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Archive | August, 2017

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

By on 28/08/2017 in Habitat

England Coast Path

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

Increased use and disturbance:

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

Coastal Margin:

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

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

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

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

Weak Habitat Protection:

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

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

Purpose:

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

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

Consultation on the Highclifffe – Calshot stretch:

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

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

Yours,

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

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

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

By on 09/08/2017 in Habitat, News

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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