|We made this statement regarding the Solent Freeport at the New Forest National Park Authority meeting on 20th October 2022. The Authority agenda included a discussion of the Freeport, its possible bid for announced Investment Zones, and whether the inclusion of the District, including the Park in the “outer boundary” of the Freeport would undermine the Park, or the habitat protections of the Park’s designated land.
Currently the Solent Freeport Board includes representatives of Hampshire County Council, New Forest District Council, Southampton City Council, Portsmouth City Council, Eastleigh Borough Council and Havant Borough Council, and representation from Associated British Ports (ABP), Solent Gateway and the Solent Local Enterprise Partnership(LEP). The National Park Authority is not a Solent Freeport Board member, but attends meetings in a non-voting capacity.
Text below in square brackets [ ] was omitted from the reading to the Authority, in order to remain within the time requirements for public speaking at Authority meetings. Notes provided for Authority Members, along with this statement, may be read here, and are given as direct footnote links below. Further context is in THIS article (forthcoming).
The case for excluding NFNPA from a formal decision-making role in relation to the Solent Freeport has not been made. Policy objectives for the Freeport are likely to conflict with both the Statutory Purposes of National Parks, and the 25 Year Environment Plan, notably regarding responsibilities for the protection, conservation, and natural capital enhancement of environmentally sensitive areas. In those respects, the New Forest is of unique global importance which must be recognised. We are deeply concerned by the prospect of further pressure on the special qualities of the National Park due to the proposed Solent Freeport. Simple retention of an ordinary planning regime[i], as promised by New Forest District Council (NFDC), will not ease our concerns, for these reasons:
- The stated aim for the Port expressed by the Solent LEP [in the consultation [ii]], proponent and Board Member of the Port, is to establish a “Virtual Planning Authority”. They suggest Freeports remove “existing environmental regulations” they claim limit incentives to investors.
- The current Planning and Infrastructure Bill[iii] and the Levelling Up and Regeneration Bill may expand the definition of Nationally Significant Infrastructure Planning removing local oversight.
- The ambition of ABP to develop the Dibden Bay SSSI [seen as “inevitable” by their previous chief exec[iv]].
- They’ve already registered the site for both Tax and Customs [as a fait accompli].
- NFDC adopted ABP’s label “ABP Strategic Land Reserve” ignoring its habitat designation.
- The Government’s initial response to the NPA’s queries about the Freeport implications[v] does not mention the Duty of Regard and states only that NPPF [National Planning Policy Framework] policy for protected landscapes will continue to apply within Freeport outer zones, excluding the Dibden Bay SSSI.
- The Duty of Regard has already been eroded by NFDC in their most recent local plan. [as noted by the RSPB and HIOW Wildlife Trust, the unsustainable level of housing development and inadequate mitigation for pressure on the Forest] [vi]
- Hampshire County Council and other proponents for the widening of the A326 [in part to support the Freeport development] have ignored the consequences to wildlife corridors and public access, showing lack of Duty of Regard. [vii]
- RSPB, and Campaign for National Parks have expressed concerns about Investment Zones and Freeports. [viii]
The Duty of Regard is key, the National Park will be negatively impacted by Freeport development. The National Park should have oversight through direct representation. The overlapping private interests of ABP, Solent LEP and Solent Gateway should not have disproportionate control.
[The notion that the Freeport could be a useful source of mitigation funding from developments is deeply flawed. The current level of development already in the NFDC Local Plan is well beyond the potential for mitigation. Development beyond these levels involves accepting irreversible damage which cannot be balanced by such small benefits. [ix]]
The Dibden Bay SSSI, an important site in its own right, is a vital support to winter waders that breed on the Open Forest. Its protection, as well as the many other sites for nature connectivity, wildlife corridors and green infrastructure, should be part of the priorities for this Authority outside the park, where nature doesn’t recognize administrative boundaries.
We ask this Authority to thoroughly weigh the implications on the Park’s Purposes, before supporting a Freeport or Investment Zone, or any planning regime that undermines the Duty of Regard. And if it goes forward, regardless of where the boundaries are drawn, the Authority should demand a place on the Board of the Freeport as a full voting member, and pursue a clear policy to block the destruction of the Dibden Bay SSSI.