Archive | August, 2018

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

5.3.3 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

5.9.1 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

5.6.1, 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”.

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.

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.

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.

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.

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.

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.

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.

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.

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”.

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.

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.

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.

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.