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Recreation Management: What We Should Keep and Add

The 2018 RMS Survey Proposals drop important Actions from the Current Recreation Management Strategy 2010-2030. We discuss what we’d want kept, and propose other useful key projects.

Actions to Retain from Current RMS 2010-2030

All the partner organizations were part of the extensive consultation that produced the existing strategy, which they would have had substantial say in and adoption. The objectives of the existing Strategy are “owned” by definition by the National Park which includes that Strategy as one of its core documents. Whilst it’s true that the Park Authority has limited direct responsibilities and powers, it’s incumbent on them to use their influence on those organizations that do, and there is a legal obligation for those bodies to listen and act accordingly.

One of the reasons that we find that the new proposals are not a substantial improvement over the existing RMS is that it leaves out specified actions which we continue to support. In some instances there are references to these in the survey, but passing or implied inclusion of these actions is insufficient as they should be explicitly included. Here is a non-exhaustive list of actions which should be considered for stated inclusion, with some suggestion for amendment or extension into new projects.

Develop a National Park Ranger Service

5.3 Raising awareness and understanding
5.3.3 Work with the recreation user groups and land managers, to promote responsible behaviour amongst all users that respects the special qualities of the National Park and the needs of others through a range of mechanisms, and especially by:
A.. Face to face contact with co-ordinated ranger services, providing a friendly and knowledgeable presence able to convey consistent messages
5.3.5 Develop a National Park Ranger Service which is responsive to the needs of the Forest as they emerge, and facilitate the co-ordination of existing ranger services within the National Park. Consider establishing a Young Friends of the New Forest Group to involve and engage young people more in the area.

5.3.3 Referenced absent Ranger Service aspiration 1.1 and 2.1
5.3.5 Passing mention 2.4 on the ground “mitigation rangers” and 5.2 funding

Credible enforcement of any rules developed, or even the existing byelaws, would require an investment in personnel. We would want to see this ambassadorial role extended to include some elements of enforcement.

We cannot necessarily expect either FC Keepers or Rangers, or NPA Rangers to fulfil the role of enforcement. It may be that a new role modelled after the Foreign style “Park Ranger”, that is with some police training and enforcement powers should be considered. There needs to be enough of a perceived enforcement presence, whether directly from beats of such rangers, or the extended eyes and ears of the combined other Rangers/Keepers/Agisters network for Park users to sense that they could be seen or challenged for inappropriate or illegal behaviour. We recognize that this would require funding, but providing this service would shore up any funding plans that require charging which itself would need enforcement to be effective.

Influencing beyond the boundaries of the National Park

5.9 Influencing recreational provision beyond the boundaries of the National Park
5.9.1 Outside the National Park, work in partnership with other Authorities to improve recreational provision that provides for their community needs (thereby helping to relieve pressure on the New Forest Special Area of Conservation). Ensure that recreation provision is at the forefront of planning for major urban expansion within a 20km radius beyond the boundary of the New Forest.
5.9.2 In partnership with neighbouring authorities, actively support their search to identify and implement opportunities for new Country Parks or similar and advocate the inclusion of these aspirations in the local development frameworks and core strategies of neighbouring authorities.

5.9.1 is not indicated in any way by the new proposals. In light of NFDC’s current draft local plan targeting 10,500 houses over 10 years, the commensurate surge in local population using the Forest, and NFDC’s low quality standards for Suitable Alternate Natural Greenspace (proposal to use degraded arable rather than setting a standard to offer land restored to a quality commensurate with the protected habitats for which it is meant to mitigate), this is clearly an important action.

5.9.2 could be construed to have a passing mention as an ambition Objective 4’s statement and glancing mention in Objective 5 Funding, but it is not featured amongst the Actions. Given that infrastructure needs may demand the wholesale destruction of the nearby habitat of Dibden Bay along with greater stress on local transport infrastructure, perhaps it would be reasonable to suggest that the National interest would demand a substantial mitigation which perhaps could include compulsory purchase of sufficient well placed land to fulfil the ambitions for Country Parks that would offset damage and act as preferred recreation sites.

Below we have proposed new projects to extend influence to neighbouring authorities: “Habitat Mitigation Framework for the Forest that is Fit for Purpose” and a “Strategic Regional Development Forum.”

Camping and Parking Infrastructure

5.6 Providing sustainable services and facilities
5.6.1 Undertake a review of recreational and visitor facilities in the National Park.
5.6.3 Manage car parking in the National Park as a means of providing access for people to the New Forest and managing impacts on the most sensitive areas. Overall car parking capacity across the National Park is not anticipated to increase or decrease significantly from existing levels:
A.. Audit car parking provision within the National Park6.4 Camping and caravanning
6.4.1 Audit the provision of camping in the National Park and maintain the unique experience the New Forest offers; sustain the significant contribution it makes to the local economy whilst ensuring that campsite management does not adversely damage the Park’s special qualities.
6.4.2 Work with partners to identify potential alternative sites to which the phased relocation of the more damaging campsites (e.g. Hollands Wood, Longbeech and Denny Wood) might be achieved whilst providing a similar quality of camping experience. It must be recognised the difficulties in finding alternative sites; many issues will have to be taken into consideration, including the local economy, transport links, access to facilities (e.g. villages, shops) and the camping experience.
6.4.3 Work with campsite operators to reduce the environmental footprint and impact of camping and caravanning on sensitive areas to enhance landscape and visitor satisfaction by:
.. preventing the extension of existing and development of new camping and caravan sites
.. restricting the spread of new supporting built facilities
.. ensuring that any built facilities that are provided reflect their surroundings
.. securing more sympathetic conservation management of existing camp sites
.. monitoring the condition and operation of the sites on designated areas.6.4.4 Explore opportunities to develop campsites as substitutes to those displaced from the commonable lands as a valuable form of farm and business diversification in robust locations.
6.4.5 Provide further guidance on the future management of campsites to reduce the dependency on car use, for example, by encouraging campers to leave their cars on site whilst visiting the National Park and continuing to promote alternatives to the private car for travel around the Forest.

5.6.1, 5.6.3 and 6.4.1 Audit of parking and camping provisions and facilities – a very straightforward achievable bit of work, unfortunately not yet done eight years later.

Below we have proposed new projects to address campsite issues: “Bring temporary campsites under a regimen of consistent standards and controls” and “Close Hollands Wood, Denny Wood and Longbeech Campsites”. Both of these would augment the goal in Policy DP18 “enable the removal of pitches from sensitive areas by the relocation of part of a site to a less sensitive area”.

New Forest National Park Core Strategy Policy DP18: Extensions to Holiday Parks and Camp Sites
Extensions to existing holiday parks, touring caravan or camping sites will only be permitted to enable the removal of pitches from sensitive areas by the relocation of part of a site to a less sensitive area adjoining an existing site, providing:

  1. a) there would be overall environmental benefits
  2. b) there would be no increase in the overall site area or site capacity
  3. c) the area where pitches or other facilities are removed from would be fully restored to an appropriate New Forest landscape, and any existing use rights are relinquished.

To be supplanted by almost identical Submission Draft Local Plan 2016-2036 Policy DP47: Holiday Parks and Camp Sites removes the restrictive stipulation “adjoining an existing site”

Possible RMS Projects

This is a non-exhaustive list of possible projects that would be welcome ways of delivering the aspirations which should have been more explicitly spelled out in the survey document.

Research Station for the Forest

This would pool resources to staff and deliver a focus for New Forest research. It would maintain a catalogue/concordance of extant research, coordinate research efforts from academic institutions, quality check citizen science, and encourage research to provide evidentiary base for spatial strategy, recreation and livestock impacts on habitat, climate change or any other key criteria for future decision making.

Habitat Mitigation Framework for the Forest that is Fit for Purpose

Mitigation regimes use formula developed by Natural England for Thames Basin Heaths, which does not scale appropriately to the Forest because a) the Forest is much richer in features and biodiversity at threat and should cost developers more b) the morphology of the Forest is different: Thames Basin Heaths spatially has greater opportunity for alternative spaces, where the Forest, surrounded, creates more of a siege situation (with only one defence to the West at Moors Valley, and plans to the East eternally pipe dreamed).

Strategic regional development Forum

In the past some planning regimes managed on a more regional basis was able to reduce pressure in and around the Forest. Both the promises of the government’s 25 Year Environment Plan and its subsequent upcoming review of National Parks should be an opportunity to put the case again. Recreation pressure on the Forest is directly affected by population proximity, housing targets within and on the borders of the Park. If the park and its borders cannot be afforded a sufficient buffer zone that retains its own green belt with sufficient alternative natural greenspace, then the government’s promise of increased protection to our parks and habitats is hollow. The Draft Action proposals have relegated engagement with other authorities to mitigation (which as already noted is undercooked), housing targets with direct impact on Forest recreation are relevant under Section 62 Duties.

Bring temporary campsites under a regimen of consistent standards and controls

Both these camping projects (see below) could help address the obligation under the 2001 SAC Management plan to relocate three FC Campsites (Five year priority 6.4.2 of RMS 2010). Temporary campsite provision in and around the Forest should provide a consistent minimal standard and be subject to appropriate licensing. This could lead to a Charter, or even a scheme similar to “New Forest Marque” for campsites to assure visitors of a Park led standard of quality, and perhaps, oversight. It may also be appropriate to encourage some small pop-up sites as alternative temporary use of backup land during the peak tourist summer season, which could serve as an additional income for commoning.

Close Hollands Wood, Denny Wood and Longbeech Campsites.

The Natural England’s SAC Management Plan for the New Forest 2001 (page 30, Part 3: General Prescriptions) gave “Unfavourable Declining” condition assessments to Hollands Wood, Denny Wood and Longbeech due to the presence and management of the campsites.   The Campsite Survey (New Forest Camp site Baseline Survey: Final Report (Cox, Jonathan: July 2010: Lyndhurst: New Forest Association)) showed these have less than half the canopy they ought. This Authority’s Landscape Action Plan doesn’t even have the word campsite in it, let alone a consideration of their impact. The NPA need to address this remiss approach.

 

 

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Recreation Management: Evaluated Actions

Detailed Response To the Draft Actions

The 2018 survey proposals consider 25 “Actions” spread over 7 “Objectives”.

For the most part these are bland statements of guiding principles, but offer few concrete strategic steps to manage recreation. It is difficult to formulate a response to such an underwhelming document. On their face, it is difficult to quibble with the stated actions they vary from statements of the obvious (apply enforcement to illegal recreation activities) to standard operational concerns (find funding and consider charging the beneficiaries of recreation), but there is almost no substance (much talk of developing mechanisms and techniques with no useful specificity). Much of it is not well written, eschews plain English, and may be left to so much interpretation that opposing views may inaccurately be imposed on its meaning. It may seem pedantic or churlish to point out these flaws in the presence of obvious good intention, but this is meant to form a core policy document of a National Park Authority, it should include clearly stated proposals.

The main problem is not the writing, or the bland proposals, but what has been left out, either dropped from the previous RMS Strategy, lost through omission by vagueness, or simply not considered.   These include Management actions meant to fulfil the obligations of the SAC Management Plan. What follows here is an in depth critique including the full text of the proposed Objectives/Actions for reference, we have detailed omitted or alternative actions, and our summary remarks and conclusions are available separately.

By and large, the stated Objectives are relatively sound, having antecedents in the existing 2010 Strategy. The descriptions of each are at the heart of the good intentions of this revised Strategy, yet they’re not even up for discussion, only the proposed “Actions” are offered up for evaluation. There has been a truly odd decision in the presentation of these core descriptions in the online survey, by default they are hidden, requiring respondents to manually “unhide” each. Additionally a Draft Criteria for Judging Recreation Facilities has been published to the Managing Recreation web page but no comment is sought for this in the survey.

Raising awareness and understanding –
ensuring recreation is sustainable, wherever it takes placeObjective 1: Convey the things that make the New Forest special to both visitors and local people in more consistent and effective ways, so that they understand the importance of making responsible recreation choices.This objective acknowledges that the level of awareness of the New Forest’s special qualities, and their sensitivity, is currently insufficient. People who enjoy and come to understand the New Forest are much more likely to value and want to protect it, so it is important to work together in a range of ways to create a greater sense of ownership, respect and responsibility that ensures the Forest will retain its unique features into the future. The work needs to be tailored to resonate with the varying motivations, values and interests of different audiences.

We fully support education initiatives. These objectives and actions are important and in many ways already in hand. We believe a change of emphasis from “the special qualities of a National Park” to “delicate habitats of a National Nature Reserve, working farm and forest” would highlight the need to protect, especially for those for whom “Park” is an urban greenspace for play.

Draft action Examples of possible delivery
1.1. Improve the quality and availability of information and interpretation about the special qualities of New Forest. Websites, social media, printed materials, exhibitions, film and face-to-face communication
1.2.Encourage organisations involved in tourism to inspire respect for the special qualities of the National Park by regularly including agreed key messages in their communications. Through Go New Forest, visitor attractions, publishers and accommodation providers
1.3.Develop the current programme of guided activities and themed events to give local people and visitors authentic experiences and meaningful connections with the special qualities. Guided walks, public events, activities in villages and training courses
1.4. Increase the uptake of formal educational programmes on offer and provide additional supporting resources on New Forest specific topics. Through Educators Forum, online curriculum-linked resources, travel grants, school assemblies, eco-groups and teacher training

Objective 2: Address significant and/or widespread negative impacts caused by recreation in the most appropriate, proportionate and effective ways.

This objective recognises that there are many different ways to encourage responsible recreation and to reduce or displace activities that might impact negatively on the New Forest or other people. It also emphasises the shared responsibility for protecting the Forest between relevant organisations and user groups. There is already broad recognition of the main issues, and some good initiatives are in place; but more work is needed to share best practice and jointly explore new ways to achieve the desired results.

Responsible recreation is an admirable goal. To some extent it should follow from education, a sense of respect, ownership, and as is suggested here “shared responsibility” for protection of the Forest.

Draft action Examples of possible delivery
2.1.To help address a range of different issues and aid joint working, develop a ‘toolkit’ of different ways to influence recreational behaviour. Best practice advice and training on face-to-face communication, ‘nudge’ techniques, making the right option the easiest one to take, printed materials and signage, websites, digital technology, social media, peer pressure
2.2.Through working groups with appropriate terms of reference or other joint initiatives involving local organisations and user groups, identify and implement the most effective and long lasting strategies to address significant and widespread negative impacts caused by recreation. Reduce disturbance of wildlife, feeding of animals, animal accidents, litter, verge parking, fungi picking and negative impacts of dog walking, cycling and horse riding
2.3. In support of other techniques, use appropriate and proportionate enforcement activities to deter illegal recreation-related activities. Address verge parking, litter, illegal flying of drones, wild camping, lighting fires, parking in car parks overnight, cycling off the permitted network and out of control dogs
2.4. Increase the number and effectiveness of staff, volunteers and ambassadors ‘on the ground’ who can encourage people to enjoy recreation responsibly. Through higher levels of funding, improved partner coordination, habitat mitigation scheme rangers, apprentices, joint training, citizenship policing and a new ambassador programme
2.5.Manage organised activities and larger events in order to minimise negative impacts on wildlife, the working Forest and on local people. Licences and permissions given for use of Crown land and other open Forest areas, and events given guidance by Safety Advisory Groups

 

2.1. “To help address a range of different issues and aid joint working,” is an unhelpful word salad and an unnecessary preamble to “develop a ‘toolkit’ of different ways to influence recreational behaviour.” which is vague enough on its own, but at least means: “develop ways to influence recreational behaviour” which is what I hope you’re trying to say.

2.2. Isn’t “Through working groups with appropriate terms of reference or other joint initiatives involving local organisations and user groups, identify and implement the most effective and long lasting strategies to address significant and widespread negative impacts caused by recreation.” exactly what this strategy is meant to be doing? Is one of the “Actions” genuinely for this Strategy to develop itself? The result apparently is to reduce all the ills of the Forest as listed as “Examples of possible delivery”. How that magically transpires is not specified.

2.3. “In support of other techniques”, which other techniques? If you can’t specify them, why mention them? “use appropriate and proportionate enforcement activities to deter illegal recreation-related activities.” Is it necessary to specify, when deterring illegal activities, use of appropriate and proportionate enforcement? Are you suggesting that, for illegal recreation activities disproportionate inappropriate enforcement is a known issue?

“Provide enforcement to stop illegal activities.” or “Enforce law” more apt / readable?

2.4. An initiative to better support, increase “on the ground” presence of staff with ambassador / education and most importantly some level of enforcement power would be welcome. If a Forest user feels that they may encounter Forest Rangers on perhaps one out of ten excursions (or whatever magic number that would inspire the public to feel that they are likely to be occasionally, even with the mildest touch, “policed”) The lofty aspiration perhaps beyond the grasp of current funding/enforcement models might be a Parks Service in the style of Foreign National Parks, like the US whose Rangers have constabulary powers, local wildlife and habitat keeping, and education expertise.

2.5. Again, managing organized activities and larger events, whether through permit systems or accompanied by Safety Advisory Group involvement (in non permit related venues) would require some level of enforcement to either insure that permit or safety stipulations were observed, or to confront those flaunting whatever system is in place. Additionally, it may be desirable, as part of wider road initiatives targeting the fenced and gridded roads to work towards powers for local Authorities to have greater say so in the use of those roads, which may lead to permits required for high capacity road using events.

Objective 3: Reduce the barriers that limit participation in beneficial outdoor recreation among those who need it most

The New Forest already helps people to maintain and improve their health and wellbeing, it provides training and employment opportunities and is an ‘outdoor classroom’ from which we can all learn. However, some people may feel excluded and others do not recognise the value of the Forest (to themselves, the wider population or to future generations). This in turn risks alienating important sectors of society and failing to make the most of the ‘natural health service’ that is available. This objective is therefore about targeted work with specific groups of people at locations that are well-suited for bespoke interventions or activities.

This objective is made more convoluted and possibly misleading by the fact that it makes much of its language vague in that obligatory dance around avoiding using a term that might offend people with disabilities. In doing so, they may have been equally patronizing, offensive, and so unspecific that anyone with a beef against “barriers” of any description, might feel they could be catered to. Additionally, there is an attempt to lump issues including “youth” which surely belong under education, and the general health of outdoor recreation, which in no way demands to be on the Forest (it is not an obligation for the Forest to provide). Conflating these issues is not helpful to any of them.

Society has an obligation to level the playing field to be more inclusive. How this practically extends to the Forest may not, or cannot remove all “barriers”. Replacing styles with kissing gates, or other manageable solutions, is likely within the purview, but paving paths, providing more pedestrian/equestrian/wheelchair friendly bridges is perhaps not. The chief problem with this section is it doesn’t confront the need to have that conversation, merely hinting at that below referencing “appropriate changes”, but with no criteria for what is appropriate. It would be disingenuous to suggest that every inch of access land on the Forest could be made accessible, nor do we think that any user group so demands.

Draft action Examples of possible delivery
3.1. Inspire more young people to appreciate and understand the special qualities of the New Forest and realise its relevance and value to them and to future generations. Through wild play, digital technology, training and apprenticeships, award schemes and inspirational youth-led projects
3.2.Develop targeted schemes that harness the health benefits of outdoor activity in and around the New Forest, close to where people live and at agreed locations. Regular walking, cycling, green prescriptions, volunteering, Green Halo Partnership and Health and Wellbeing Forum projects
3.3.Establish regular liaison between organisations that provide opportunities for outdoor recreation and organisations that represent people with a range of disabilities to identify and implement appropriate changes that will increase accessibility. Better information, fewer stiles or other ‘barriers’, accessible toilets

3.1. This point is more about using some recreation opportunities to promote education for youth, and belongs in Objective 1.

3.2. When discussing schemes to promote recreational activity, whether part of a health benefit scheme or not, the key aspect we would want to manage is where this takes place. This point belongs in Objective 4.

Sustainable recreation in the right places – managing where it happens
Objective 4: Achieve a net gain for the New Forest’s working and natural landscape and for the recreational experience by influencing where recreation takes place.This objective is primarily about geographical distribution of recreation and associated facilities; there are also links with earlier objectives with respect to specific sites where people are provided with information. An holistic, long-term vision and a short-term plan for agreed gateways, key sites and core routes is needed (within and beyond the National Park). Only by taking this ‘spatial approach’ can we be sure to attract people to the most appropriate sites and reduce the impact on the more sensitive areas and thereby protect the special qualities.

By using this approach, significant net benefits should be achieved. Desirable changes will vary considerably: from ‘easy wins’ such as the provision of additional information through local information points, through changes to the location of car parking provision (about which a range of views is likely to be expressed), to ambitions for new country parks outside the national park boundary that may take many years to come to fruition.

The long-term vision needs to address the following categories of locations:

  • a) Gateways: key access points such as certain villages, visitor centres and information points, rail stations and car parks near the perimeter of the Forest or close to A roads
  • b) Key sites: agreed popular sites for recreation such as country parks, wild play sites, campsites and Forest locations with facilities such as larger car parks, visitor information and toilet facilities.
  • c) Core routes: walking, horse riding and cycling routes (on and off road) including sustainable travel options (walking, cycling or public transport from where people live).

Spatial strategy is at the heart of how we can actually influence recreation, which is why we have continually called for a review of recreation infrastructure since the inception of the Park, and nominated it as one of three key priority projects in our response to last year’s RMS call for views. We strongly support “ambitions for new country parks outside the NP boundary” although this is given only a passing reference in the deliverables for action 4.2.

When discussing key access points, it is worth noting that RMS partner, NFDC took the extremely short sighted decision to close the visitor information centre in Lyndhurst.

Draft action Examples of possible delivery
4.1.Develop a long term vision for where within and around the National Park people should be encouraged to enjoy outdoor recreation. Changes to ‘gateways’, key sites and core routes
4.2.Within a year of publishing the update to the 2010 strategy, consult the public and relevant organisations on what changes should ideally be made to ‘gateways’, key sites and core routes to achieve this objective. Maps showing sensitive habitats, conservation designations, and areas with higher tranquillity which need to be protected from adverse impacts of increased recreation; revisions to the location of parking capacity in the National Park; parking restrictions to prevent physical damage to the Forest; selective improvements to the network of off road cycle routes; rights of way where enhanced signage would be useful; locations for visitor information; locations where safety can be improved e.g. where off-road routes cross busy roads; possible areas where increased recreational opportunities might be desirable on private land and outside of the National Park
4.3.Having taken account of feedback on the above action, and after obtaining appropriate regulatory consents, develop a phased programme of implementing changes that avoid temporary net or ongoing likely significant effects on the recognised features of designated areas. Extend, relocate or reduce gateways, sites or routes to ensure impacts on recognised features are decreased
4.4. Implement the programme as resources allow, adapting and reassessing individual elements in the light of monitoring. Ensure that people park in the car parks and not on the verges, and use the sites and routes provided.

4.1. Simply summarizes the key notion that “where” is one of the key tools at our disposal for management of Recreation. This is the crux of what we support.

4.2 Here we have one of the few concrete proposals, and it gibes well with the new spatial strategy for recreation infrastructure which we have proposed and would support. However, by lumbering the project with a year timeframe, which would limit decision making to whatever data is to hand or can be cobbled together within that time, it would inevitably result in an infrastructure just as arbitrary as the one created when the Forest was fenced and gridded half a century ago. Given that within the current RMS, five-year action 5.6.3., the very straightforward project to audit car parking provision within the National Park has not been undertaken within eight years, some scepticism arises as to how this and all other relevant data may be achieved.

There is a further disconnect in not folding in the longer term goals of Objective 6 for data and evidence, and the notion that a spatial strategy should be achieved by public consultation rather than a basic evidence based consideration of the existing habitat and its pressures.

4.3. Merely posits implementing the half-baked brainchild of 4.2.

4.4. Again an instance of presuming the resolution of the list of “Examples of possible delivery”.

Finding funding – and using it effectively
Objective 5: Increase the level of funding available for recreation management so that it is sufficient to address both existing and upcoming needs.This objective recognises that resources are limited and that some aspirations for improved management of recreation can only be achieved if additional funds can be found. For example, car park maintenance could occur more regularly and more rangers could be deployed across the National Park if additional funding can be found. New recreation sites such as country parks would require major capital funding and business plans which ensure they are sustainable financially.

It is both good that a forward strategy considers funding sources for implementation, but also sad that certain elements of basic management including enforcement and education are no longer guaranteed products of the public purse despite their universal benefit (this is not leveled as a criticism of the proposal, but an observation of the situation this objective must address). We do find a disconnect between a Government touting a 25 year Environment plan including promises of greater support and protection for habitats and National Parks, but not offering the cash to ensure these goals may be met.

Draft action Examples of possible delivery
5.1.Approach and work with organisations to raise funds and other resources for specific recreation-related projects. Local businesses and charities, Local Enterprise Partnerships, grant making bodies, youth and health-care organisations, Clinical Commissioning Groups
5.2.Develop a coordinated approach among planning authorities in and around the New Forest to mitigate the impacts of new housing on protected areas – with the aim of using developer contributions to support work that protects the Forest. Agree a common approach to determine the levels of developer contributions, work together to boost awareness raising initiatives (including rangers) and, with funding from the Local Enterprise Partnerships, landowners and businesses, create significant new recreation sites outside of protected areas
5.3.Through consultation, develop mechanisms through which those who benefit from recreation facilities can contribute towards their maintenance and the good of the wider Forest. Developing and promoting the voluntary Love the Forest visitor gift scheme, inviting donations to support specific recreation facilities, reviewing where and how much people are charged for parking, larger events and provision of services
5.4.Work with the Government to include incentives for access improvements on private land within future land management grants, where these would benefit the public and reduce (or not increase) pressure on nearby sensitive areas. New walking, cycling and horse riding routes; campsites and other recreation facilities; England Coast Path

5.2. Mitigation schemes are key in and around the Forest, but sadly they need to be drastically redesigned to fit the Forest. Using the Natural England work at Thames Basin Heaths critically undervalues our much richer and under pressure habitat. This is why we proposed a project to make mitigation for development in and near the Forest fit for purpose.

5.3. We welcome allowing for the possibility of charging Forest users, but this should be stated more clearly. If the charging model is adopted, there would likely be backlash, but a sound rationale should be developed to justify this move. A more specific view of what this would fund (enforcement, education, infrastructure maintenance etc) would make the value of charging clearer.

5.4. We outright reject the notion that “where these would benefit the public and reduce (or not increase) pressure on nearby sensitive areas.” could result in the England Coast Path, which under current proposals only increases pressure on our most disturbance sensitive highly designated Coastal habitats.

Data and evidence – to help guide the work
Objective 6: Collate data and evidence to help inform the ongoing management of recreationThere is ample evidence of the benefits of quiet outdoor recreation to our health and wellbeing. It is also clear that people sometimes impact in negative ways on each other, on sensitive wildlife and on important aspects of the working New Forest. The actions in this strategy can and should therefore be progressed.

However, more data and evidence would help target resources more effectively and efficiently, clarify trends in recreation, help predict which interventions are most likely to work and monitor the success of different recreation management initiatives.

 

Draft action Examples of possible delivery
6.1.Through existing or new forums, collate existing data and evidence, agree which data can most usefully be used as ‘key indicators’, identify gaps in knowledge and develop plans to improve the evidence-base used by organisations that manage recreation in the New Forest. Species population data, habitat condition assessments, frequency of incidents caused by recreation, numbers of people taking part in different recreation activities, traffic counts and visitor data from tourism businesses
6.2.Analyse and publish data on a repeat or rolling basis to assess trends in recreational activity and on aspects of the New Forest that might be affected. Analysing data to show the degree to which recreation management interventions achieve the desired effect, State of the Park Report, Annual Monitoring Reports for local plans

 

Evidence based decision making should be at the heart of management across the Forest, not merely for recreation. Although it is acknowledged that the Forest is a highly designated Habitat for conservation, it is relatively poorly surveyed. A Recreation Management Strategy demands a more thorough, cohesive knowledgebase to be able to move forward, particularly in respect to spatial management decisions (as in the canard of Action 4.2. proposing spatial maps absent sufficient data/evidence). This does present an opportunity for fostering useful research, surveys and a more comprehensive understanding of populations of local flora and fauna and their sensitivities.

We agree with the element of 6.1. that useful key indicators must be identified and agreed, but would add further that an agreed minimum level or granularity of data is necessary. This would allow pragmatic decisions to be made once some basic understandings have been achieved, avoiding analysis paralysis. We would quibble slightly with 6.2., the emphasis on “trends of activity” over habitat that is (not “might”) be affected.

Adaptive monitoring and implementation – keeping the strategy alive
Objective 7: Regularly review progress against agreed recreation management actions and adapt forward plans to protect the special qualities of the National Park and enable people to enjoy and benefit from them

It is impossible to predict the degree to which the actions in this strategy will be achieved, especially given the ambitious nature of some actions that will depend on new resources being found. However, the six organisations on the RMS Steering Group intend to remain focussed on protecting the Forest for the benefit of future generations; they will therefore continue to meet, monitor progress and consider how to respond to changing circumstances.

Draft action Examples of possible delivery
7.1.Regularly review the implementation of the actions in this strategy and the degree to which they achieve the desired outcomes. Feedback from lead organisations, reports from joint forums, trends in the occurrence of incidents, analysis of the effectiveness of interventions where this is possible, feedback from user groups
7.2.Where actions are not progressed or finalised, consider what could be done to redress the situation and gain agreement for revised actions where possible. Find new resources or prioritise the most important actions
7.3.Review and update the Recreation Management Strategy actions after five years. Consultation with user groups, local organisations and the public

Reviews and updates are the minimum due diligence to any plan. There’s no objection to its obvious inclusion, but this is another disconnect as to why it is necessary for these elements to be rated on a like/dislike scale in an online opinion poll.

Many of the “actions” from the rest of this proposal are so vaguely defined that it will be difficult to establish criteria. The promise of a “review and update” after five years seems a bit hollow coming from the Park Authority which in eight years has not reviewed the actions of the current strategy, despite containing the same five year promise.

We will continue to insist that a Strategy must contain a Plan with more precisely defined actions, these are mostly ideas and guiding principles about what actions might be done.

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Recreation Management: Adjusted Expectations

Our Strategic (or perhaps less than) Approach to the RMS Review

We welcomed the review of the National Park’s Recreation Management Strategy, the core policy document whose difficult birth plagued the early years of the Park. Little of its 60 actions, including straightforward surveys and a five year review had been achieved. It is to the credit of the Authority officers that they mooted this review, which was accepted unenthusiastically at the March 2017 meeting by the Authority membership in the manner of a recalcitrant child taking medicine.

This review is an opportunity to raise the profile of Recreation Management in the Forest, to revisit the extensively publicly consulted upon 2010 Strategy, to create a more focused Plan featuring fully specified high-priority projects to address the ageing infrastructure, education and large increases of use resulting from growth of development on our borders.

Since then the red flags have gone up with the confusing, unrepresentative survey, its poor interpretation, and the drive this year to engage in a similarly, perhaps even more empty and simplistic exercise in public engagement. (for more about our concerns with the surveys read here)

We have at every step of the way offered the NPA constructive criticisms of both the content and method of this review.

When questioned directly as to how the review in any way improves on the existing Strategy, NPA Officers and Members have given certain responses (which I’ve taken few liberties in paraphrasing):

  • All is well because the surveys and proposals have been signed off by the partner organizations (gnomically tautological, often with flourish pointing to their logos).

  • The “actions” of the original strategy weren’t “owned” by the relevant organizations, which need to deliver the objectives.

  • This Strategy will call for the partners and others to volunteer initiatives to deliver actions and objectives which will deliver Recreation Management.

All the partner organizations were part of the extensive consultation that produced the existing strategy, to suggest that they never really signed up to those objectives is a ripe nonsense. The objectives of the existing Strategy are “owned” by definition by the National Park which includes that Strategy as one of its core documents. Whilst it’s true that the Park Authority has limited direct responsibilities and powers, it’s incumbent on them to use their influence on those organizations that do, and there is a legal obligation for those bodies to listen and act accordingly.

Case in point: the Natural England SAC management Plan 2000 prescribed that campsites in A&O woodlands be shut down with their camping provision perhaps moved elsewhere. The FC are under an obligation to make this happen. The National Park should be monitoring camping provision for the whole of the Forest, including the licensing of “pop-up” campsites which may very well be providing that alternative provision organically. The National Park, obligated by their purpose to conserve, should encourage the FC to fulfill the SAC management plan, and use its leadership and influence to help smooth the way for this action.

This is not merely a case in point. It is an Action pledged under the existing 2010 Strategy. Oddly it seems to have been dropped from the new version. Whilst all this should happen because of obligations outside the purview of the Strategy, it is entirely within to help chivvy it along.

There might be the view that the Friends of the New Forest / NFA should play a longer game, presume that the vague well-meaning mishmash will eventually garner useful concrete proposals fully supported by the partner organizations, and that these will also magically cover the statutory obligations given little or no space in the proposals. Given the lack of follow through on the 2010 plan, and the failure of the Park Authority, both officers and members to take on board our criticisms of this version of the strategy over the last year, we lack confidence in their ability to steer this course. We would fail our duty as a critical friend of the Park if we merely patted them on the back for their effort and patronised them with a “bless!” and perhaps a gold stick-on star.

This may risk a chilly relationship between us as the National Park Society for the New Forest, but they are public servants, they are indulging our resources and they should expect criticism for below par output. As little we’ve said has deterred them so far, we can at least demand from them a swift roster of actual plans following on from this survey process which would quell our concerns, and attract our praise, which will be equally vocal and public should they hit the mark. Otherwise we’ll continue to watch as they tread water and ignore all the life preservers we helpfully lob in their direction, mindful that this delays useful and needed action to the detriment of the Forest.

We still have faith in the potential of the National Park to deliver a coherent plan which we could support, and what we have before us contains many of the right ideas amongst the blather. The Authority needs to show a willingness to propose specific solutions which could include difficult choices which they would defend publicly. We await their leadership.

This is part of our ongoing coverage of the National Park Authority’s review of the Recreation Management Strategy which we ultimately support, but have grave disappointments in the conduct and current proposals to date.
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Recreation Management: In A Nutshell

Whilst we’re still formulating our detailed response to the Future Forest draft actions survey 2018, we’re sharing these preliminary thoughts.  These observations will make more sense if you read the proposals. You may read the full text of the proposals without engaging in the survey with this Adobe Reader pdf version: Future Forest draft actions.

Here is a more admittedly impressionistic summary of our thoughts about the Recreation Management Strategy proposals in question:

Much of it lacks detail and substance.

It makes no reference to the National Park purposes or the Sandford principle enshrined in legislation, obliging the park to conserve and enhance natural beauty, wildlife and cultural heritage, and dictating that irreconcilable conflicts with public enjoyment should favour conservation.

It drops useful proposals from the existing strategy, including at least one legal obligation to fulfil the SAC management plan.

Much is poorly written. Not in plain English.

All of the “Actions” have “Examples of possible delivery” which are often accompanied by a list of problems presumptively resolved by the action. (When one of the more glaring examples of this style disconnect was spotted by a helpful member of the Park Authority at the meeting that OK’ed the draft, the word “Reduce” was plonked at the front of the list. See below.)

With absolutely no sense of irony, or understanding of the concept of recursion, one of the proposed actions is “Through working groups with appropriate terms of reference or other joint initiatives involving local organisations and user groups, identify and implement the most effective and long lasting strategies to address significant and widespread negative impacts caused by recreation.” I thought that was what we were developing here. Under “Examples of Possible delivery”: “Reduce disturbance of wildlife, feeding of animals, animal accidents, litter, verge parking, fungi picking and negative impacts of dog walking, cycling and horse riding” a list of desired outcomes, which, as if by magic results from the here-to-for unglimpsed illusive strategies that this strategy plans to seek out.

In support of other techniques, use appropriate and proportionate enforcement activities to deter illegal recreation-related activities.” Could be said in two words in two ways either “Stop crime” or “Enforce law”. If anyone has a clue what “other techniques” is euphemistically…..?

It frequently supposes that the Forest is obliged to provide a venue for recreation, rather than a place where managed recreation is appropriate. It does suggest, conversely, that there should be “shared responsibility” for recreation impacts and protection of the Forest.

There is slight mention of influencing neighbouring authorities for developer mitigation, but not on quelling overdevelopment that increases local populations regularly using the Forest. The ambition to create neighbouring country parks as alternative recreation sites is mooted, but not stated as a specific goal for survey respondents to support.

The surveys, by their own admission, employ no attempt to get “a balanced and representative sample”, have been poorly interpreted (including the claim that one proposal had “wide public support” despite positive comment from only 22% of respondents), and so make them a nearly meaningless time-wasting exercise.

The new survey only asks for feedback on a sliding scale of agree/disagree on vaguely stated proposed actions. No consultation is made for the stated Objectives or for the Draft Criteria for Judging Recreation Facilities (published on the Park Authority website but not included in the survey).

These “actions” may form the basis for future useful proposals for action from the partner organizations, but we cannot judge it on this assumption as there is no onus put on these organizations to deliver these specific outcomes.

On the upside it does acknowledge the importance of education, spatial strategies, data and evidence.

There is a good mention for increasing the number of “on the ground” staff to influence and educate recreation behaviour, we’d be more heartened if some aspects of enforcement were added to this ambassadorial role.

It also tries to address funding issues and floats the notion that Forest users may be charged for some facilities, possibly parking, as a means of funding both upkeep and relevant initiatives to protect the Forest.

Overall: Good ideas dragged down by blather and vagueness, amounting to a statement of guiding principles, but not a Strategy.

A Strategy should be a Plan with specific actions.

This is not a palpable improvement over the existing Strategy, and in some respects an abrogation of responsibility to deliver the actions of that Strategy, which was subjected to a lengthy and thorough public consultation, including the partner organizations, which are obliged to assist the Park in delivering its purposes.

This wheel spinning exercise has merely deflected from any continued implementation, although it has helped highlight how sorely we need to manage recreation in a proactive, robust, brave fashion.

This is part of our ongoing evaluation of the RMS Proposals, and may be subject to amendment, updates, and further consideration. In particular this is not how we are expressing our opinion n the official response, but a quick snapshot of our thoughts for our members, readers and followers.
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Recreation Management: Summary of Our 2017 Response

A summary comparison of our 2017 response to the draft “Actions” proposed by NFNPA in the 2018 survey.  For last year’s Future Forest survey, we sidestepped the survey format and focused on three main areas for specific, achievable projects. These were 1) National Park Infrastructure 2) Influencing Adjacent Authorities and Communities and 3) Education Emphasis on Protecting the Forest

1. National Park Infrastructure –

  • Parking and Camping Provision Assessment
  • Habitat Assessment / Evidence Base
  • Actions to lead to provision design Fit For Purpose

The Draft Actions contain an aspiration to create a map to be used to address infrastructure priorities, but this is given an absurd “quick-win” goal of being produced within a year of the adoption of the RMS update. Rather than specifying key criteria and gathering evidence to base a sound spatial strategy, this will be done with whatever haphazard data is to hand or may be hastily compiled within that timeframe leading to an infrastructure just as damagingly arbitrary as that which we’ve inherited.

2. 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

The Draft Actions limit discussion of influencing adjacent authorities to their recreation provisions, where placement of population increases from new development if often the strongest driver in creating recreation pressure on the Forest. As mentioned above mitigation regimes undervalue the New Forest without scaling Thames Basin Heaths framework appropriately.

3. 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

Of course there is a useful “Raising awareness and understanding” action point which is front and centre, but it is focussed very much on doing more of the same, but more often in more places with better production values, not shifting the message to significantly highlight the habitats and ways of life under threat. Getting a very simple key notion across that the Forest needs our collective respect and protection could give those education efforts a more useful focus and lead to positive impact.

This is part of our ongoing engagement in the debate on the National Park Authority’s Review of the Recreation Management Strategy.  Our full response to the 2017 survey is available here.  Our 2018 response is ongoing.
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NFNPA Public Questions: Recreation Management Strategy

We continue to welcome the opportunity presented by the review of the RMS, but are underwhelmed by the process and proposals. I wouldn’t belabour the deficiencies of last year’s online survey with 1500 unverified respondents[1], but for the proposal that the exercise be repeated, with the “Draft Actions” under consideration.

I must admit I was initially optimistic when these were previewed, there are sound ideas at heart, but made anodyne, presented with so little detail, as to be vague and inoffensive; anyone could read into them goals we’d like to see achieved. These are “more plans to make plans”, with no palpable improvement, apart from brevity, on the previous RMS. Some essential actions, predicated by legal obligations to designated habitat, have been discarded. All the education actions focus on promoting special qualities[2], not on shifting emphasis to protection.

The Strategy needs to include a set of concrete proposals, a non-exhaustive list could include:

  • Establish a Research Station for the Forest – this could provide an evidentiary base for spatial strategy.
  • Habitat Mitigation Framework for the Forest – reliance on Thames Basin Heaths mitigation severely undervalues our more richly featured at-risk habitats, and is not fit for purpose.
  • Audit of parking and camping provisions[3]
  • Strategic Regional Development Forum – working to lower housing targets within and on the borders of the Park to reduce pressure.
  • Bring temporary campsites under a regimen of consistent standards and controls.
  • Close Hollands Wood, Denny Wood and Longbeech [4]
  • Create a “Park Ranger” role that includes enforcement.

One set of actions that nearly rises to the level of a plan, managing recreation infrastructure[5], is lumbered with an unrealistic year limit to decide future zoning and control. Rush decisions using whatever data is to hand or can be cobbled together, rather than developing a spatial strategy, with agreed criteria, tied to well grounded evidence, would lead to an infrastructure just as damagingly arbitrary as that which we’ve inherited.

It’s well and good to have a set of aspirations, but without a clear set of projects to achieve the least of them, reviewing our aspirations is relegated to a make-work delay in taking action. I am confident that you could hammer out useful, practical proposals, that would fulfil the Statutory Purposes of the Park, and legal obligations to designated habitats, commoning, and the working Forest. Please do not let a dumbed-down internet poll be the final word on this important document.

[1] half the population of Lyndhurst.

[2] In ways that are already being done. This strategy should show how we’ll do things differently to be effective.

[3] Five year priority 5.6.3 of RMS 2010

[4] The obligation under the 2001 SAC Management plan to relocate three FC Campsites (Five year priority 6.4.2 of RMS 2010) should not be ignored; it is even possible that the rash of 28 day license pop-up campsites has effectively absorbed an equal provision already.

[5] Objective 4

This Statement was read out to the 15 June 2018 Meeting of the National Park Authority. The version of the document distributed to the members included more detailed versions of the non-exhaustive list of project proposals which would be appropriate for inclusion in a Recreation Management Strategy with any depth and utility. A revised and updated version of those proposals has been submitted as part of our response to this year’s survey, and may be viewed *here* (Coming soon.)
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Recreation Management: An Overview

Recreation Management Strategy 2010 – 2030 (May 2010)

Last year the New Forest National Park Authority launched a review of the Recreation Management Strategy (RMS), its core policy document for Recreation.  With over 60 action points over 60 pages, it is very wide ranging, but also fuzzy, aspirational, and many of its projected tasks are yet planned, let alone achieved.  We welcomed the review with the hope that a more practical and focused update would lead to needed change.

In Summer 2017 the Authority launched the review with the “Forest First” online survey.  Whilst, as far as we were concerned, this may have been a good PR exercise to raise the profile of the RMS review, the survey itself was flawed in its format, execution and interpretation.  The Strategy needs to address many statutory obligations to habitat, to commoning and the working forest, and a complex mesh of overarching issues including wider town and country planning across the region.  Reducing many aspects of this to an online poll ranking whether walking, cycling, or golf are more important than cricket, camping and coastal access, is an unhelpful distraction seemingly promoting activities rather than looking at their impacts and how best to minimise them.

We sidestepped the survey and gave a response calling for specific projects in areas of education, infrastructure for recreation in and outside the park.   Our Response to the 2017 Call for Views

We criticised the format and unintended messages of the survey in the very brief window afforded in the Public Questions at the July 2017 Park Authority meeting.  At the January 2018 meeting we criticised the faulty interpretation of the results.  At the May 2018 Verderers Court we raised concerns over the plan to run a second survey intended to be a final consultation with the public on the new document.

The survey has now been launched to consider 25 “Actions” spread over 7 “Objectives”.  Whilst these are hodgepodge of bland guiding principles there is almost no substance.  We support most of these principles, but specific policies, projects and initiatives are needed to form a strategy.  These blandishments on offer in no way improve on the existing 2010 RMS document.

The online survey merely provides an opportunity for the public to “rate” these “actions” on a five point sliding scale from strongly agree to strongly disagree.  A 2000 character limit box (that’s nearly 14 tweets worth to the social media generation) allows a more “in-depth” response to the entirety of this from each respondent.  This is less a survey than a rubber stamping exercise.

The survey closes at 11.59pm on 12 August.

Coming soon!  Our suggestions for responses.  What should be retained from the original RMS.  What we think of the proposed “Actions”.  Some projects we’d want to see proposed instead.  And where we should set or lower our expectations for what the Park Authority can achieve if it only adopts these principles without offering a more concrete strategy.

To see all related articles (including this overview which we’ll update as this progresses) click here: http://newforestassociation.org/tag/rms/

Latest update 7 August 2018.

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Presentment: Recreation Management Strategy : May

RMS Findings report Cover Image Horse-riding-on-heath

At January’s Court, I asked you to take with a blood pressure threatening portion of salt, the results of last year’s online RMS survey, which by its own terms made no attempt to get “a balanced and representative sample”, and included provably false misreadings of its mere 1500 respondents[*].  A true consultation would present the relative merits, pros and cons of its statements, no attempt was made towards this in the survey.

When I make these complaints to park authority staff, who now erroneously refer to this poll as a “consultation”, they have a tendency to brush these off with the tautological statement that all must be well because the process has been signed off by the Six Organizations on the RMS Steering Group including NE FC HCC NPA NFDC and of course, the Verderers. [This confers a collective infallibility which I would not burden you with.]

Sadly, as another online poll will be used to comment on new RMS proposals, we’re now due to repeat that meaningless exercise this year. There are some good ideas within these proposals[†], but they are incomplete and unfocussed, and very much the result of the messy group think employed.

The review of the RMS should have a broader vision, which acknowledges that the complexity of solutions required may need more than 144 characters to express, should include not just the recreation provisions for neighbouring authorities, but strategic review of new development that puts greater recreation pressure on the Forest. This brings housing targets and mitigation regimen across the entire region into the discussion[‡]. This cannot be done in a format more suited to counting how many people like that photo of a fox cub, or if you think that dress is blue/black or white/gold.

The future of the Forest, and its millions of recreational visitors, should not be at the behest of an insecure online poll whose unverifiable population is half that of Lyndhurst. We want an RMS aimed at Managing Recreation Strategically to fulfill the Statutory Purposes of the Park, and the legal obligations to protect the designated habitats. We want leadership able to defend that Strategy in a public consultation, even the measures which may not be simply explained, or may need defence against interest groups who would put their needs above those of the habitat, commoning’s working farm and forestry. Please use your seat at the table to stop this important document, and the process guiding it from being dumbed down.


[*] One item was interpreted as having “wide public support”, despite only being supported by 22%.

[†] See Addendum below.

[‡] The RMS would need to confront the aspects of the NFNPA and NFDC draft local plans which will pave the way for an inappropriately large development, wholly within the National Park, creating a new population centre of 3500 people (larger than Lyndhurst). Placed 30 minutes down a cul de sac with paltry mitigation for that population which would be dumped entirely on the Forest for Recreation provision, and on the road infrastructure (requiring upgrades that would encroach into the Forest, and greater traffic across animal accident hotspots within the Forest).

ADDENDUM:

The Addendum written for the Verderers referred them to  the NFA’s response to last year’s Future Forest survey, then included these additional remarks on the latest RMS proposals under our three main areas for specific, achievable projects.

National Park Infrastructure

The proposals do contain an aspiration to create a map to be used to address infrastructure priorities, but this is given an absurd “quick-win” goal of being produced within a year of the adoption of the RMS update. Rather than specifying key criteria and gathering evidence to base a sound spatial strategy, this will be done with whatever haphazard data is to hand or may be hastily compiled within that timeframe leading to an infrastructure just as damagingly arbitrary as that which we’ve inherited.

Adjacent Authorities and Communities

The proposals limit discussion of influencing adjacent authorities to their recreation provisions, where placement of population increases from new development if often the strongest driver in creating recreation pressure on the Forest. Mitigation regimes use formula developed by Natural England for Thames Basin Heaths, which does not scale appropriately to the Forest because a) the Forest is much richer in features and biodiversity at threat and should cost developers more b) the morphology of the Forest is different: Thames Basin Heaths spatially has greater opportunity for alternative spaces, where the Forest, surrounded, creates more of a siege situation (with only one defence to the West at Moors Valley, and plans to the East eternally pipe dreamed).

Education

Of course there is a useful “Raising awareness and understanding” action point which is front and centre, but it is focussed very much on doing more of the same, but more often in more places with better production values, not shifting the message to significantly highlight the habitats and ways of life under threat. Getting a very simple key notion across that the Forest needs our collective respect and protection could give those education efforts a more useful focus and lead to positive impact.

 

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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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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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