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.
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.
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.
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:
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”.
|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.
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.
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.
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.