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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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A Year In The New Forest — telly doc review

It may be difficult to quantify why Channel 4’s new documentary series A Year In The Forest is such a uniquely rich and well observed celebration of what makes our Forest so special.  Sure, there’s abundant beautiful photography, but we should expect this in a 7 pm Saturday flagship documentary slot.  The filmmakers took their time with this, literally a year and change, and have produced an episode per season of that year for a set of four.

The filmmakers have avoided pitfalls of previous efforts, no celebrity CNP figureheads up in hot air balloons, no gross oversimplifications, no — as certain BBC magazine programmes past have done — touting of inappropriate recreation activities (there was some regrettable habitat disturbance intentionally running through bogs for some mucky version of orienteering).

They’ve selected a cast of knowledgeable local characters, who they seemingly allow to speak for themselves, variously representing commoning and conservation.  A decent proportion of those “followed” are members of the Friends of the New Forest / NFA, including two members of our council; this is less a declaration of interest from this reviewer, more an appreciation that they’ve chosen people who know what they’re on about.  (We should probably mention much of the glorious wildlife is captured on film by our friend Dr. Manuel Hinge.)

Its success may lie partially in what they leave out.  Last names, for starters, all the “leads” in focus are only referred to by their first names, this has the effect of making the discussions more intimate and personal.  A last name is dropped in a description of a family heritage going back to 1680, you may spot a familiar commoning name on an erstwhile bucket, and a side character local mycologist is anonymised when joining “Richard” for a fungi ID hunt (her name passed in conversation).  In focusing on individuals they’ve also skirted or left out larger group activities, hard to imagine a doc on Autumn in the Forest without a chunk about the Drift or Beaulieu Rd Pony Sales (will Winter include the Point-to-Point?).

There’s also a lack of official talking heads from the statutory organizations, the National Park Authority, the Forestry Commission (The Forester featured is not even from the FC, but from the excellent Pondhead Conservation Trust which manages their inclosure sympathetically under lease from the FC), or even the Verderers.  We’re not being lectured at, we’re being spoken to.

This works well in conveying the love and care for the Forest from all those involved, but excludes any prescriptive suggestions on how to protect it.  An incident of a dog chasing deer, resulting in a drastic change to mating patterns, amongst other things, passes without any comment on the behaviour of the dog owner.  The foray for autumn fungi is not concluded with any message to not pick (which I’m certain will have irked at least one participant).  As a campaigning organization, we know it’s often difficult to express precautionary principles without falling the wrong side of hectoring, but these few moments begged a slight nudge at least, although this may have not fit with the welcoming tone the narrative affects.

At the same time they don’t utterly shy away from hard realities, TB tests are endured and acclimatizing young stock to coming Winter requires a firm stance that may not sit well with those ready to misunderstand animal welfare.

Based only on the first quarter, a sterling effort.  Although the slight niggle of missed opportunities to guide viewers from respect towards protection of the Forest; perhaps a “if you’ve been effected by issues in tonight’s programme” proviso, with hints on how to help, which might include supporting local conservation landowners (Wildlife Trust, National Trust and recently in place RSPB), volunteering for on the ground conservation, or even joining the Friends of the New Forest, at a stretch…

A Year In The New Forest is produced by Blast! Films for Channel 4 and airs on Channel 4 on Saturdays starting 28th July at 7pm, and available on All 4 Catch-up Apps for 30 days each.

 

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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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England Coast Path: What can I do about it?

We suggest some representations you might wish to make.  And discuss how the format of the consultation is restrictive.

In the run up to the end of the consultation on the Highcliffe-Calshot stretch, we’ve put together a series of articles about the England Coast Path.   Now with precious time to spare, you may want to respond to the consultation. (if you want to refresh your memory on everything we’ve posted so far on the subject (including this article))
http://newforestassociation.org/tag/england-coast-path/

Here’s where you can find all the proposal documents including the forms for responses:
https://www.gov.uk/government/publications/england-coast-path-from-highcliffe-to-calshot-comment-on-proposals

First, let’s hunker down on what hoops Natural England have set for us to jump through.  There are two types of response you may make, “Objections” and “Representations”, both with different forms to fill out.  We have been told that if you do not use the forms for your response, your response may by discretion be ignored (and some have informally been advised that they would be ignored).  In some instances you may do both.

Only owners/tenants/occupiers of land directly effected by the route may make “objections”, but these are limited to specific grounds:

  1. The position of any part of the proposed route shown on the map(s)
  2. Where we have proposed (or not proposed) that the route should “roll back” in response to erosion or other forms of coastal change, or the nature of our proposal
  3. Where we have proposed (or not proposed) an alternative route (in addition to the ordinary route), or the position of the alternative route or any part of it.
  4. Where we have proposed (or not proposed) that the landward boundary of the coastal margin should coincide with a physical feature such as a fence or wall, or the nature of our proposal
  5. Where we have proposed (or not proposed) an access exclusion or restriction, or the nature of our proposal
  6. Where we have proposed (or not proposed) to extend the route to any point between the open coast and the first public foot crossing point on a river.

“Representations” are not limited in subject matter / grounds, and owners/tenants/occupiers may make these as well (and are invited on the forms to identify themselves).  Anyone else may also make representations as individuals or group representatives.  In both types, multiple forms would have to be submitted if commenting on non-contiguous portions of the route.  Each form must identify a single “land parcel” or several adjoining ones.  Again, you may choose to depart from guidance, but run the risk of being ignored.

1 & 2. For our purposes here you’ll need to look through Chapters 3, 4 or 5 of the proposals.  These 3 Chapters alone propose 114 discrete sections of the route from Lymington Bridge (East) to Calshot (and that’s excluding possible Alternate Routes, which we have little to worry about as in this instance there’s only two bits along public highway from Inchmery Lane to Lepe Road, and Alternate Routes do not create additional Coastal Margin).  54 of those sections aren’t on current established Rights of Way, 21 of these sections classified as “Other existing walked” 33 sections are new “not an existing walked route”.  You can choose any of these for comment, I’d suggest an area you know well, or if you don’t know, go for one of the new ROW as these may be the most problematic.

For your additional research, I suggest looking at the Government’s Magic Map page http://magic.defra.gov.uk/MagicMap.aspx.  This lets you zoom into the area where your route sections are, you can turn off useful layers (layer menu is on the top left of the map ) under Designations / Sites of Special Scientific Interest (England) / Special Areas of Conservation (England) / Special Protection Areas (England) etc, also with useful Marine designations).  This is somewhat necessary as the consultation maps do not provide this information in any useful context or detail (there’s one map in the Overview which does not show the route and how it or Coastal Margin interact with the habitat and other designations).

3. Those listed in Schedule 1 Coastal Access reports, those with sport shooting rights and the following organizations: BASC; British Mountaineering Council; Country Land and Business Association; NFU; Open Spaces Society; Ramblers ; RSPB have to identify themselves (as if they were marked! — do you suppose they get a knock on the door asking how they were recruited to these shady organizations?).

4. “relevant interest” means that you are a legal owner / tenant / occupier of the land in question (i.e. you would also be able to make an “Objection”)

5. Here’s the real meat of the Representation, what ever concerns you about the report in such a way as to show that it “fails to strike a fair balance” between the provision of Coastal Access Duty and personal, statutory, local or National Interests.  National interests would include honouring the protections to habitat in the Wildlife and Countryside Act 1981, and other agreements and law that specify relevant habitat designations.  Either think of your own concerns that fit the bill, look through our other articles for extensive critique, and/or use almost any of the points below which sadly will apply to much of the route.

  • The Sensitive Features Appraisal fails to carry out a full Habitats Regulation Assessment to assess impact of this section of the route, route facing mitigation measures may not be presumed to work, and in the context of Coastal Margin which may allow incursion through the Margin from other directions, the proposed mitigation is flimsy.
  • Presumption that this route has no significant impact has not been proven in the absence of the full Habitats Regulation Assessment, or the possibly illegal inclusion of the proposed mitigation at the screening stage.
  • Because of the poor presentation on the maps provided it is difficult to judge the relationship between the route, potential Coastal Margin, excepted land and exclusions.
  • The Ordnance Survey’s practice of showing all potential Coastal Margin as access land will mislead many off this route section onto protected habitats and dangerous salt marshes.
  • Dogs should be on leads for all sections adjacent or through protected habitats, grazing or back-up land for livestock.
  • Using the least restrictive option principle as a standard for the Sensitive Features Appraisal is wholly inappropriate in the context of a National Park.
    • The least restrictive option principle has no basis whatsoever in the Legislation,
    • whereas within a National Park, the Sandford principle which favours conservation over recreation where they may not be reconciled is enshrined in the 1949 Act and subsequent Acts.

6 & 7. Self Explanatory, note because you are expected to submit separate forms for each contiguous stretch you criticise, you may have made other representations about the same report.  8. Again, harking back to #4. If you are and owner/tenant/occupier, have you also made out an “objection” form for between 1 and 6 statutorily granted reasons.

9 & 10. Tell them who you are, and send it in.  At this late date, you’ll want to use the email. (southcoastalaccess@naturalengland.org.uk)

Now I think it’s worth noting, if you haven’t already caught on, but the format of this consultation is onerous.  Some of the questions on the forms themselves require specialist knowledge, or a visit to a separate document that explains some, but not all of the questions.  You are told to submit multiple forms for multiple sections.

By virtue of the fact that the forms are geared around references to sections of the route, there is no way to identify portions of the Coastal Margin you may wish to comment on,  the seaward portion of the Margin is never explicitly delineated on the maps, although there is a useless box, often sitting on the map obscuring features that explains the Margin is the whole seaward side but for Excepted Land and Exclusions, and the maps do not depict these either for reference.  The maps do not show the boundaries of legally protected designated habitats, so it is not easy to judge whether the section has an impact.  There is no direct way to reference any of the supporting documents.  There’s much wrong with the Sensitive Features Appraisal itself, the forms don’t really offer you a way to make those comments.

So, if you’ve any spare time between now and Midnight Wednesday 8th of May 2018.  Download and fill out the form and email it in.  Even if you miss the deadline, keep sending them in with the complaint that an extension to the consultation should have been granted as Natural England have produced a report of much greater size and complexity than any to date, with unhelpful maps to judge the proposals by, and they took more than an extra year to do it : they should be obligated to produce useable maps and allow another four weeks.

Finally, while you’re at it, go to the link to this article on our Facebook page and just leave the reference to the section on which you commented.  Thanks for your help!

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