Desmond Swayne MP for New Forest West; DR Julian Lewis MP for New Forest East; and Daniel Hannan MEP for the South East have issued the following response to the New Forest National Park Authority's controversial draft management plan in the form of a joint letter to the chairman of the NPA. Although the principal concerns expressed have focussed on proposed restrictions on dogs and horses, DR Julian Lewis MP identified a deeper problem when commenting on the reslease of the MPs joint letter: he said "First the National Park was imposed on the Forest by the Government. Then it took planning powers away from the democratically elected New Forest District Council when it did not need to do so. The result is the present uproar and the problem will only be solved if democracy is restored to the management of the Forest".
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Clive Chatters
Chairman
New Forest National Park Authority
South Efford House
Milford Rd
Everton, Lymington
Hants SO41 0JD
11 November 2008
Dear Clive
Please accept this letter as our joint response to the draft Recreation Management Strategy and the Park Plan Consultation draft.
We believe that the interests of the communities that we represent will best be served by promoting a broad consensus in support of measures to conserve the New Forest for this and future generations. A sense of ownership, pride and shared endeavour needs to be at the heart of this approach if it is to succeed.
The consultation documents have had the effect however, of uniting our constituents against the NPA proposals (we note that the response of the Verderers has been ‘spun’ as being in support of the NPA proposals but this is not consistent with the detail of their response nor the representations of those Verderers who have spoken to us.) We have received only six representations in favour of the NPA’s proposals as against hundreds which are opposed to them and nine thousand signatures on the Forest Uprising petition.
Service Villages
The nominated service villages are communities and not mere repositories for housing and accommodation for additional visitor numbers. It is entirely proper to expect Brockenhurst, Lyndhurst, Sway and Ashurst to accept affordable accommodation, sympathetically designed and appropriately sited, in order to house people who have a local connection and would otherwise have no possibility of living anywhere near where they had been born and brought up.
It is quite unacceptable, however, to expect those villages to satisfy a wider need for affordable housing and to become increasingly suburbanised. In our estimate there is a significant possibility that the four villages may lose their essential character and sense of community. We believe that the policy will also introduce an unhelpful inflexibility and an inability to respond effectively to the proper needs of the non-designated villages.
Zoning
The objective may appear laudable even if some of the language has Orwellian overtones in its determination to see all recreation in the right place at the right time. The proposals, however, conflict with other objectives such as the desire to reduce vehicle movements and increase visitor numbers. We believe that the proposals are probably unworkable. Zone 1 contains most of the heath and woodland whilst zone 3, by far the smallest, is mostly private land with relatively few footpaths and bridleways. The prospect of re-locating activity from zone 1 to zone 3 therefore, seems to us to be quite impracticable.
It is important to note that Zone 3, although more robust than the sensitive Forest core, has its own essential character and ecology which also deserves protection. There is a significant danger of damaging these areas by promoting them as holiday destinations for a 25% increase in visitor numbers by 2015, and providing them with a range of visitor facilities. It is not in the character of the New Forest to become a theme park or activity centre. Such facilities already exist close by for those who wish to avail themselves of them.
Road Closures
The issue of temporary and time-tabled road closures is highly problematic. The NPA probably does not possess the necessary powersand, in any event, there will need to be a proper respect for the legitimate needs of residents to go about their business and not to be inconvenienced.
Horse-keeping
In our estimate, the NPA is seeking a sledgehammer to crack a nut. Surveys reveal that the numbers of horses kept, and the numbers of riders on the Forest, have been constant since 1994. The damage done to the Forest by riders is negligible when measured against the impact of livestock, visitors and other users. We believe that issues relating to tidiness (the now notorious ‘alien buckets’), fencing and visual impact can be addressed by exhortation and persuasion. In addition, powers already exist to address the sub-division and sale of agricultural land into small paddocks.
We believe that it is fanciful to expect that restraints on the keeping of horses will lead to an increase in the land available for back-up grazing.
There are significant problems with the criteria set down for determining whether a horse is kept for leisure or agricultural purposes. The designation of a minimum of two-and-a-half acres per equine is generally regarded as ridiculous, taking no account of the size or nature of the beast or the nature of the land in question. It also raises a serious welfare issue in respect of laminitis; and we have been told of cases where older animals, kept out of kindness and as companions for other horses, will have to be put down because of the unavailability of sufficient land.
The other criteria are equally problematic: even unquestionably agricultural horses will have to have supplemental feeding from time to time; or be sheltered; or for some to be rugged. The law demands that owners have regard to these requirements irrespective of any distinction between agricultural and recreational beasts. We go further: we believe that the distinction between agricultural and leisure use is a wholly artificial one with the sole purpose of gaining control over the use of land. This might be entertained were some great public good to be achieved but, on the contrary, we believe that the NPA is courting enormous anger and opposition in pursuit of an objective which will have the most marginal impact on the conservation of the Forest. It will, however, have a very significant impact indeed on amenity, livelihoods and the Forest economy.
Dogs
Dog owners feel particularly aggrieved at the way they perceive they have been singled out. This perception is reinforced by the fact that, in recent memory, the issues raised by this consultation were thoroughly rehearsed in the face of similar proposals brought forward by the Forestry Commission. Agreement was reached then and the re-opening of all these questions seems to us to be unnecessary, provocative and in bad faith.
Dogs can disturb ground-nesting birds but we do not believe that this is a significant problem in the New Forest. Most ground-nesting species in the Forest have enjoyed breeding success over recent years. Those few species that are exceptions to this trend mirror their lack of progress in other parts of Hampshire and the country, in areas where recreation and dogs are simply not a factor. Their failure to thrive, therefore, can reasonably be attributed to other factors.
We have heard evidence to the effect that the presence of dogs under control (and that is not synonymous with being on a leash) can sanitise an area of predators and so provide a high measure of protection to ground-nesting species that would not otherwise be available. Where disturbance is a particular factor in some wet heaths and mires at sensitive times of the year there may be a case for restricting access, but this should equally apply to anything that disturbs and not just dogs.
We reject the argument that the worrying of livestock by dogs is an issue: absolutely no evidence has been presented to justify such a conclusion.
The prospect of dog-free car parks might offer some small amenity to those families who wish to avoid dogs. This however, will be provided only at the expense of those families who do wish to enjoy the company of their pets in those same locations. We have not received any representations to the effect that there is a need to separate those with and without dogs. We also note that it may be beyond the powers of the NPA to decree that car parks must be dog-free.
Generally, dog-fouling is not an issue with the exception of a few concentrated areas and we believe that other effective measures should be taken to address this which fall well short of banning dogs. The groups which represent dog owners have been active in bringing forward sensible proposals to address this. We believe that the perceived problems arising from dogs in the Forest can be addressed by the NPA and the user groups working together to promote a sensible code without recourse to proscription and heavy-handed measures.
The Root of the Problem
Although we are responding to these Consultation drafts on their own terms, this should not obscure the fundamental problem – a symptom of which is the present level of outrage and uproar. The New Forest has so high a density of people living and working within its boundaries that the whole paraphernalia of a National Park Authority is inappropriate for its management, regulation or conservation.
The NPA also made the greedy, and potentially fatal, mistake of voting (by the narrowest of margins) to take planning powers away from the democratically-elected New Forest District Council, which traditionally exercised them well and which could always be held directly to account if ever it did not. The NPA looks at the New Forest through too narrow a prism – that of conservation alone, with little if any regard for living and working requirements of the very substantial local population.
We shall do our best to make the existing flawed arrangements work, while they last, but this must be without prejudice to our view that the National Park Authority is the wrong body, in the wrong place at the wrong time.
Conclusion
We accept that the New Forest needs to develop strategies to preserve its unique character against a background of growing urbanisation and human population close to its borders. The residents of the New Forest and its habitual users ought to be a powerful ally in developing and implementing this strategy. The divisive nature of the current consultation has had entirely the opposite effect: it has set the majority of users of the Forest against the NPA. We believe, therefore, that the best way forward is to withdraw the current proposals as set out in the drafts and to start again with a more conciliatory, incremental and inclusive approach.
Yours sincerely
Desmond Swayne MP Dr Julian Lewis MP Daniel Hannan MEP |
