Archived decisions
New Forest National Park Plan Consultation
Hampshire County Council's Technical Response to the New Forest National Park Authority
This document sets out technical comments on the New Forest National Park Plan on a chapter by chapter basis. It has been written to accompany the County Council's strategic response to the New Forest National Park Plan. The two documents should therefore be read in conjunction.
HCC has been used throughout the document to refer to Hampshire County Council, and NPA to refer to the New Forest National Park Authority
Purpose of the plan - combining the Management Plan with the LDF Core Strategy and Development Control Policies
The Plan should identify which sections and policies of the Plan will formally constitute the `Core Strategy' or `LDF' for the Park, once adopted.
The combined approach has been at the expense of a more comprehensive and robust land management plan which does not address in sufficient detail:- Historic environment and cultural heritage; Rural land management ;Community engagement/involvement; Community planning; Social inclusion and Landscape Character Assessment
The proposed supporting strategies should contain a robust evidence base that will inform priorities and policies in the Plan.
An economic development strategy should be added to the list of proposed strategies.
Vision
Climate change should be translated into all relevant areas of the Plan.
The second bullet point under "A place where people live and work sustainably and contribute to the care of the Forest..." does not recognise that car ownership is likely to remain the dominant mode of transport in rural areas and that many services and facilities are going through a process of concentration and contraction.
Bullet point one of "A place which looks outwards and is fully recognised and valued as a national asset...." does not recognise the role local decision makers have to play and that they will have competing demands that they will have to consider alongside those of the National Park.
It is not clear whether the vision reflects local people's aspirations and how local communities and stakeholders were involved.
Chapter 1
High value staying tourism should not be seen as detrimental to the special qualities of the New Forest.
The Solent Maritime SAC is designated for coastal habitats.
Cultural identity should be reinforced within this section, including the roles of Forest organisations such as the Verderer's Court.
The socio-economic content of Chapter 1 should be improved to provide a better evidence base to support the economic and social well being duties of the NFPA.
The Plan should state who was involved in developing the `special qualities', and whether they reflect local people's views.
Chapter 2
p22 "Local distinctiveness": highway design and infrastructure must conform to design and safety standards. HCC as the Local Highways Authority will target maintenance expenditure where there is greatest need across the whole network.
Climate change will have much wider impacts than currently recognised in the document.
Chapter 3
There are serious reservations about zoning and the flexibility of the NFPA's approach, particularly in relation to the socio-economic needs of residents in Zones 1 and 2. Applying an overly prescriptive approach to development control to those communities living outside the `service villages' will have serious implications for sustainable development, on community and public services facilities, and on the ability of the New Forest Park area to process waste materials in a sustainable way. An improved socio-economic evidence base is required.
Zoning and settlement hierarchy
Focusing the majority of new development on the largest settlements will have an impact on the roads network. A Transport Assessment of the policy is required so that the existing capacity, operation and safety of the network is not negatively impacted. The funding and delivery of mitigation measures should be outlined.
Concentration of recreational activities at Lepe and Calshot is likely to place additional strain on the A326, as the main access road to the locations
New small scale B&B, guesthouse and self-catering development should be allowable outside the villages where these support existing businesses and local employment.
Relocating facilities from zones 1 and 2 will have an impact on businesses which rely on proximity to those facilities, such as pubs, catering businesses, cycle hire companies etc.
The Sustainability Appraisal Report should be amended as this shows no adverse or uncertain economic impacts of relocating facilities.
The inflexible tone of the language used on pages 28 and 29 negates sentiments in the vision about creating a New Forest "where everyone is welcomed.......".
Strategic policies
p30 "Manage the growing impacts of traffic effectively"
Refer to the County Council's comments in the accompanying strategic response report on this bullet point.
p31 "Ensure the essentially rural character of much of the villages is not lost."
Any reduction of traffic "domination" will need to take a strategic as well as local view.
The restrictions on development will limit opportunities for funding to come forward for highway and transport measures
Chapter 4
Overall comments
An economic and social cost-benefit analysis of the measures proposed in this section is required. This would be in addition to the Sustainability Appraisal and inform this appraisal, which underplays potential social and economic impacts.
p 39. P1 and PP1.1.
Climate change will impact on the special quality of `strong and distinctive local communities' as well as the natural environment. Impacts on the economy and well-being of the local communities within the National Park will need to be considered as people adapt to a changing climate.
p 42. PP1.3
This policy will have implications for HCC coastal interests.
p 42. PP1.4
This policy will not be achievable if there is an inflexible attitude towards waste-related development . Better outcomes for wastes as well as the means by which technical improvements can bring about waste minimisation will come from practical innovation and industrial development.
p43. PP1.5
It is important that all regions in Hampshire make a contribution to delivering improvements in the sustainable use of resources. The policy should state that schemes are determined in terms of visual and "outcome" considerations rather than based primarily on size.
p 46. PP2.2
These enhancements are dependent on financial and staff resources being available.
p 47 PP2.3
HCC has a statutory duty under the Highways Act 1980 to maintain the highway network. All highway works within the New Forest are subject to discussion and agreement with the statutory bodies including Natural England, and a protocol is in place to enable routine operations to be undertaken in an agreed manner.
p48. P3 and p 51 PP3.3
The County Council is proposing a major re-investment programme in street lighting. A decision will be taken shortly by Cabinet. At that point the County Council will decide what the appropriate balance will be.
p 50. PP3.1 and 3.2.
Refer to the County Council's comments on traffic management in the accompanying report on the strategic response.
p 50. PP3.2
The policy for reduction in the number of masts must take account of the communication needs of businesses within the National Park.
Chapter 5
p53 C1
An additional objective should be added to Increase the proportion of local wildlife sites (SINCs) in active management in order to help meet local authority duties set out in National Indicator 197.
P55 CP1.2
Grazing may not always be the most appropriate form of management e.g. where there is a high invertebrate interest.
It will be important to ensure that, in seeking new opportunities for creating semi-natural habitats outside the perambulation, with extensive grazing elsewhere on the enclosed lands, the availability of sufficient back-up grazing land for stock is not compromised.
p58 CP2.1
The third bullet point- "providing the necessary infrastructure close to development itself ( such as green space, community facilities and local services) ". Development of infrastructure will depend on funding being generated through development. Given the restrictive policy approach in this plan this is likely to be modest.
P 58 CP2.2
Designed landscapes on the English Heritage Register, those on the New Forest Local Plan list and other sites of local interest recorded on the Hampshire Register of Historic Parks and Gardens requiring further research and assessment will need to be identified. The Draft Heritage Protection Bill (2008) proposes that a register of heritage assets of special local interest are included within the Historic Environment Record.
p 59. CP2.3
With reference to comments made under PP1.4 and 1.5 this policy must also apply to essential infrastructure such as waste management facilities which contribute to the sustainability of the National Park.
p62. CP3.1 and 3.2
There is a need to ensure that back-up land (which may include SINC meadows) is not overstocked and thus damaged.
P63. CP3.4
The conversion of any back-up grazing land to semi-natural habitat must be subject to an assessment of the needs of stock in that location.
Chapter 6
p.70. UP2.2
Further work is needed to better understand the nature of the groups and undertake some form of prioritisation over which groups should be targeted.
P71. UP2.6
The welcoming culture needs to be better reflected in all National Park documents. Some of the language used in this document does not give the impression that the Park welcomes visitors.
Chapter 7
P77-81. L1
References to young people and to deprivation in the area should appear at a much earlier stage in the Plan
P79 LP1.3 and Ref. p107 DC4
These policies aim to deliver at least 50% affordable housing, `subsidized' by 25% market housing where necessary. In the absence of any allocated exceptions sites in the Plan, and with less of the financial incentives generally associated with market housing, the NPA need to consider the deliverability of this approach.
P80 LP2
The recognition of the need for flexibility is not reflected in the overly prescriptive approach adopted elsewhere in the plan, which will not enable communities to develop in a sustainable way.
P82 LP2.1
This policy is overly restrictive and in conflict with the objectives of Policies LP1.1. and LP1.2. Local Authorities responsible for the delivery of public services such as HCC and other public service providers need to undertake service rationalisations which may result in the expansion or relocation of existing community facilities, or the development of new ones. This may result in disposal of surplus land to provide capital receipts required to fund rationalisations or provide new or improved facilities. The reference to `community facilities' in the Policy should be deleted and a new policy related to `core public service policy' added, such as:.
"Public Services Provision
Development proposals for new or improved public service operational facilities, or other new uses on surplus land which are proposed as part of public services rationalisations, will be permitted provided that:
A. the development is appropriately located within or on the edge of settlements or villages or involves the re-use of rural public services land or buildings which are close to residential areas; and
B. the development will support the improvement or continuation of public services in the locality or elsewhere in the Park and/or County of Hampshire".
P84-85. L3 and p86 LP3.3
Refer to the County Council's comments on traffic management in the accompanying strategic response report .
p87 LP3.4
Public transport operates in a commercial environment and will be provided by bus operators where it is economically viable. The New Forest Tour, which operates during the summer, provides an alternative and more sustainable transport choice and should be considered for inclusion in this priority.
Chapter 8
p89-91 - working together
The information on partnership working and community involvement which is vital to the successful delivery of the Plan is `buried' within the Plan. These sections need greater prominence. A significant increase in the level of community consultation is required.
pp93-96 - actions for living and working in the National Park
PA7 All highway works within the New Forest are subject to discussion and agreement with the statutory bodies including Natural England. An agreed protocol is in place to enable routine operations to be undertaken in an agreed manner.
PA9 Include within this action historic parks and gardens of national and local importance.
pp97-100 Indicators and targets
Many of the indicators and targets are not fully measurable without significant resources and research. It is not clear what `partners' are expected to do in terms of monitoring and delivery.
Chapter 9
There are no policies for development of tourist accommodation or industrial use.
p. 105. DC2 - General Development Criteria
This policy should also reflect the need to be appropriate and sympathetic to the capacity, operation and safety of the highway network and the bullet point "Increases in traffic or pollution (including light and noise)" should then be deleted
Incorporate a policy identifying circumstances where a Transport Assessment would be required in conjunction with new development.
P107. DC4
Provision should be made for specialist or supported housing in response to the increasing numbers in the older persons population.
p113 DC8 extensions to all non residential buildings and uses
Policy DC8 is too restrictive. The Policy does not provide sufficient scope or flexibility in meeting the future needs of the local community
p125 DC20 infrastructure
The definition of infrastructure within the supporting text is too narrow, being restricted to recreational facilities and highways. The text should include community facilities and green infrastructure. There is an over-reliance within this Plan on very limited developer contributions to deliver all of the infrastructure needed as well as high sustainability standards
The final paragraph on page 125 should include reference to Section 278 of the Highways Act
Ommissions from the plan
HCC would have expected to see development control policies that include the following:
· Development that is located such that it minimises the need for travel and reduces car dependency.
· Permeability of development for all sectors of the community and all modes of transport.
· A requirement for Design and Access Statements to accompany planning applications that demonstrate the retention of existing access and how the post development environment will be inclusive.
· A requirement for developments to provide appropriate access from the highway network that does not compromise the capacity, operation and safety of the highway network or public and community transport and cycling and pedestrian infrastructure.
· The promotion of sustainable travel modes.
· Cycle parking.
· A requirement for a Transport Assessment / Statement (although suggested above that is incorporated into Policy DC2).
· A requirement for a Travel Plan.
· Improved protection for the historic environment, including the protection of historic parks and gardens and/or their setting.
The Hythe-Marchwood Strategic Gap
The Plan does not designate land between Marchwood and Hythe as a strategic or local gap. Saved policies of the Hampshire County Structure Plan 1996-2011 policy G2 identifies a strategic gap between Marchwood and Hythe.
Annex 5 and 6:
The Sustainability Appraisal (SA ) is not considered comprehensive enough and needs to be revisited. Of particular concern is the need for assessment of the potential impact of policies and objectives on the local community, economy and transport. There are no mitigation measures put forward where they are most needed. The SA states that there are no economic, transport or tourism impacts of relocation, which is strongly disputed.
.