues solely within effects to landowners. Coastal habitats would end up being squeezed between the established path and the advancing sea.

Currently the Natural England Coastal Team have offered Sensitive Features Appraisal which narrowly considers only certain items at risk, as if in isolation. The higher standard provided by Habitats Regulation Assessment is more appropriate for this very protected stretch of the National Park. Unless the proposed Appraisal were to exclude the route / spreading / coastal margin for these areas out of hand, the Habitats Regulation Assessment should be insisted upon. We would expect this to exclude these habitats comprehensively.

Purpose:

While the path is being promoted for useful alternative recreation, pleasant views and tourist destinations, in other regions this may be desirable. Here it is:

  • Unnecessary – There is no actual need for the path.       The Forest does not want for draws to Tourism.
  • Arbitrary – The notion of a “coastal” path is merely a goal for completists, like those who want to walk Hadrian’s Wall, Land’s End to John’O’Groats etc. While a nice paper exercise for box tickers and sponsored walks, other paths / destinations are otherwise available.
  • Redundant – The Solent Way (aka Solent Coast Path) already follows much of the Hampshire coast line and passes through the New Forest; it also forms part of the European Coastal Path (E9).
  • No Benefit – Any suggestion that the path would draw recreational pressure away from other areas of the Forest is a robbing Peter to pay Paul argument, and perhaps worse as the coastal habitats have been better protected and thus more prone to fresh disturbance than other areas where sadly much damage has already been done.

Consultation on the Highclifffe – Calshot stretch:

Unfortunately the consultation timeframe (eight weeks, likely 27th September to Nov 22nd) unhelpfully falls between both the New Forest Access Forum and New Forest Consultative Panel quarterly meetings and does not take into consideration either of the pertinent National Park’s Recreation Management Strategy Steering and Advisory Groups. I’ve suggested NE move the end date to December 21st at the earliest, two weeks after the Consultative Panel, but I otherwise presume sub-groups would be formed to respond within the currently mooted dates. I respectfully offer any sub-group formed by this Access Forum, at its convenience, a presentation from one of the New Forest Association’s ecologists which would help contextualize the extremely high value of the habitats and species at risk near or on the route. I hope this would convey a more comprehensive picture of what’s at stake, than the information provided by the Natural England team tasked with delivery and promotion of the route has yielded thus far.

Thank you for your time and attention to this important Access issue,

Yours,

Brian Tarnoff
Chair, Habitat And Landscape Committee
New Forest Association / Friends of the New Forest


Update: We would now withdraw our objections about the Sensitive Features Appraisal, which should overlap sufficiently with a Habitats Regulation Assessment, however, we would still insist that the route and spreading room should comprehensively exclude the important designated habitats.

Although the timeframe of this consultation has slipped repeatedly since originally mooted for February 2017, the March 2018 launch date has fallen just after the 12th March meeting of the New Forest Local Access Forum, would have fallen after the 1st March meeting of the New Forest Consultative Panel.  The Panel was postponed by inclement weather to 19th April, giving it less than three weeks to formulate comment on the consultation (and its 72 page overview 81 pages of route detail and 213 page Sensitive Features Report).

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Recreation Management Strategy Survey Response

Our response to the Future Forest RMS Survey launched by the New Forest National Park Authority.  We call for priority projects to address outdated infrastructure, boost regard for protecting the Forest with neighbouring authorities, and education focusing on the Forest status as a National Nature Reserve and working commoning landscape.  We sidestepped the unintentionally restrictive and misleading elements of the survey (including categories and canned language from the previous Strategy document) to focus on demand for plans for action with clear goals and realistic time frames.

Recreation Management Strategy Survey Response

The New Forest Association welcomes this opportunity to feed into ongoing Recreation Management on the New Forest and this survey meant to guide the Strategy’s next incarnation. We hope this process will deliver a more focussed strategy that yields high priority projects to reform our outdated recreation infrastructure, and elevates the discussion of the National Park as a protected natural landscape requiring a duty of care from ourselves and our neighbours.

Reference to Park Purposes and Special Qualities

Both the New Forest National Park and its younger sibling, the South Downs, are the two most densely populated national parks in the UK, and have significant populations in environs for regular use and day visitors. Unlike the less populated, more remote parks, the recreation management goals should firmly be based on the purpose to Protect.

This is summed up in English National Parks and the Broads UK Government Vision and Circular 2010:

However, in light of research published in 2005 (20), the Government recognises that not all forms of outdoor recreation are appropriate in each Park and that activities which would have an adverse impact on the Parks’ special qualities and other people’s enjoyment of them may need to be excluded (in order to meet the requirements of section 11A(2) of the 1949 Act).

All of the “Special qualities”: outstanding natural beauty, habitat, heritage, commoning / working forest, free roaming livestock, tranquillity, quiet recreation, low levels of urbanisation are under threat from increased recreation pressure which disturbs and destroys habitat, creates wear and tear on the fabric of the Forest and interrupts tranquillity. The aim is not to invite more recreation than the Forest may sustain, but to protect the Forest by managing the recreation that takes place here, and honour the Sandford Principle as enshrined by the 1995 Act.

An Actual Management Strategy

We need more focus on practical, achievable goals, along with a plan that can achieve them within defined timeframes to which the Park and its stakeholders may commit. It’s all very well and good to list our many aspirations as the current strategy does, but few of the “within 5 years” goals have been achieved in its first seven years.

The main way we can control where recreation happens within the Forest is where people park and camp. Outside of the Park we can call for greater alternative recreation provision, and less development that swells the population and moves a hard urban edge toward the park boundaries. Priority projects must be chosen and developed from our aspirations, to achieve significant gains to Protect the Forest, particularly the open access areas of the Crown Lands and their adjacent Commons.

Infrastructure Within the Park

(Sustainable services and facilities / Camping and caravanning / Joined Up Routes / England Coast Path)

We’ve inherited an outdated infrastructure imposed in the 1960’s that replaced the previous free for all with over 130 Forestry Commission car parks and 10 camp sites. While these disperse activity throughout the Forest, and have come to be relied on by their users, no one can say that they are in the best places to protect our more sensitive habitats and species from disturbance. We do know that the campsites in the A&O Woodlands of Holland’s Wood and Denny were slated for removal under the SAC Management Plan 2001 (their management for camping has degraded their habitat, our campsite survey showed these have less than half the canopy they ought).

Practical steps to make this provision fit for purpose must be taken. A straightforward assessment of the current provision could easily be carried out ASAP. A well designed assessment of the habitat to create the evidence base against which to model future proposals for recreation infrastructure placement would be the next highest priority. Discussions may include charging for car parks to cover maintenance and on the ground resources, models for camping provision both elsewhere on FC land and/or on private land. Delivery of “joined up routes” and The England Coast Path would be subject to the results of any relevant habitat assessments and should not go forward in their absence.

Infrastructure Outside the Park

(Influencing recreational provision beyond the boundaries of the National Park)

A huge wave of development is proposed on our borders, given little strategic consideration for the Park, unreasonable housing targets from Central Government for all local authorities, token mitigation which does not adequately reflect the value of the Forest, we’ve little hope for avoiding a substantial increase of recreational activity that will be dumped on the Forest. The Forest is under a palpable threat, and needs influence on both development and recreation provision outside the Park.

Our adjacent and concurrent authorities have shown little respect to their Environment Act 1995 Section 62 duty to have regard to National Park purposes. Sometimes the opposite, Test Valley Borough Council once proposed using National Trust Foxbury (adjacent to Common and an SSSI candidate) within the park as SANG mitigation for one of their housing schemes. Section 62 must be considered by our neighbours, not merely for mitigation purposes but for all development.

The mitigation regime is limited, flawed, and does not proportionally value the New Forest. SANG mitigation schemes are based on figures developed by Natural England regarding the Thames Basin Heaths SPA which has a fraction of the notified features that the New Forest possesses, if these were properly scaled up to reflect the Forest’s relative habitat value, many SANG’s on offer would need to be nearly the size of the Forest itself. SANG sites themselves may have their own designated habitats that are sacrificed, and many are proposed with no long term plan or funding for their maintenance.

We must make the debate about these allocations more visible, more public. The New Forest is the last stand for many of its habitats throughout the UK, it is of national and international importance, our neighbours and central government need to be constantly reminded of this.

Education

(Raising awareness and understanding)

Whilst this is already the National Park’s strongest suit, there are certain nuances missing. The National Park has made great inroads in areas such as social media. However, even at our own 150th Anniversary keynote event in January 2017, the audience of very engaged locals clearly included many who still did not understand the Park’s purposes, functions or capabilities. This perhaps suggests that the Park still has work to do piercing the bubble beyond their current success.

One of the key problems the National Park has to overcome, is the word “Park” in its name, which too often is taken for “a large public garden or area of land used for recreation” . Explaining the legislation that gives the “National” prefix its protective connotation, and the slew of habitat designations and their acronyms does not thoroughly dispel that erroneous notion. The message up front should be simplified, the Crown Lands have the status of a National Nature Reserve, a Working Farm and Forest. With that in mind we can then ask “what activities are appropriate there”, “in order to protect such a place, what are you willing to do differently or do without?” “We have the privilege of open access to this place, what responsibilities must we take on?”

Conclusions

The next RMS should include the following priority projects:

  • National Park Infrastructure –
    • Parking and Camping Provision Assessment
    • Habitat Assessment / Evidence Base
    • Actions to lead to provision design Fit For Purpose
  • Adjacent Authorities and Communities –
    • Raise the profile of development on our borders that will affect the Forest
    • Brief Decision makers on impacts on the Forest and Section 62 Duties
    • Make nearby communities aware of their representatives responsibilities
    • Promote adequate, proportional mitigation
    • Petition Central Government for more strategic targets to take pressure off the Forest
  • Education –
    • Develop clearer more straightforward messages
    • Look to reach other audiences
    • Easily highlight the Forest’s need for protection
      • National Nature Reserve
      • Working Farm
      • Working Forest
      • In context of the ongoing Habitat Loss in the UK

Whilst other aspirations remain, solid plans and policies addressing these areas will have the most impact. Consultation over future versions of the RMS should include messages consistent with the National Park’s purposes and priorities, and not be shy in making a case for resources and changes necessary for implementation. The NFA hope to be able to support this Authority in its efforts to Manage Recreation in The New Forest, and willing to lend our time, knowledge and resources towards achieving these priority tasks in provision redesign, influence on strategic planning and mitigation, and education.


ADDENDUM:

English National Parks and the Broads
UK
Government Vision and Circular 2010

4. Priority Outcomes for 2010 – 2015 and suggested actions
4.1 A Renewed Focus on Achieving the Park Purposes page 10

  1. The Parks contain a variety of landscapes, capable of accommodating many different types of leisure activity. Authorities should continue to identify and promote new access and recreational opportunities and ways of delivering them, working proactively with a range of statutory and non-statutory interests such as local access forums (see section 5.6), Natural England, English Heritage, voluntary sectors and, particularly, farmers, commoners and landowners. However, in light of research published in 2005 (20), the Government recognises that not all forms of outdoor recreation are appropriate in each Park and that activities which would have an adverse impact on the Parks’ special qualities and other people’s enjoyment of them may need to be excluded (in order to meet the requirements of section 11A(2) of the 1949 Act).

(20 Demand for Outdoor Recreation in the English National Parks – Countryside Agency October 2004 (updated March 2005 and published alongside a Guide to Good Practice in managing and promoting outdoor recreation in the Parks) )

NFNPA/RPC 51/08 Page 1

The National Park’s special qualities
The New Forest National Park’s landscape is unique; it is a ‘living’ and working remnant of medieval England with an overwhelming sense of continuity, tradition, and history. It is the survival of not just one special quality but a whole range of features that brings a sense of completeness and integrity.

These features include:

  • the New Forest’s outstanding natural beauty: the sights, sounds and smells of ancient woodland with veteran trees, heathland, bog, autumn colour and an unspoilt coastline with views of the Solent and Isle of Wight
  • an extraordinary diversity of plants and animals of international importance
  • a unique historic, cultural and archaeological heritage from royal hunting ground to ship-building, salt making and 500 years of military coastal defence
  • an historic commoning system that maintains so much of what people know and love as ‘the New Forest’ forming the heart of a working landscape based on farming and forestry
  • the iconic New Forest Pony together with donkeys, pigs and cattle roaming free
  • tranquillity in the midst of the busy, built up south of England
  • wonderful opportunities for quiet recreation, learning and discovery in one of the last extensive, gentle landscapes in the south including unmatched open access on foot and horseback
  • a healthy environment: fresh air, clean water, local produce and a sense of ‘wildness’, low levels of urbanisation
  • strong and distinctive local communities with real pride in and sense of identity with their local area

 

  • SUMMARY: outstanding natural beauty, habitat, heritage, commoning / working forest, free roaming livestock, tranquillity, quiet recreation, low levels of urbanisation, local communities
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