|We were greatly heartened by the news that Forestry England and Forestry and Land Scotland had purchased Camping in the Forest (CiTF) from The Camping and Caravanning Club, because this seemed to present a great opportunity to review campsites in the New Forest with a fresh start in their management.
However, with the publication of tender documents for campsite management the Friends of the New Forest are now gravely concerned that the process of appointment of an operator of campsites on the Crown Land is failing to have proper regard to the particular circumstances of the Forest. We have made our concerns known to the Chief Executive of Forestry England and to the Deputy Surveyor in the New Forest in the letter reprinted below.
|22nd June 2022
Dear Mr Seddon
Tender for the operator of New Forest campsites
We were greatly heartened by the news that Forestry England and Forestry and Land Scotland had purchased Camping in the Forest (CiTF) from The Camping and Caravanning Club, because this seemed to present a great opportunity to review campsites in the New Forest with a fresh start in their management. Likewise, Craig Harrison, Deputy Surveyor, commented, “Taking greater control of these [campsites]will allow us to continue to offer this experience and support local businesses, whilst working more closely with our local partners to plan and develop their future”; and the New Forest National Park Authority expressed the view that, “A number of these sites are located in environmentally sensitive areas and longer term, we are keen to explore with Forestry England and partner organisations whether some of these pitches could be relocated to less sensitive areas.”
However, with the publication of tender documents for campsite management the Friends of the New Forest are now gravely concerned that the process of appointment of an operator of campsites on the Crown Land is failing to have proper regard of the particular circumstances of the Forest. We question whether the proposed terms of a lease are lawful, we are certain that the process is inappropriate. There is a risk that a future operator of campsites will compound existing harms to the Forest and will find themselves in conflict with those concerned with the conservation of the Forest. We therefore request that Forest Enterprise suspend the current process of appointment and take time to work with partners to review their strategy for camping in the Forest.
Our broad areas of concern are set out below.
We question whether Forestry England, on behalf of the Secretary of State, has the lawful authority to enter into a lease with campsite operators as set out in the draft Heads of Terms. Our understanding of the tenure of the Secretary of State in the New Forest is that it is insufficient to enter into such agreements.
We had expected to see any arrangement with campsite operators being fully compliant with the laws and legislation governing the New Forest, particularly incorporating the role of the Court of Verderers and the rights of Commoners. This absence infers that Forestry England do not properly appreciate those roles and rights.
We are alarmed at specific provisions in the Heads of Terms, notably those relating to provisions for ‘year-round’ camping (rather than the limited open season in the New Forest) and provisions for removing a percentage of trees each year from the campsite without any reference to aesthetic and nature conservation obligations. Furthermore, we regret that the Heads of Terms do not set out a campsite operator’s obligations to deliver the statutory and policy commitments of Forestry England arising from designations, nor advise prospective campsite operators that they will become an ‘occupier’ of the designated sites and therefore will be regulated by the relevant authorities.
Consequently, we are concerned that the documentation accompanying the Heads of Terms fails to clearly advise prospective campsite operators of obligations arising from the status of the New Forest as a National Park, a Site of Special Scientific Interest, a Natura 2000 site (both a Special Area of Conservation and a Special Protection Area) and a site designated under the Ramsar Convention. In the past, Forestry England have recognised some of their obligations to these designations, not least in their signing the 2001 Special Area of Conservation (SAC) Management Plan together with the agreement of 1995 that the Crown Lands will be managed as if they were a National Nature Reserve.
Over twenty years have passed since the Forestry Commission recognised the need for closure of selected campsites due to the damage they have done to the internationally important habitats of the New Forest. Not only have those closures not happened but other remedial works agreed with Natural England have not been delivered, nor have the baseline surveys and monitoring of the condition of campsites been delivered. The Friends of the New Forest sought to assist the establishment of baseline surveys through our report of 2004, unfortunately Forestry England have not adopted this methodology on other sites, nor have they used our work as a baseline for monitoring. In the meantime, we have experienced a continual deterioration in the condition of campsites, with decades more attrition to their character.
Since the signing of the 2001 SAC Management Plan, the New Forest has been declared a National Park, with its own statutory obligations relating to the aesthetics and special qualities of the landscape. With National Park status comes the Sandford Principle, setting out the pre-eminence of the conservation of the Special Qualities of the National Park. We regret that this principle is not reflected in Forestry England’s appointment process.
Fifty years ago removing unfettered camping on the New Forest was a bold and essential move, although establishing some designated campsites on the open Forest perpetuated problems of conflict including with semi-feral roaming stock. And much has changed in half a century, not least a rising appreciation of environmental issues, the biodiversity crisis and our understanding of the harmful impacts arising from poor locational or management decisions for some aspects of recreation in a fragile landscape. Now could be an opportunity to review historical decisions in that context – it should not be lost. We remain committed to participating in planning a fresh start with camping and working with whoever becomes the operator in the New Forest.