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The NFEA, which is a membership organisation, has represented the interests of horse riders in the New Forest since 1993 when the Forestry Commission proposed licensing horse riding on The Forest. The NFEA is a member of the New Forest Access Forum, New Forest Consultative Panel, the Quiet Recreation Forum, and participates in numerous ad hoc stakeholder meetings. The committee is comprised of people who have experience of horse ownership, have traditional Forest values, and an interest in what is happening in the Forest. The NFEA also has the benefit of past and present committee members who have a professional legal background and advice and assistance is therefore currently available to deal with matters such as this ill-founded approach by the National Park Authority.

A Introduction and Summary

The NFEA has restricted its feedback on the Draft Plan and Strategy to horse related issues and in particular, this document should be read as a response to Question 22 relating to Chapter 9 of the Draft Plan.

The NFEA notes that the Authority recognises:

• The benefits to individuals and society alike of riding as a quiet outdoor recreation.

• That horse riding has a long history within the New Forest and is part of the New Forest cultural heritage.

• That horse riders have rights of access established by law across all the open Forest.

• Making road space available and safer crossing points for riders would contribute to enhancing the quality of the experience of horse riders in the Forest.

• That horse riding and ownership make a significant financial contribution to the local economy and livelihood and to farm diversification income, estimated at £15 million p.a. and should thus be regarded as an important component of the “working Forest”.

The NFEA believes that:

• The policies proposed, particularly those relating to the planning framework do not reflect those positive aspects of horse riding and ownership listed above and are specifically designed to resist horse keeping and limit horse riding and are more unnecessarily onerous than the current Local Plan requirements.

Specifically, therefore, the NFEA objects to Objective HR2 and policies DC12, 13 and 14 on the basis of:

• The wholly inadequate basis of evidence to underpin what are otherwise merely assertions and personal alleged opinions used to justify the policies. This contravenes Guidance for National Park Management Plans issued by the Countryside Agency in 2005, which states that ‘Their objectives and policies should be based on clear evidence’ and ‘Unsubstantiated assumptions and assertions should be avoided’.

• The criteria proposed to define horse keeping would apply to a very much larger proportion than hitherto of existing horse ownership in the New Forest.

• The process proposed to apply for planning permission will be difficult and expensive for applicants to follow and give enormous scope for eventual rejection and increase cost for subsequent appeal.

• Given the scope for retrospective effect and the stated intention of “resisting recreational horse keeping”(page 117 of the Draft Plan) and “limiting the proliferation of any further equine buildings”(page 119 of the Draft Plan), a high proportion of horse owners are deeply concerned that they will be faced with serious horse welfare issues. It is impossible to reconcile these legitimate concerns with the National Park Management Plan Guidance which ‘ Underlines the importance of securing commitment through partnership to the implementation of relevant policies’.

• Reassurances have been offered with regard to a selective approach to be taken by the Authority in pursuing retrospective planning applications. For these assurances to be reliably effective requires them to be enshrined in detail in the documents and processes put in place.

• In the Sustainability Report, the impact of Policy DC12 is rated as zero with regard to the economy, the rural economy and heritage/culture, none of which can be true if the Policy were to be implemented.

Specifically therefore the NFEA seeks: -

• A presumption that recognises the beneficial impact to the local economy of recreational horse riding.

• A presumption that planning permission, if required for field shelters, stables, manèges, should be granted in accordance with policies NF-R7 and NF-R8 of the New Forest District Council Local Plan.

• A planning framework related to horse keeping and equine related developments, which has the presumption of permission being granted, so long as some practical conditions relevant to recreational horse keeping are met.

• A planning application process, which the average horse owner could reasonably be expected to be able to complete without additional specialist help.

• An enforcement approach that emphasises working with the horse-owning population using advice, spread of best practice and incentive, rather than a rigid planning framework, which is punitive and confrontational. In the few extreme cases where this approach is not successful there are adequate powers under other legislation without the need for the activities of the vast majority of horse owners being put in jeopardy.

B The Basis for the Proposed Policies

1 Horse Numbers
Despite its importance as the only definitive study of recreational horse keeping in the Forest, there is no reference in the Key Documents list in the draft plan or indeed to the findings of the 1994 report to the New Forest Committee on “Recreational Use of Horses in the New Forest Heritage Area” by the Royal Agricultural College, Cirencester and a respected Verderer, nor of the 2007 update commissioned by the NPA, and carried out by the same field officer as the 1994 survey. The survey carried out by England Marketing as part of the European funded PROGRESS initiative, and that carried out by the NFEA in 2007 consulting local veterinary practices gave almost identical figures. These reports collectively show quite clearly that recreational horse numbers have not increased during that period and data from the licences granted by the NFDC to Commercial Riding Establishments show that horse numbers in such establishments have declined significantly. Given the greater number of hours that commercially owned horses spent on the Forest per week, this means that overall horse riding pressure on the Forest has declined. For table see Appendix

2 Erosion
Against the background of reducing riding pressure on the Forest has to be set the increases in depastured stock, visitor numbers, cyclists and the heavier modern equipment used by the Forestry Commission’s contractors in felling and hauling out timber. All of these activities have an impact on the vegetation and the scope for surface water run off as a cause of erosion. No objective evidence with regard to erosion is offered to justify the specific restrictions on horse keepers being proposed. See Appendix for details.

3 Back up Grazing
The 1994 study referred to above says that; “a Commoner with a large number of animals who wants land on an annual basis can usually find it. Commoners with only a few animals on the other hand, typically do not have enough land to make hay so they buy it in and neither are they able to afford to rent back up land which they may not in any case need”. The 2007 update concluded that there was little evidence to show that more land was going out of Commoning into horse keeping. The 2000 Natural England Countryside Agency report on the NF Park Boundaries said that back up grazing is “a difficult topic, not least because there is no hard and fast definition of the amount of back up grazing land needed to support the New Forest’s land management, or where it is”

We are not aware of any objective study dealing with back up grazing, its definition, quantity, location, ownership, economics and link to commoning, which would support restricting recreational horse keeping. This is despite the New Forest Commoning Review of 2007 that recommended further research in order to identify the amount, use, and nature of back up land.

4 Biodiversity and Nature Conservation
We are not aware of any study basis for supporting the idea that horse keeping is either beneficial or harmful in its effects on wildlife, nor that horse riding has ever been cited as a significant cause of disturbance to ground nesting birds when set against the impact of other recreational activities and predation.

1) Criteria for “horse keeping” (Policy DC12)

i) “stocking density of less than one hectare per horse”
We understand that 1 hectare is the area, which theoretically could support under average conditions a 500 kg horse living entirely from the pasture and preserved pasture. In reality stocking density is only one variable amongst many such as breed, size, age, health and work level of the horse together with soil type, pasture quality, land management regime, and climate. And it would require sub-division to avoid metabolic disorders (especially laminitis) and ensure adequate pasture management.
We also note that the NFDC Local Plan First Alteration, August 2005 included the statement: “As a guideline, the keeping of horses occurs when there is less than 0.3ha (0.75 acres) of land per horse.”

ii) ‘shelters, supplementary feeding and rugged throughout the winter’
These are normal components of the appropriate management of horse welfare. And we note that the NFDC Local Plan states that “the need for field shelters and stables for horses is recognised and therefore they will normally be permitted provided they are sensitively designed and can be accommodated without being obtrusive in the landscape.”

iii) ‘Corrals’
These are provided as a matter of sound safety management for tacking up, veterinary and farrier attentions, for the avoidance of horses straying onto the road and to lessen the risk of disease transmission between the enclosed and depastured stock. The farriers’ charter requires that a safe area, level, well drained and away from other animals is available when a horse is attended.

2 Planning Application (Policy DC12)

• The detail required is such that in the absence of practical guidelines the average horse owner will find it impossible to complete, without the need for expensive, independent specialist input.
• The significance of the information sought regarding “Availability of off road riding in the area (other than on the open Forest)” is not clear and appears to conflict with the legal right of horse riders to access across all the open Forest and with the Authorities intention to limit the construction of manèges within the National Park.
• Given the stated intention of “resisting recreational horse keeping” the scope of the unnecessary and irrelevant information sought for planning applications and the conditions under which horse keeping will be permitted, the presumption must be that permission would rarely if ever be granted – this wholly wrong.

3 Stables and Manèges (Policy DC14)

• We note that Policy NF-R7 of the NFDC Local Plan states “However, the need for field shelters and stables for horses is recognised, and therefore they will normally be permitted providing they are sensitively designed and can be accommodated without being obtrusive in the landscape.”
• The policy proposed is much more restrictive in only allowing stables in residential curtilage or immediately adjoining a residential curtilage. The restrictions proposed on the design of field shelters would render them ineffective as an aid to horse welfare.
• Manèges offer valuable off road and off Forest riding opportunities. The evidence is that where these facilities are available, riders will often choose to use them as an alternative to riding out on the Forest. Rather than limiting the provision of such facilities, the policy should encourage their construction where access by multiple users will be possible, thus linking with Policy HR 2.2.

4 Conclusion

1) The NFEA strongly believes that no evidence has been presented to justify the disproportionately onerous and restrictive proposed planning framework for equine related development.

2) The NFEA seeks a planning framework in which the presumption is that permission, including retrospectively will normally be granted provided reasonable, practical conditions are met.

3) The NFEA seeks a planning application process, which can be completed by the average horse keeper without resort to expensive specialist advice.

4) The NFEA acknowledges that there is a small minority of horse keeping cases where management standards need to be improved and in such cases, recommends a course of action through advice, spread of best practice and incentive.

5) The NFEA as a key stakeholder is willing to work with other organisations to advise the NPA on relevant land management guidance.

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APPENDIX

1 Horse Numbers

Data on horse numbers over time is available from:

• “Recreational Use of Horses in the New Forest Heritage Area”, Report to the New Forest Committee 1994, by G Cox, University of Bath, J Hallett and C Short, Royal Agricultural College, Cirencester and P Thorne.

• “Recreational Use of Horses in the New Forest Heritage Area”, Update of Field Survey (2007) Summary Report by P Thorne.

• Licences granted by the NFDC to Commercial Riding Establishments.

The 1994 report showed that there were 3,600 recreational horses in the New Forest Heritage Area, of which approximately 3,000 were in work at any one time.

1 Retired horses, breeding mares and foals, young stock
2 Non-recreational horses were part of a commercial enterprise such as a stud, or were Commoners’ ponies not then depastured.

The 2007 update used one of the methods from the 1994 report (survey of local farriers) to estimate the total number of shod horses at 3,537 compared with 3,500 in 1994.

NFDC Licences for Riding Establishments show the following trend:-

2 Land Use

The 1994 study estimated that 1,800 hectares were used for grazing recreational horses and a further 1,100 hectares was used for grass conservation (hay etc), not all of which was necessarily within the Heritage Area boundary.

Fields containing horses were frequently small, often less than one hectare. The condition of 88% of fields was rated fair or good.

The 2007 survey showed that for the land area surveyed there had been an 18% reduction in area occupied by horses, since 1994. The researcher found little evidence to suggest that more land was going out of commoning into horse keeping.

The 2007 update also showed a significant reduction in the number of fields with jumps and the researcher rated the visual impact of horse-keeping as fair, good and very good in 88% of the fields.

3 Erosion

It is clear that all uses of the Forest, whether for recreation, commoning or Forestry Commission operations have the potential to contribute to damaging vegetation and eventually to erosion by running water. The influences affecting the impact are complex, involving weight, speed, rate of change of direction, area in contact, type and condition of soil and gradient. Surveys of the extent of erosion in the Forest cannot in most cases identify the original cause, the exception being the obvious tracks caused by vehicles. (See photographs for examples).

In the past it was frequently suggested without any supporting evidence, that horse riding was the major cause of erosion yet as long ago as 1995 the Forestry Commission, after a series of the discussions with the NFEA, acknowledged that horse riding was not a major source of erosion. More recently at the workshop for Parish Councils and the Access Forum held at Brockenhurst on 9 October 2008, it was acknowledged by the Forestry Commission that erosion has multiple causes.

Of the 3,500 horses in the Forest, some 2,800 are ridden on average for 2 hours at a time, three times per week.

Also on the Forest are:-

• Between 6,000 and 7,400 ponies, cattle, pigs and sheep – up from 5,190 in 1987. (It should be noted that many of the cattle are much heavier breeds than the Galloways and Dexters of twenty years ago). Most ponies and cattle are on the Forest all the time.

• 13,000,000 visitors per year – up from 8,000,000 in 1994 and anticipated to increase by a further 1,600,000 in the future.

• Unquantified numbers of cyclists.

• Heavy Forestry Commission contractors’ vehicles hauling out timber from time to time.

• Substantial quantities of surface water – a major cause of erosion as is shown by erosion in areas and slopes where horses cannot be ridden. Other national parks have identified surface water as a significant cause of erosion.

The unshod hooves of ponies and cattle and the wheels of bicycles sink just as deeply into soft or waterlogged earth as do the hooves of shod horses and other national parks such as Snowdonia have found that walkers often cause significant erosion