Tag Archives | Planning

Notes: Solent Freeport Background

By Brian Tarnoff on 20/10/2022 in Uncategorized

Our statement regarding the Solent Freeport at the New Forest National Park Authority meeting on 20th October 2022 included these Notes and Footnotes for the benefit of the Authority Members.

Further context is in THIS article (forthcoming).

NOTES:

New Forest East MP Dr Julian Lewis submitted a question about the seeming inclusion of the whole of the New Forest in the provisional boundary of the Freeport.

LEVELLING UP, HOUSING & COMMUNITIES – SOLENT FREEPORT [53254] – 21 September 2022

Dr Julian Lewis: To ask the Secretary of State for Levelling Up, Housing and Communities, for what reason the entirety of the New Forest has been included within the provisional boundary of the proposed Solent Freeport. [53254]

[Due for Answer on 11 October.]

ANSWER

The Parliamentary Under-Secretary of State for Levelling Up (Dehenna Davison): By delivering investment on specific priority sites, Freeports will create thousands of high-quality jobs in some of our most disadvantaged communities. These sites have been carefully selected for their suitability for development by the local Freeport coalition, which comprises key private partners and Local Authorities who, importantly, provide democratic accountability for the actions of the Freeport. The development sites sit within an ‘outer boundary’ which sets the limit for how far apart they can be and broadly indicates the area they expect to benefit most directly from the Freeport’s economic impacts. While the Solent Freeport outer boundary intersects with the New Forest National Park, this in no way means that the area has been earmarked for development nor does this confer any special planning status. Local authorities retain all their statutory powers and responsibilities, including responsibility for providing planning permission. Freeport status in no way undercuts the local planning process and there is no change to the current planning and environment status of national parks.

https://www.julianlewis.net/covid-written-parliamentary-questions/levelling-housing-communities-solent-freeport

The Government’s assurances in their reply to Julian Lewis [above] do not mention or reaffirm the Duty of Regard to the National Park in the planning process, and given that this government and its predecessors have failed to bolster environment legislation (and may even further dilute), had Natural England assess their own proposals below the standards demanded by legislation, systematically defunded both Parks and the agencies relevant for delivery of environmental and habitat, their ambitious targets seem hollow promises.

ENDNOTES:

[i] Statement on NFDC Website, 14 October 2022

No changes to planning and environmental protection says New Forest District Council

New Forest District Council leader, Cllr Edward Heron has written to the Secretary of State for Levelling Up, Housing and Communities, in response to the call for expressions of interest to become an Investment Zone which was announced by government on 24 September 2022.

The letter reiterates that as a partner in the Solent Freeport, we are keen to secure the greatest benefits for their residents, as well as the local area.

Councillor Edward Heron writes:

“Within the government’s recent Investment Zone opportunity there is much that aligns and enhances the Freeport benefits, both to the tax site areas, and the wider District. The financial incentives are significantly enhanced and it is important that our businesses and developers have the opportunity to benefit from this new offer. For example, securing tax incentives over a 10 year period to 2032 rather than the current Freeport period which expires in 2026 and will make these sites significantly more attractive as a place to locate businesses.

We are keen therefore to explore with Government, and our partners what an Investment Zone could deliver for the Solent Freeport and ultimately our residents and our environment now and in the future, and I have therefore supported the Solent Freeport Board’s expression of interest submitted today.”

The announcement from government made it clear that Investment Zones would only be taken forwards with the support of the Local Planning Authority.

The letter from Cllr Edward Heron goes on to say:

“New Forest District Council supported the Freeport on the basis that the designation would not impact on the statutory planning process that a landowner would need to go through, to seek consent to develop the site.

The indication of support from this Council as the local planning authority is based on the understanding that the current level of environmental protection is assured for the future and on the clear and unequivocal understanding that conversion of the Solent Freeport to an Investment Zone will not include a streamlining of planning, deregulation, or a dilution of the environmental protections that are currently in place. Should this not be the case, then the Council would not support the designation of the Freeport Tax Site within the District as an Investment Zone.

I understand that this commitment is shared by the Freeport Board and we look forward to shaping a unique Investment Zone that delivers sustainable and inclusive growth for the New Forest and wider region.”

The increased Freeport opportunities for investment, regeneration, and employment were endorsed by us during the submission of the Solent Freeport business case to the government in March 2022. The business case carefully considered the Freeport within the context of the environmental designation across the area, working to focus on net zero, green recovery and strengthening the environment.

The Solent Freeport focuses on the Council’s Waterside area with the Waterfront tax site covering four specific landholdings; the former Fawley Power Station, Exxon Mobil, ABP’s Strategic Land Reserve and Marchwood Port (Solent Gateway). The whole District, including the New Forest National Park, is included in the Freeport outer boundary which is intended to ensure that the potential funding and broader benefits from the Freeport can be focused across the whole area.

https://www.newforest.gov.uk/article/3167/No-changes-to-planning-and-environmental-protection-says-New-Forest-District-Council

[ii] The Solent Protection Society review of the Solent LEP’s Freeport Consultation response makes these observations (quotes from the LEP response in italics):

Given the large number of local authorities across the Solent Freeport region, Solent LEP go further, proposing “the establishment of a special Virtual Planning Authority that is facilitated by a coordinating institution with the cooperation of relevant local authorities”. This is a direction which Solent Protection Society believe should be pursued with great caution. There are already well publicised proposals, for example the Aquind Interconnector project near Portsmouth and the Southern Water desalination plant near Fawley, where opportunities for public and local authority scrutiny are being overridden by central governments’ declaration of the initiative as a ‘National Infrastructure Development Project’.

The Solent LEP response also proposes “extending the permitted development rights accorded to ports to include assembly and manufacturing though they believe this would still not improve the planning environment enough to act as an incentive to potential investors. While the expansion of permitted development rights would simplify development processes on seaport land, it would still not allow for the greater freedoms or coordination in higher-level planning required to ensure Freeport success.”

In what might seem to some a worrying threat to environmental standards, the Solent LEP go further, suggesting that “existing environmental regulations along much of the UK coastline supersede Permitted Development Rights, further limiting their additional value as an incentive”.

https://solentprotection.org/2021/05/11/what-might-the-solent-freeport-mean-for-the-solent-area/

Their updated analysis of Freeport Tax Sites including noting that Dibden Bay is listed as both a Tax and Customs Site (for those trying to disabuse the notion of its development as a port facility). This notes particularly:

Marchwood Port / ‘Strategic Land Reserve’ – Solent Gateway / ABP

Tax site type – Existing Facility / Greenfield
Customs Site – Marchwood Port / ABP ‘Strategic Land Reserve’
Assumed programme delivery priority – High/Medium

It is notable that ABP have only submitted the northern part of their Dibden Bay ‘Strategic Land Reserve’ for definition as a Freeport tax site. Leaving the southern part of the Dibden Bay site out of the Freeport definition enables ABP to retain an option to keep this part of the ‘Strategic Land Reserve’ for future expansion of its non-freeport operations from the eastern shore.

Current environmental regulations give the Dibden Bay shoreline some level of protection from development, however once the freeport is in operation, developments within its boundary will benefit from the government’s proposed relaxation of planning regulations within freeports. As SPS observed in our report from May 2021, the Solent LEP at page 17 of their consultation response suggested that permitted development rights in freeports should be extended to enable those rights to supersede existing environmental development regulations.

Once development of the northern part of the Dibden Bay shoreline has been permitted under the freeport rules, then a precedent would have been set which could then be used to attempt to override the existing environmental protections outside the freeport boundary in the southern part of the ABP ‘Strategic Land Reserve’.

https://solentprotection.org/2022/03/21/solent-freeport-tax-sites/

[iii] Two bills effecting planning, with overlapping goals for growth are still proceeding forward, expect if one falls the other to remain:

https://www.planningresource.co.uk/article/1801329/expect-planning-infrastructure-bill

https://www.planningresource.co.uk/article/1801044/levelling-bill-cards-says-housing-minister-despite-rumours-contrary

[iv] Interview with outgoing ABP exec Doug Morrison [including claims for future of Dibden Bay]:
http://www.dailyecho.co.uk/news/10914052.Port_expansion_will_happen__says_outgoing_boss/

https://solentprotection.org/2014/01/05/dibden-bay-yet/

[v] Report to NF NPA Meeting 20/10/2022 by David Illsley, this is the paper that the Authority were to discuss after our statement in Public Questions. It outlines the lack of clear guidance from Government surrounding the Investment Zones, issues of implications of the Freeport and Investment Zones on the National Park, and options for the Members to support.
https://www.newforestnpa.gov.uk/app/uploads/2021/12/AM-637-22-Solent-Freeport-and-Investment-Zones-update-October-22-Authority-report-1.pdf

[vi] The Duty of Regard has already been eroded by NFDC in their most recent local plan:

During the 2019 examination both the Wildlife Trust and RSPB stated categorically that not only had the NFDC failed to show the efficacy of their current mitigation, but NFDC had in no way shown that they could possibly mitigate for their four-fold increase in housing development in the new plan. (also see Endnote ix below)

[vii] HCC failed to initiate the most basic habitat assessment before or since consultations around the proposals for widening the A326. Also, given the years of NFDC consistently overdeveloping the Waterside and permitting development up to the edge of the road, any widening will inevitably impinge on the Forest.

viii] The Campaign For National Parks wrote a brief analysis of the Investment Zones and Freeports, (including the claim that the current sea life disaster off the North York Moors coast are due to dredging at Teesside):

“The Government’s proposed Investment Zones may impact 7 National Parks and 29 Areas of Outstanding Natural Beauty – together accounting for 2 million hectares of our most special landscapes. This follows announcements on Freeports that include the New Forest, Dartmoor and North York Moors National Parks, along with many AONBs, within their boundaries. We only need to look at the ecological disaster unfolding on the North York Moors coast, with growing evidence suggesting this is a direct effect of the Teesside Freeport, to know that unregulated development in these precious landscapes would not end well.”

https://www.cnp.org.uk/blog/%E2%80%9Cnot-blind-opposition-progress-opposition-blind-progress%E2%80%9D

Their comments on the Government’s Response:

There is much to be concerned about in the current Government’s proposals to boost growth by “liberalising” planning and doing away with many vital environmental protections. One of the things we’re most concerned about is the proposed investment zones which, as analysis we published last week shows, could impact seven National Parks and 29 Areas of Outstanding Natural Beauty (AONBs). These areas account for a combined 2 million hectares of landscape, pulling in 250 million visitors last year, and generating an annual economic contribution of £24 billion.

We wrote to Simon Clarke, the new Secretary of State responsible for planning, to highlight these concerns and seek a formal commitment to excluding National Parks and AONBs from investment zones. Our letter also asked for reassurances that there will be no downgrading or removal of the additional planning protections which apply in these areas, including the presumption against major development.

We’ve now had a response from Simon Clarke, which makes lots of positive references to the benefits National Parks deliver, but unfortunately doesn’t give us the reassurances we need. It is good to see that the Secretary of State recognises the contribution of these Protected Landscapes to our identity, economy and environment, and his acknowledgement of the important role for these areas in achieving nature recovery commitments. But rather than ruling out any possibility of investment zones in Protected Landscapes, he says that they will only be allowed where there is local consent.

This doesn’t give us the reassurance we need. The Secretary of State must go further and confirm that there is no way that Investment Zones will go ahead in National Parks and AONBs. Placing the emphasis on local planning authorities to make those decisions brings huge risks, particularly for AONBs which are not planning authorities and have no formal role in decision making. Indeed, the Government set out proposals in the Landscapes Review earlier this year to make AONBs statutory consultees for planning precisely because they don’t currently have a strong enough role in planning decisions.

Dr Rose O’Neill, Chief Executive of Campaign for National Parks said: “We welcome warm words from the Secretary of State, but we need to see firm commitments in policy that Investment Zones will not go ahead in National Parks and AONBs.”

Campaign for National Parks is also very concerned about the impact that investment zones in other areas close to their boundaries could have on National Parks and AONBs. Increased development in neighbouring areas will only increase pressure for new roads and other infrastructure inside Protected Landscapes.

Rose added: “It is absolutely vital that our Protected Landscapes are protected from the impacts of damaging development outside their boundaries too. We only need to look at the ecological disaster unfolding off the coast of the North York Moors National Park, and the growing evidence linking this to the neighbouring Teesside Freeport, to see why it’s so important to protect our most precious landscapes from unregulated development.”

Campaign for National Parks fought for the creation of National Parks over 70 years ago. That they, and AONBs, have been stewarded safely and protected from irresponsible development ever since is one of the biggest successes in public policy in this country. The rules in place to protect them are not “burdensome requirements”: they are a vital part of ensuring we pass this inheritance to future generations.

https://www.cnp.org.uk/news/warm-words-are-not-enough-we-need-firm-commitments-planning-system

The ongoing issues with Teesside Freeport dredging and the DEFRA response to mass sea life poisoning, noted in the CNP’s response:

https://www.newscientist.com/article/2340893-whats-causing-a-mass-die-off-of-crabs-on-the-uk-coast/

The RSPB response to recent proposals including “Investment Zones”
https://www.rspb.org.uk/about-the-rspb/about-us/media-centre/press-releases/millions-called-on-to-stand-up-for-wildlife/

[ix] Additionally, the conservation charities agreed with the NFA contention that the mitigation regimes inappropriately use the 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 major SANG to the West at Moors Valley, and plans for similar facilities to the East not yet realized).

NFDC’s standards for SANG’s are not sufficient to create landscape scale alternatives for recreation of sufficient quality to take pressure off the New Forest. Initiatives to create effective and meaningful landscape scale mitigation projects to relieve recreation pressure on the Forest have been stalled continually, but their fruition should have been a prerequisite to any further development within the District. A HIOW Wildlife Trust assessment of greenspace provision within Hampshire ranked NFDC third from bottom, just above Portsmouth and Southampton, yet developers seek to erode the NFDC’s already minimal standards for SANG delivery. The Plan released Green Belt sites for development, rather than considering its potential for large landscape scale alternative greenspace for mitigation.

The Plan also undermined Duty of Regard by making the Fawley Waterside allocation dependent on the destruction of a SINC (Site of Interest to Nature Conservation) within the National Park, which was opposed by some National Park members.

Solent Freeport Requires Regard for the New Forest National Park

By Brian Tarnoff on 20/10/2022 in News, Planning

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).

Solent Freeport

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.

Declaration from National Parks Movement to Strengthen Protected Landscapes

By julietlynn on 19/10/2022 in News

The annual National Parks Societies Conference was held in Snowdonia last week.

Recognising the present scale of the nature and climate emergency, the Friends of the New Forest proposed a resolution calling on governments in England and Wales to give Protected Landscapes (National Parks and Areas of Outstanding Natural Beauty) their full backing in legislation. This was unanimously agreed by all National Park Societies and Campaign for National Parks who signed the joint declaration below

Declaration from the National Parks Movement:

At a time of nature and climate emergency, we must retain and strengthen the laws and policies which protect the Protected Landscapes of Wales and England. This means there must be:

No weakening, or removal, of vital European legislation such as the Habitats Regulations;
Effective schemes of support for farmers and land managers which safeguard rural livelihoods, reinforce nature’s recovery, and promote public access; and
A principle of safeguarding the additional planning protections which are crucial for Protected Landscapes.

We need to and will strongly support governments’ commitments to new purposes, duties and powers to ensure that Protected Landscapes can deliver more for nature, climate and people in future.

The statement was signed by the following organisations:

Campaign for National Parks, The Broads Society, Snowdonia Society,
Dartmoor Preservation Association, The Exmoor Society, Friends of Pembrokeshire Coast National Park, Friends of the Brecon Beacons, Friends of the Dales, Friends of the Lake District, Friends of the New Forest, Friends of the Peak District, Friends of the South Downs, North Yorkshire Moors Association

Delegates at the Conference (photo CNP)

This declaration will be used to engage with Parliamentarians and demand they do more to back National Parks and ensure their protection.

John Ward, Chairman of the Friends of the New Forest agreed with Dr Rose O’Neill, Chief Executive of the Campaign for National Parks that it was fantastic to see the National Parks movement in England and Wales come together to make a powerful, positive case for why these landscapes matter.

Unfortunately the signals we are getting from the UK Government in Westminster suggests they are heading in the wrong direction. Any government who is seen to be undermining these aspirations risks suffering a political price at the next election.

Just CLICK HERE to register your support for this Declaration

Presentment: New Forest Crown Freehold Properties

By Brian Tarnoff on 15/05/2019 in News

Here we welcome a guest post from Dr Tony Hockley, Chairman of the New Forest Commoners Defence Association, who gave this Presentment in this month’s Verderers Court.

I would like to begin with a quotation from the only person I have yet encountered with 100% confidence in their own knowledge of this landscape:

“It is not the flowers, not the birds or the deer or the badgers or the butterflies that are in most urgent need of conservation here but the people, the real people of this place.” *

Chris Packham’s wise words are deeply relevant to what I have to say.

It is now more than two years after I succeeded Dr Ferris as Chair of the CDA. Since then nothing has caused me greater and more consistent concern than the challenge of ensuring that there will be affordable land and homes available for the next generation of commoners – in Britain’s least affordable National Park ** .

We are fortunate that we have a keen and active young commoners group in the CDA. Young people who are willing to commit their lives to sustaining the grazing of the New Forest – An incredible vocational commitment, amongst all the other pressures of modern life, upon which everything that is so special about this landscape depends.

In 1991, after a thorough review of the challenges and all options to sustain grazing, the Secretary of State determined that the 65 Crown holdings should be prioritised for those who would commit to New Forest grazing, and that they should be kept truly affordable to them. Since the time of the Illingworth Report these holdings have enabled families with a long history of commoning to maintain the practice, from one generation to the next. We all benefit from their love of the New Forest, their deep knowledge of the livestock and the landscape, and their lifelong commitment to commoning. The Crown holdings have been crucial in this.

In 2016 all that changed – on a whim. The Forestry Commission simply decided that market rents would help fill the coffers: To cash in on property values in Britain’s most expensive and least affordable National Park. In 2017 Sir Desmond Swayne prompted ministers to remind the Commission that such a change of policy would require a formal and inclusive review, and a decision by ministers. Since then we have caught the Commission advertising cottages to the highest bidder, with no mention of grazing, and allocating them to its own managers however it sees fit.

Forestry England is now attempting to entrap this Court in its disgraceful strategy of privatisation by stealth. By selecting just one small part of the Government policy, for one cottage at New Park; this is the involvement of Verderers in tenant selection. Clearly, it hopes that the Court will not notice:

Every other holding has been auctioned or allocated to staff. With no consultation with this Court: Powdermill, Kings Hat, Longbeech, Springfield.
The rent for Little New Park has been fixed at more than 100% of many young commoners’ household income. Not the 15% stipulated by Government. With no consultation with this Court.
An arbitrary qualification has been set, that at least 10 ponies will be turned out from Little New Park’s 1.3 acres of back-up land. With no consultation with this Court
It has separated the barn from the property: Again with no consultation with this Court.
For Little New Park it is demanding income statements from anyone interested, to check they can afford £18,000 a year in rent alone and to deter all those commoners who cannot.

Tenant selection is, therefore, just a trap that the Court would be wise to avoid. This is simply a diversion along the route to effective privatisation of the Crown freeholds; removing them from support for commoning.

This open defiance of government policy for Crown property is shameful from a public body. It not only defies policies that have worked well to sustain Forest grazing over a quarter century. It also defies the Ministers Mandate to the Commission; that it should put the Forest first, ahead of its corporate financial interests. And it defies the 2018 Accord with National Parks England. I am very sorry to say that we no longer have confidence in the Deputy Surveyor to put the Forest first in this regard.

This is a matter of the utmost gravity for the future of commoning in the New Forest. We have tried for three years to work with the Forestry Commission – willing to discuss update the Illingworth policies, but their ears are deaf to the voice of the Forest. They will push on regardless of all due process. Standing idly by whilst Forestry England misappropriates these Crown properties, so that tenancy is a matter of income rather than the good of the Forest, will have lasting consequences for the conservation of this precious landscape. We are very grateful to the Friends of the New Forest for their support.

I have written to the Secretary of State to ask him to put a stop to this disgraceful episode. I would urge the Court and the National Park Authority to do likewise.

Dr Tony Hockley is a Practicing Commoner and Chairman of the New Forest Commoners Defence Association. This has been shared with his express permission, and represents the view of the CDA.

The Friends of the New Forest fully support this position, and have and will continue to stress the importance of all initiatives to maintain affordable housing stock for practicing commoners which is essential to commoning’s continuing service to the Forest.

The CDA Blog post detailing more of the history including the Illingworth report may be read here.

* Chris Packham, Foreword to Clive Chatters “Flowers of the New Forest” WildGuides (2009), p9
** Average property values within the National Park boundary are now 15.9 times average local income.

Presentment: Ashurst Hospital Site

By Brian Tarnoff on 17/04/2019 in News, Planning

1909 Map including the layout of the Ashurst Workhouse

We welcome a guest post from our former chair, Peter Roberts, who gave this Presentment in this month’s Verderers Court.

Ashurst workhouse from the west c.1907.

My name is Peter Roberts. I am a former Verderer and a former resident of Ashurst.

Yesterday the National Park Authority published their Plan Amendments which includes the use of of land at Ashurst for housing. This land is the former Workhouse Site, which was taken from the open Forest in 1836. When the grant for the land was made there was a specific reservation that in the event of the workhouse no longer being required it should revert to the Forest. Seven acres of the site were returned to the Forest in 1988, thanks mainly to the work of the late Verderer David Stagg.

The remaining land is commonable land from which the common rights have never been removed. It should be returned to the open Forest for grazing for the commoners stock. I implore you to object most strongly to the National Park Proposed Main Modifications and work towards returning this land to the rightful users.

1836 Site Plan

Notes:
The grant was made on 31st December 1836 and may be found in the Wood Lease Books now held by the Forestry Commission in Queen’s House (Vol 4 pp 279-285). The original is at Kew: NRA ‘Grants of land for Workhouse 1836-1915’, F10/52 4079/1.

We thank Peter for permission to share this Presentment, and his notes. For the 150th Anniversary of the New Forest Association (aka Friends of the New Forest) he wrote our history in Saving the New Forest.

At last month’s court, in a short, off the cuff, two sentence presentment, one of our trustees similarly urged the Verderers to assert the Forest’s rights to the land in question. Our planning committee had made a representation to the New Forest National Park Local Plan Inspectors regarding the site. Notes from both Peter Roberts and Richard Reeves regarding the site were shared privately with the Verderers at that time.

New Forest Local Plan Modifications are open to consultation until 31st May 2019. More information, including the additional Ashurst Workhouse allocation, which does NOT recognize nor even mentions the Forest rights of the portion not returned to the Forest, may be found here.

Presentment: Our Objections to Local Plans

By Brian Tarnoff on 17/10/2018 in Habitat, News, Planning

New Forest District Council’s Local Plan aims to build 10,500 homes over ten years. In their own summary they admit this is 3 to 4 times their current development rate. 13 of 20 of their proposed strategic development sites are on Green Belt.

This will increase the population in the district and park by roughly 7 times that of Lyndhurst. One of these “Lyndhurst”s will be an entire new village at Fawley, which will increase the population of the park by 10 %, at the wrong end of the already stressed A326 transport corridor. This would have a severe recreational impact on the Forest with disturbance to habitat and livestock, and would further urbanize the already saturated Waterside Area, requiring upgrades to the roads that due to that saturation would necessarily encroach onto the highly protected Crown Lands within the National Park, and would increase traffic westward across the Park on roads already animal accident blackspots.

The New Forest National Park Authority and NFDC share a viability study that accepts the developer’s contention that in order to develop 1500 homes at Fawley, they must build 120 as premium homes on a Site of Importance to Nature Conservation in the National Park. Adjacent to the Power Station site, Tom Tiddler’s Ground is a young coastal grazing marsh that could easily qualify for SSSI status if it were grazed by commoners livestock[1]. [see addendum below for alternatives offered]

The National Park is failing its statutory purposes to conserve and enhance by adopting the poor logic and questionable feasibility behind the NFDC support for the Waterside development, and lack of objection to the scale of NFDC’s 10,500 home plan. The Park Authority and District Council should be working together to fulfil their legal obligation to protect the Forest, not to undermine that protection for the sake of NFDC’s political objectives.

The Friends of the New Forest / NFA are objecting to the NFNPA Local Plan under examination in November, before your next court, because if accepted as it is, it lays the groundwork for NFDC’s Local Plan which presumes the need and scale of the NFDC objectives, including the destruction of Tom Tiddler’s Ground.

The Government 25 Year Environment Plan promises greater protection for National Parks and both designated and undesignated habitats, and a review for possible expansion of the boundaries of National Parks. The Park’s own policy should only allow major development under exceptional circumstances. 10,500 homes in the ostensible buffer around the Park, the intentional destruction of Important habitat, and the decimation of Green Belt flies in the face of any presumption that the National Park provides the Forest with any protection.

We ask the Verderers, in their role as a statutory consultee to support our objections, particularly when the NFDC Local Plan is considered. This is a generational threat to the Forest, and hope that all present in both official and private capacities will join us in this fight.

[1] Indeed previous attempts to do just that failed only due to unreasonable demands from the Power Station management.

ADDENDUM:
The current proposals range from 1500 homes on both the site and onto the SP25 land, or 4000 homes on the site alone (that profitability in the viability study equates 120 homes on the Park’s area with 2500 homes difference, is an example of the nonsense that the viability study purports, and a veiled threat to make an even more unacceptable development). Even within the Power Station site, the proposals are not limited as they should be to just the former industrial area. There is also an entirely cracked logic that if these homes must be built to fund the Power Station site development, that they must be built there, and not anywhere else in the country, and they must be built first, but with no guarantee that the industrial site would be developed subsequently.

The current proposals for the Power Station site, which do not demonstrate exceptional circumstances required for major development within the Park, should either be abandoned, scaled down to minor settlement, or mixed use for recreation or perhaps most fittingly for its industrial heritage sustainable power generation in the form of a solar array, all of which should be confined wholly to the industrial area alone, and outside the 400m zone of any future and very likely SPA designation.

NFA Habitat and Landscape 2017-18

By Brian Tarnoff on 15/04/2018 in Habitat, News

RSPB Franchises Lodge - credit Terry Bagley

Habitat and Landscape Chair, Brian Tarnoff reviews with uncharacteristic brevity the past year on the Forest Design Plan, Recreation Management Strategy and the England Coast Path. Part of our series of Annual Reports relevant to our AGM on Saturday 21st April 2018. Updates since original publication, reflecting these ever changing issues, are provided below each section.

Once again I am full of gratitude and amazement at the generous contributions of our committee members this year. This included countless hours volunteered to pour over one of the most vital consultations we’ve seen in some time, and days spent trudging the Forest in all weathers on site visits for works proposed by the Forestry Commission on the open Forest.

The Forest Design Plan

Consultation continued this year. Our ecologists took part in round table discussions on this year’s draft, a palpable improvement over the March 2016 version. The detail, which had concerned us previously, now was much more in line with the commitment from the 1999 Minister’s Mandate (strongly supported by subsequent policy) to restore pasture woodlands, heathlands, valley mires and Ancient and Semi-Natural native woodland, and favour broadleaves over conifer. In these meetings, Forestry Commission staff expressed sound underlying principles that would serve this plan, both in its current form, and going forward, to manage towards these goals.

Our main quibble is that the documentation of the plan does not adequately express those principles. This may seem a small thing, given how close the detail plan is to delivering many of our Association’s goals, but without them in place the plan may not be able to show its logic adequately to stand on its own against Habitats Regulations Assessment, or possible changes in future management of the Forest which could veer away from the promise this plan holds.

After the public consultation on the plan, the Forest Services review determined that consent under EIA regulations is required for the deforestation proposals (some areas being returned to open Forest habitats). Forest Enterprise has been tasked with producing an Environmental Statement for consideration, and we are amongst the stakeholders invited to a scoping exercise in January 2018. DEFRA have agreed to roll forward some elements of the FC’s expired felling license, which was dependent on the now unknown date for approval of the plan by the Inspectorate for renewal.

The Forestry Commission have opened up the next stage of consultation which runs for eight weeks from 11 Apr 2016 to 6 Jun 2016. This will produce the version of the plan which will be submitted for the inspectorate, and final consultation later this year. The NFA will argue that the planned eight weeks may not be sufficient for less nimble organizations (those that meet less frequently, such as Parish Councils, or those larger whose relevant knowledge is spread across expert and consequentially busy staff); we would prefer ten to twelve weeks. When the timeframe was sprung upon the great breadth of Forest organizations in attendance at a special launch day on March 22nd, the FC suggested that they may be “flexible” about the length of the consultation. We will be making our case later this month.

Wetland Restoration Strategy

In a similar spirit of openness the Forestry Commission proposed a Wetland Restoration Strategy at a well-attended December workshop including representatives across the spectrum of the debate. In addition to more constructive engagement with all stakeholders, we hope this will lead to a monitoring program that is apt, affordable and will adequately support future efforts.

The FC have just updated us (12/04/2018) with a view of present and future monitoring plans. We believe these will be robust and adequately adapt and augment standard river monitoring techniques to the unique challenges of the New Forest’s streams and wetlands. We hope sufficient funding will be allowed to cover a range of catchments including both restored and untouched.

England Coast Path

Understandably our section of Coast, with a nearly uninterrupted series of very protected habitats (some garnering between four and five layers of designation, nationally and internationally), has been a very thorny problem for Natural England, who have nudged the consultation forward throughout the year. Once mooted for March 2017, now February 2018 (the original target date for implementation was March 2018).

Although a habitat adjacent inland route may be viable, the coastal margin created by the default spreading room designated in the Marine and Coastal Access Act 2009 would potentially create up to 3,500 acres of new access land on these easily disturbed habitats, where it would cause irreparable damage. We hope that Natural England will exclude these, but even if they do, the Ordnance Survey will not show those exclusions. Our main role currently seems to be to remind one and all of the immense importance of our Coast with greater fragility and importance than the precious habitats of the Crown Lands that typically draw our focus.

The eight week consultation on the Highcliffe-Calshot stretch finally began on 14th March 2018 and is due to run until 9th of May 2018. The route itself (barring some quibbles) is reasonable, however the exclusions for spreading room are either incomplete or lacking classification for habitat protection. The consultation documents themselves are of greater scale and complexity (the sensitive features appraisal alone, at 215 pages is three times larger than the equivalent document for any of the other published stretches), and yet we’re expected to comment on them within the standard 8 week consultation window. The Sensitive Features Appraisal is rife with error and stops short of a full Habitats Regulation Assessment (relying on flimsy mitigation measures which have failed elsewhere). We could go on (and we will elsewhere….), but in short, the needs of our habitat point up severe flaws in the legislation, specification and consultation processes.

Recreation Management Strategy

The welcome review of the NPA’s Recreation Management Strategy has been mentioned above in this annual report. Unfortunately the public survey reiterated paragraphs from the current strategy alongside each potential subject heading, leaving some confused as to whether to respond to these remarks or implicitly approve them? For our response we asked that the next RMS should feature priority projects with clear objectives and timeframes. We proposed a comprehensive review of recreation infrastructure within the park, including surveys of habitats, campsites and parking, with actions leading to a provision that is ‘Fit for Purpose’. We proposed initiatives to raise the profile of the National Park so the decision makers of adjacent Authorities and communities become more aware of their impacts on the Forest and ‘Section 62 Duties’, create adequate, proportional mitigation, and petition Central Government for more strategic targets to take pressure off the Forest. We also asked for clearer messages in Education that would easily highlight the Forest’s need for protection as a National Nature Reserve, Working Farm and Working Forest.

Our full response to the RMS survey is here. Subsequent remarks on the Park Authority’s flawed draft interpretation here.

Going Forward — Other areas of concern to address in 2018:

Dibden Bay (ABP) / Fawley Power Station (Fawley Waterside Ltd)

Along with Associated British Ports revisiting their goal of a deep-water container port at Dibden Bay, our Association and the whole of the Forest will be facing many challenges for renewed development of the already heavily urbanised Waterside. This includes the proposal by Fawley Waterside Ltd for the development of a new town, with an estimated population of 3,500 on the site of the Fawley Power Station. The development on the brownfield portion of the site, originally exempted from the National Park, might be hard to resist, but the current proposal includes a ‘village’ built out into the National Park on Tom Tiddler’s Ground*, which is a young coastal grazing marsh and forms a rough habitat that is prime for rehabilitation.

— excerpted with updates and links from the NFA Habitat and Landscape Committee Annual report, by Committee Chair, Brian Tarnoff

* Tom Tiddler’s Ground is considered over several pages in committee member Clive Chatter’s tome Flowers of the Forest.

Finally, we should note that many of our committee members were involved in steering the process which led to the purchase by the RSPB of a major landholding in the Forest, now to be known as RSPB Franchises Lodge. We’ve been embargoed from discussing this effort as it has unfolded over the years (and at long last announced on 23 Mar 2018). I wish to thank the RSPB for the purchase, and the members of our committee who identified and shepherded this opportunity to fruition.

NFA Planning and Transport 2017-18

By Brian Tarnoff on 14/04/2018 in News, Planning

Here Planning and Transport Chair, Graham Baker weighs in, with some frustrations, over the past year, full of mounting concerns of increased pressure on the Forest. Part of our series of Annual Reports relevant to our AGM on Saturday 21st April 2018.

It is difficult to read the 2016 planning report and not to conclude that 2017 has been a largely wasted year. You will therefore excuse any frustrations that show.

There remains little between our Association and the National Park Authority (NPA) over individual planning applications. In the defined villages we are succeeding in coping with the need to increase central housing densities without disturbing the spacious nature elsewhere and coping with the reduction in retail outlets without losing the vitality of High Streets. Residents agree that the type of housing required is modest, suitable for younger people starting out and older people downsizing. But we are challenged by developers’ desire to build what is most profitable without regard to local need; currently this is managed flats for old people who can afford high charges.

Second home ownership and short-term letting are growing at a rate that could exceed the planned increase in housing numbers. This sometimes requires planning permission and it is always worth knowing the extent of the problem, so please let us know if it happening near to you.

In the countryside problems remain dispersed but accumulatively erode character and traditions. Commoning properties are sold to the extremely well off who then seek to convert their humble holding into something else. Extensions are maximised, tatty outbuildings are replaced by three car garages with fully equipped offices above, large loose boxes are replaced by a row of pretty stables, ménages replace a pleasing adjacent paddock and elaborate electric gates or cattle grids replace five bars. Any common grazing land owned outside the new fence is “tidied” – this usually means easing the entry of the Land Rover Evoque by dumping tonnes of gravel on common grazing land. Often these activities do not break planning rules. Where it does we seeks first to have the applicant reconsider and secondly seek refusal.

Discussions continue on the revised Local Plans of the National Park and NFDC. We have achieved protection for the NF Special Protection Area broadly similar to that of the Thames Basin Heaths. This caused several proposed housing sites to be withdrawn, but rather than reduce numbers, NFNPA sought more sites, previously considered unsuitable, to keep the likely new dwelling numbers at around 35 per annum. The average house price in the Park is £581,000, over 15 times average earnings and there is a desperate need for affordable homes for local people. The NPA recognise the problem but their solutions lack ambition. We believe a straightforward policy that all new housing should be affordable stands the best chance of resisting incessant government meddling and developer manipulation and that the NPA should accept a greater role in securing underutilised publicly owned land in the villages for development.

Since we have become a National Park, the NPA’s own data reports that the success of many species of ground and low nesting birds has suffered a “marked decline”. The universally agreed cause is disturbance from recreation and the extra dwellings being built around the New Forest will result in an additional million visitors per annum, considerably worsening the problem. Despite this it is difficult to find any action stemming from the NPA’s 75 page Recreational Management Strategy since its publication in 2010. The planning committee will do all it can to ensure the emerging Local Plans recognise recreational pressure on the National Park as the primary problem facing the New Forest and that compensation from developers is used in forthright measures to reverse the problem. The relocation or closure Forestry Commission car parks will be one of the most effective management tools in reducing disturbance and we have developed sophisticated mapping techniques to measure levels of disturbance from them.

In 2017, planning volunteers have scrutinised over 1,000 planning applications, responded to a dozen consultations, developed maps, maintained good relationships with the parishes, plotted aircraft routes and surveyed overhead cable routes (with some success the line south and west of Burley is to be buried in 2018). Our thanks go to them all.

Planning & Transport Committee Chair – Graham Baker

NFA Council and Trustees 2017-18

By johnward on 11/04/2018 in News

With our AGM fast approaching on Saturday 21st April 2018, this and next week we’ll feature our annual reports. NFA Chair John Ward reports on the work of our council and trustees on both this year’s work and our 150th Anniversary celebrations.

Formal meetings of Council were held six times and for the Board of Trustees four times during 2017. In addition there were regular meetings of the Habitats and Landscape Committee and the Planning and Transport Committee; and also ad hoc meetings of the Education Working Group. At the end of 2017 there were eight trustees and sixteen nontrustee members of Council.

We have continued to share issues and experiences with other National Park Societies and as a Council member of the Campaign for National Parks (CNP): and have collaborated with them to co-ordinate responses to government and other national consultations and draft proposals that will affect National Parks. Examples of national consultations and draft proposals with implications for the New Forest that have crossed our desks in 2017 include:

Department of Transport consultation on the future of strategic roads
Emergency Services Network (ESN) – mobile communications
Campaign for Better Transport Report
Ofgem open letter on RIIO-2 Framework
Electricity transmission owner stakeholder consultation
Government Housing White Paper
Government proposals for Permitted Development Rights
Proposed UK Minerals Strategy

We have held informal liaison meetings with the National Park Authority and Forestry Commission; and attend various New Forest forums and working groups including the Consultative Panel and meetings of the Verderers Court. The Friends of the New Forest were in evidence on stands at the New Forest Show and at Roydon Woods Woodfair. Sponsorship funding support was given for the animal accident ‘advert’ on the back of the New Forest Tour bus through 2017; and also for the ‘Our Past Our Future’ projects for ranger training and for habitat restoration. The Association had previously committed to support the project to develop housing for commoners at Rockford farm and during 2017 we contributed to the costs of preparing drawings and making a planning application. On the research side we made a funding contribution to the New Forest Curlew Project.

2017 was, of course, our 150th Anniversary year. At the end of 2016 we launched “Saving the New Forest”, the book written by Peter Roberts telling the story of our Association. It has been selling well throughout 2017. The story of the Association and the New Forest from the mid 19th century until today was put together into a slide show presentation. This has been given to more than 20 groups, reaching over 1,000 people most of whom had not previously heard of us and gaining donations to support our work to protect the Forest.

We organised and hosted the National Parks Societies annual conference, held this year in October at Balmer Lawn Hotel and attended by 50 delegates from other national parks, the Campaign for National Parks, other national bodies and New Forest organisations.

During the year our Anniversary programme provided 16 events. Walks and visits included, the Verderers Court and Lyndhurst Church, Archaeology in Sloden Inclosure, Caring for Pondhead Inclosure, Needs Ore, Rockford and a Fungi Walk at Rans Wood. Following the AGM there were options to visit Furzey Gardens or Minstead Study Centre.

Two events were held specifically to celebrate the 150-year anniversary:

Lunch at MJs restaurant was attended by our Patron, Belinda Lady Montagu, and President, Oliver Crosthwaite-Eyre, together with NFA members and trustees, affiliated Parishes and representatives from the Forestry Commission, Verderers, Commoners and National Park Authority.
Council members and invited guests gathered at the Crown Hotel in Lyndhurst on the 22nd of July to raise a glass and mark the day on which the New Forest Association was founded.

We held two receptions and exhibition private views – The New Forest Open Art Exhibition at the New Forest Centre, and New Forest Bird Sculpture by Geoffrey Dashwood at St Barbe Museum and Gallery.

Purely social events proved to be less popular with Friends of the New Forest and a summer garden party and an autumn golf day were cancelled due to lack of support. Unfortunately the intended Frohawk Walk was also cancelled at short notice due to a gypsy drive-in clashing with this event. Ours was not the only anniversary this year. It was the 800th anniversary of the New Forest Charter and panels about the New Forest Association were included in a display at the New Forest Centre. In November we hosted a small delegation from the Anglo-Portuguese community who visited the New Forest in November to mark the 100th anniversary of the arrival of 150 Portuguese troops to assist with timber production for the war effort.

Two large events for 200 people, both of which were booked out with waiting lists, provided the bookends for the Anniversary Year.

The first was “What Future for the New Forest – A Foot in the Past and an Eye to the Future”, with a keynote address from Council member, Clive Chatters followed by responses from Alison Barnes, Chief Executive of the New Forest National Park Authority, Bruce Rothney, Deputy Surveyor for the New Forest and Dominic May, Official Verderer, together with the audience. Clive identified the management of recreation in the Forest as being a key issue, and concluded that ‘this generation’s responsibility to secure the future of the Forest now lies with us’. By the end of the evening there seemed to be an emerging consensus, particularly with respect to recreation management, that it feels like ‘one of those moments for bold decision making’.

Our final, very well attended event was “An Evening of New Forest Films with Lord Montagu”. This was hosted at the John Montagu Theatre in the Beaulieu Motor Museum, and featured a fascinating array of archive footage of the Forest, some not publicly viewed previously. We thank both Lord Montagu and Dr. Manuel Hinge for this most fitting closing event for our Anniversary year, and their untiring efforts to preserve films that provide an historical, cultural, and community window on the Forest.

Recreation management continued to be a major issue for us through the year. There have been several presentments to the Verderers Court echoing similar concerns, and at the New Forest Show the National Park Authority launched a consultation on reviewing their Recreation Management Strategy. We responded to this consultation and also opened up a dialogue on the subject with the Forestry Commission. We believe this is the most pressing issue needing to be addressed within the Forest and significant action must to be taken to review and change the recreation infrastructure within the Forest. To succeed his must be driven by the statutory authorities with as much vision as those who implemented the 1971 Conservation of the New Forest proposals and not just end in fine words but with little tangible effect.

Chair – John Ward

DEVELOPMENT THREAT TO THE NEW FOREST

By johnward on 23/02/2018 in News

DEVELOPMENT THREAT TO THE NEW FOREST – URGENT
Please help us to help the New Forest. Your action is needed now!

Friends of the New Forest (New Forest Association) is urging our members and supporters to respond to a public consultation in order to protect part of the New Forest National Park from a development scheme that is proposing over 1500 houses (bigger than the size of Lyndhurst) to be built on or near the site of Fawley Power Station.

We believe that this development will have a detrimental impact on the ecology of the area and are urging people to oppose the scheme before the public consultation deadline to the National Park Authority Local Plan ends on 28th February.

Although the Fawley Power Station site itself is in the control of New Forest District Council, it is an ‘island’ within the National Park and the development impacts will fall heavily on the National Park. The proposals of the National Park Authority’s Local Plan could pave the way to development of 1500 or more houses that would clearly constitute a major development.

Your comments on Fawley Power Station Site in the New Forest National Park Authorities Plan should reflect:

• Need for use of site for building not proven.
• Site could be made safe and managed for conservation.
• In the long term the site could be included within the National Park.

If it is developed on the scale proposed (1500 houses) there will a catastrophic environmental impact on the New Forest:

• Extra traffic will cause loss of tranquillity
• Increased risk to Forest livestock – may lead to road widening and fencing.
• Extra recreation will bring more litter and more disturbances.
• Extra recreational horse keeping will raise the cost of renting back up land to beyond what a commoner can afford.

A town of this size will require additional development of schools, surgeries, shops, and pubs.
It will be larger than Lyndhurst (1374 households at 2011) – Would this be tolerated in, say, the Lake District?

In addition it is stated that National Park land will be required for an additional 120 houses:

‘Viability work commissioned by the Authority and New Forest District Council concludes that without some limited development in the National Park, this major brownfield site could only come forward with a very high density development on the brownfield site outside the National Park – development that in itself would have a detrimental impact on the surrounding National Park. ‘

This feels like being held to ransom and is clearly nonsense.

Many of the National Park Authority members are also Councillors of NFDC who are pursuing this development. How independent is the National Park Authority and how does this development meet the dual purposes of the Park?

This development does not foster the economic and social well-being of the local communities within the National Park – it drops a complete new settlement into its midst which does not in any way comply with National Park purposes.

Another major anomaly is the lack of protection for back-up grazing land. The practice of commoning is recognised as essential to the ecological and heritage assets of the area. Policy SP48 includes ‘…resisting the loss of back-up grazing (which is fundamental to commoning) through development…’

BUT Local Plan Policies SP22 and SP24 recommend approval for 60 houses at Ashurst and 40 houses at Sway that would result in the loss of back up grazing in direct contradiction to the earlier policy.

PLEASE OBJECT TO THE LOCAL PLAN
BEFORE THE END OF THIS MONTH
Particularly Policies SP22, SP24 and SP25

YOU MAY OBJECT BY emailing THE NATIONAL PARK PLANNING TEAM AT:
policy@newforestnpa.gov.uk

BY FILLING IN THE NATIONAL PARK AUTHORITY FORM AT:
https://www.surveymonkey.co.uk/r/GJRLLJJ

Information about the local plan and a copy of the local plan are here:
http://www.newforestnpa.gov.uk/info/20040/planning_policy/361/local_plan

We are grateful for your support.

Friends of the New Forest
Registered Charity No. 260328

1 2 … 4 Next →

Top Menu

Navigation