AM 740/26 – Annex 3 – Regulation 18(2) Consultation Statement
Summary
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Consultation statement summarising feedback and the National Park Authority’s responses on the New Forest National Park Local Plan Review Regulation 18 Part 2 consultation (Nov–Dec 2025). It reports over 1,110 responses and explains consultation methods. The document reviews comments policy-by-policy across themes including spatial strategy, housing need and allocations, affordable housing and local connection rules, climate change, water resources, flood risk, biodiversity net gain, protection of designated habitats, landscape character, green and blue infrastructure, tranquillity and dark skies, heritage, tourism, employment land, and transport. Key disputes include proposed new “Defined Villages” and housing sites (notably Landford/Nomansland, Ashurst, Winsor, Redlynch), impacts on infrastructure, flooding, sewerage, traffic, and protected habitats. The Authority notes amendments made for the Regulation 19 draft, while defending modest growth focused on local needs and national park purposes.
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AM 740/26 – Annex 3
Appendix 1 of Regulation 18(2) Consultation Statement (July 2026)
Summary of main issues raised made pursuant to Regulation 18 (Part 2) – Reponses to the NFNPA Local Plan Review
Introduction
The tables below provide a summary of the responses received from the groups and organisations submitted to the National Park Authority during the Regulation 18 Part 2 consultation period (November – December 2025). Each table is divided into policies from the draft Local Plan. A response from the Authority is provided to each summarised comment. Responses from individual members of the public have been summarised for clarity into one response under ‘Individuals’.
It should be noted that statutory bodies who were consulted, in most cases, did not respond to every policy within the draft Local Plan. Responses to this consultation were greater than that of the Regulation 18 Part 1 consultation, with 1,110+ responses received in comparison to 81.
The higher response rate for this latest consultation can be attributed to several factors, but particularly the introduction of a full draft version of the Local Plan, which included draft policies and proposed site allocations. The consultation statement from the Part 1 Regulation 18 consultation can be found here: Local Plan review 2025-27 - New Forest National Park. Both statements should be read in conjunction to assess how the Local Plan has proactively responded to the views of the local community and others with interests in the New Forest National Park.
Consultation publicity and format of the Local Plan
Many of the representations referred to the format of the draft Local Plan and publicity of the consultation. A summary of the main issues raised is set out below.
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Individuals |
Consider the plan to be cumbersome, the terminology and abbreviations a challenge to comprehension, and the response method difficult to navigate and respond to the correct sections.
Suggest that publicity has been poor in Landford and Nomansland and that insufficient notice of the consultation was provided. Queries why the consultation was not advertised locally. |
Comments noted. The New Forest National Park Local Plan Review is comparatively succinct compared to many development plans. The Commonplace platform has broken it down into individual chapters for ease of navigation.
The Regulation 18 (Part 2) consultation was undertaken over a six-week period between 5 November and 19 December 2025. The consultation was widely publicised ahead of its start date, and Parish Councils were notified, both within the Park and adjoining its boundaries. Posters advertising the consultation were sent to Parish Councils and the NFNPA engaged proactively with the Councils, including holding a briefing session with Landford Parish Council in September 2025. Consultation documents were made accessible online, with hard copies available for inspection at Lymington Town Hall. The Authority subsequently held 5-hour public drop-in sessions in 5 locations – including Landford – during the consultation period to enable people to find out more about the draft Local Plan. Consequently, the publicity and consultation undertaken by the NPA exceeds the statutory requirements and aligns with our adopted Statement of Community Involvement (2023). |
Chapter 1 – Introduction and Background
There were a total of 26 representations relating to this chapter. A summary of the main issues raised is set out below.
| Respondent | Summary of representation | NPA response |
|---|---|---|
| RSPB | Pleased to see the two primary purposes for the NPA highlighted and the duty to co-operate clearly articulated. | Comments noted and support welcomed. The adopted New Forest National Park Local Plan sets out the statutory National Park purposes and related socio-economic duty, and similar wording has been retained in the revised Plan. |
| New Forest Cycle Working Group | Requests that transport issues relating to strategic cross-boundary planning be included within the supporting text. | The transport policies in the draft Local Plan have been informed by the relevant Local Transport Plans prepared by Hampshire County Council and Wiltshire Council, as well as other transport-related documents. Paragraph 1.20 has been updated to reflect this. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Supports inclusion of the two statutory purposes for the NPA, the national strategic context for National Parks, and links to other plans and strategies. | The draft Local Plan highlights the Authority's socio-economic duty, and several sections of the draft Local Plan specifically seek to deliver the duty in the context of the statutory National Park purposes. |
| Individuals | From the few representations received for this section, broad support was shown for setting out the NPA’s two statutory purposes. The commencement of the Local Plan period was queried. |
Broad support welcomed and it is agreed that the Authority must put the two statutory purposes of the National Park first and this informs the overall quantum and distribution for development in the draft Plan. Small-scale development is supported in all National Parks to ensure local needs can be met where possible. This helps to sustain local communities and services.
The Local Plan period starts at the date the NPA commenced the review - this was 2024 (5 years after the date of adoption of the current Local Plan). Local Plans are required to look forward at least 15 years from the date of adoption, and this is why the Local Plan end date is 2043. |
Chapter 2 – Profile of the New Forest
There were a total of 22 representations relating to this chapter. A summary of the main issues raised is set out below.
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Brockenhurst Parish Council | Requests the chapter to make reference to commoners and commoning. | Further wording has been added into the supporting text to make specific reference to New Forest commoners. There are several references to commoners and commoning throughout the draft Plan and additional wording in Chapter 2 helps to set the scene. |
| Woodford Green Parish Council | States that the summary is good. | Support welcomed. |
| New Forest Association | To align with the definition of the purposes and duty of a national park, requests deletion of the word ‘important’ from the paragraph setting these out. | The word 'important' has been deleted in paragraph 2.13 of the draft Plan in accordance with this representation. |
| New Forest Cycle Working Group | Requests reference be made to active transport as an existing means of transport, and the negative effects that major roads have on active transport. | The transport policies in the draft Local Plan have been informed by the relevant Local Transport Plans prepared by Hampshire County Council and Wiltshire Council, as well as other transport-related documents. Further wording has been added to the paragraph on transport issues. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) |
Welcomes recognition of the important role played by traditional rural land-based activities in maintaining the landscape character of the National Park and supporting local employment. Notes that the projected decline in the working-age population is a significant concern, despite current low unemployment rates and considers that the NFNPA should use the new development plan to help retain and attract young people, both for traditional land-based activities and for other sectors of the local economy. Suggests that this should include ensuring that affordable homes are available for those working locally, particularly younger people, and enabling rural businesses to diversify where appropriate so that they can remain sustainable over the longer term.
Supports the draft plan’s acknowledgement of the NFNPA’s duty to foster the socio-economic wellbeing of National Park communities. Advises that given the environmental, landscape, ecological and heritage constraints within the Park, it is particularly important that opportunities for employment development are used effectively and that limited previously developed land is put to its best use. Proposes that the economic opportunities associated with the Solent Freeport designation should be reflected more clearly. Notes that while the designation is primarily related to major port expansion, some limited areas of land within the NFNPA plan area fall within the Freeport tax and customs area, creating potential economic and transport-related opportunities that should be recognised consistently across the plan. |
The draft Local Plan includes policies that support traditional rural-based activities such as farming, forestry, commoning, and the role of the Estates. The supporting text has been updated to refer to the parts of the designated Solent Freeport that lie within the New Forest National Park. |
| Laister Planning on behalf of Paultons Park | Suggests that the effects of the draft policies, in combination with the objective of conserving the National Park’s special qualities, risks creating an overly restrictive policy framework that discourages sustainable investment in major visitor attractions, which is contrary to national policy objectives. Proposes that the Plan is amended to address this. | Comments noted. It should be highlighted that the planning policy approach in the National Park must be consistent with both national planning policy set out in paragraphs 189 - 190 of the NPPF (2024) and also the primary legislation established for National Parks through the National Parks & Access to the Countryside Act 1949. National planning policy is clear that National Parks are not appropriate locations for major development other than in exceptional circumstances. The NPA has a duty to support the socio-economic well-being of local communities within the National Park linked to the delivery of the two statutory National Park purposes. Policy SP62 (Sustainable tourism development) has been amended to include criteria for considering proposals relating to major visitor attractions. |
| Individuals |
Recognition of the impact of increased visitor numbers has on forest landscapes and communities requested. The New Forest’s ecological systems are under pressure from dog walking; banning dogs from the Open Forest proposed. Road deaths of animals increase as more vehicles traverse the Park.
Reference to different ethnic and cultural groups represented within the Forest proposed. Reference to active travel as an existing means of transport and the negative effects of major roads on this should be included within the supporting text. Opposition to further development within the Forest. More social housing for rent is required to support commoning and low-income residents. The impact of high land and property values on practising commoning noted. Suggested that the Waterside area should be incorporated into the National Park. |
The role of the Local Plan review in addressing increased visitor pressures has been set out in updated text. Planning permission has bene granted in several locations for off-designation dog walking/training areas. It is not within the remit of the NPA or the Local Plan to ban dog exercise on the Open Forest, as no planning permission is required. Through Operation Mountie and other initiatives, the proportion of commoners' stock killed through road traffic accidents is at a historic low and work will continue on this.
The transport policies in the draft Local Plan have been informed by the relevant Local Transport Plans prepared by Hampshire County Council and Wiltshire Council, as well as other transport-related documents. Further wording has been added to paragraph 2.14 on transport issues. The scale of new development within the National Park is limited, but it is also home to 34,500 people and 2,500 local businesses that have needs. The draft Local Plan includes draft planning policies that would deliver social rented housing and would contribute towards the needs identified in the response. The draft Local Plan seeks to address high house prices by (a) limited the size and scale of replacement dwellings and residential extensions; and (b) a suite of policies that aim to deliver housing for commoners, Estate workers, agricultural & forestry workers and local people with a connection to the New Forest in housing needs; and (c) limiting the size of net new dwellings to ensure new provision meets identified needs for smaller properties. The draft Plan specifically supports commoners' dwellings through a bespoke policy. The boundary of the New Forest National Park is established by the Government, and it is not within the NPA's remit to change the boundary. A review of the National Park boundary is not timetabled and is a separate process from the current Local Government Reforms review process taking place in Hampshire and the Solent. |
Chapter 3 – Vision and Objectives
There were a total of 22 representations relating to this chapter. A summary of the main issues raised is set out below.
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Natural England | Supports the draft Local Plan’s Vision and development particularly the commitment to delivering wider environmental net gains and restoring nature’s capacity to deliver ecosystem services through nature recovery. Welcome the integration of climate change considerations, landscape, and the National Park’s special qualities throughout the Plan’s policies. | Overall support for the Vision and strategic objectives welcomed and comments noted. |
| Historic England | Supports the objectives but notes that the National Park’s special qualities are intrinsically linked with the Park’s cultural heritage and that the Objective 2 reflects the NPA’s second statutory purpose. | Support welcomed. It is agreed that the second objective also relates to the second statutory Park purpose, and the text has been updated to reflect this. |
| Woodgreen Parish Council | Expresses concerns that further development will increase pressures on existing infrastructure. | Comments noted, but it is not a tenable position for there to be no development within the National Park, and the housing crisis means there will continue to be growth in the areas surrounding the Park. The NPA engages with neighbouring planning authorities on cross-boundary impacts and seeks to manage these as appropriate. |
| New Forest Association | Suggests that the Vision should begin with setting out the strategic context of the National Park and proposes amendments to the key challenges likely to affect the Park over the next 15 years. | The first of the key challenges set out in paragraph 3.4 has been reworded to be more of an explicit challenge, and the final challenge has been rewritten along the lines suggested by the NFA. |
| Verderers of the New Forest | Welcomes that the New Forest Partnership Plan 2022-2027 is acknowledged as playing a central role in delivering a shared Vision for the New Forest. The Vision for the Local Plan is supported and reference to traditional land management practices, particularly commoning, is welcomed. | Support for the draft Vision and strategic objectives welcomed. |
| CPRE Hampshire | Welcomes the introduction of the strategic objectives but proposes that the draft Local Plan’s objectives should seek to improve affordability of homes. | Support for the strategic objectives welcomed. Clearer reference has been made to affordability within the strategic objectives; this includes, but is not limited to, affordable housing for local people. |
| New Forest Cycle Working Group | Supports strategic objective 9 and notes that increased use of active travel could contribute to other objectives. | Support for the wording of draft Strategic Objective 9 welcomed. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Supports the Vision and objectives of the draft Local Plan, specifically the recognition of the contribution of traditional land-based activities to the National Park and rural exception sites and estate workers housing. Proposes that the Vision should be more ambitious in addressing the impacts of climate change and redevelopment of brownfield sites for renewables and other supporting energy-related infrastructure. | Support welcomed. There is some merit in the representations made by the Cadland Estate relating to the wording of the Vision and renewable energy and the text has been amended to reflect this. The draft Local Plan support appropriate small-scale renewable energy, and this is now referenced. Deciding on what development is appropriate is more nuanced than whether a site is brownfield. |
| Carter Jonas on behalf of Fawley Waterside Ltd | Supports the Vision but considers that opportunities to maximise appropriate and sensitive development beyond the National Park’s boundaries should be given priority over development within the Park. | Support for the Vision welcomed. The point raised by Fawley Waterside is noted and understood. However, as the NPA is preparing the statutory development plan for the National Park area and has no direct planning remit beyond the Park boundary, there is limited scope for our Local Plan to make specific reference to areas outside the National Park. |
| Turley on behalf of Pennyfarthing Homes (LAA31 site promoter) | Proposes that stronger emphasis is given in the Vision to the importance of providing sufficient homes – particularly affordable homes – and to focusing on the needs of local people. Suggests that objectives 3 and 9 should set out that growth should be redirected to sustainable locations that reduce the need to travel. | The wording in the draft Vision relating to meeting the needs of local communities within the National Park is taken from the National Park Circular - which remains extant - and reflects the NPA's socio-economic duty towards local communities within the National Park. The third paragraph of the draft Vision talks about meeting local housing needs. The wording of draft objectives 3 and 9 is considered reasonable and has now been updated. |
| Individuals | Support for the strategic objectives and strong support for the vision, in particular reference to the climate emergency, inclusion, and people living and working sustainably. Changes proposed to the Vision relating to the management of recreation and visitor pressures. Rewording of the climate change objective suggested. Commitment to support minority communities within the New Forest requested. Park and ride facilities proposed. Queried how the Plan period between 2024 and 2026 is considered. Increased traffic from development outside of the National Park resulting in accidents involving Commoners’ livestock observed. Opposition to further development within the National Park and queries why it is considered to be in the public interest. Development considered to conflict with the statutory purposes of the National Park. |
Support for the strategic objectives and strong support for the Vision welcomed. The suggested rewording around the Vision relating to the management of recreation and visitor pressures is reasonable, as is the suggested rewording of the objective relating to Climate Change is also considered reasonable and as such, these sections have been amended. It is unclear how support for minority communities would feed into the local planning policies for the National Park. The transport policies in the draft Local Plan have been informed by the Hampshire Local Transport Plan and other local initiatives. There are currently no plans for park and ride in the New Forest area. The planned charging for New Forest car parks is a matter for Forestry England rather than the National Park Authority.
The Local Plan period starts at the date the NPA commenced the review - this was 2024 (5 years after the date of adoption of the current Local Plan). Local Plans are required to look forward at least 15 years from the date of adoption, and this is why the Local Plan end date is 2043. The NPA is not the planning authority for the areas outside the National Park and so cannot feasibly include policy coverage of these issues through our Local Plan. The NPA's wider work includes engagement with partners on animal accidents, with the proportion of stock killed in recent years at a historic low. Development is not, and never has been, precluded in National Parks. National policy supports small-scale development to meet local needs, including proposed housing allocations with affordable homes reserved for local people in need. New housing in an area of need is a community benefit, supporting local services at risk of closure, such as schools, and enabling further benefits including public greenspace and safer school drop-off areas. |
Chapter 4 – Strategic Policies and Development Principles
There were a total of 120 representations relating to this chapter. A summary of the main issues raised is set out below.
Policy SP1 – Supporting sustainable development
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Natural England | Supports Policy SP1 and welcomes its strong emphasis on sustainable development, that conservation and enhancement of the National Park will be afforded greater weight in decision-making. | Support welcomed and comments noted. |
| Historic England | Suggests that reference could be made to culture and heritage capital | The first sentence of the policy wording has been amended to include culture and heritage capital. |
| Hampshire County Council | Proposes that reference is made to ‘improved public transport and active travel links’ within the policy. Suggests that a list of the services that ecosystems provide should be included within the supporting text. | Criterion a) has been expanded to reference active travel links. However, it is not considered necessary to set out a description of ecosystem services as this is provided within the glossary. |
| Dorset County Council |
Supports deviation from the standard method in defining local housing needs and offers strong support for the definition of sustainable development in criterion a).
Suggests that the proposed supply of 50 homes per annum may not be a true reflection of the ability of the Park to sustainably deliver new homes and that an assessment should be undertaken of the locations around the Park’s fringe, adjacent to existing urban areas, to inform a full understanding of the unmet housing need in the National Park. |
Support for deviation from the standard method and strong support for the definition of sustainable development welcomed, and comments noted.
The Sustainability Appraisal evaluated spatial strategy options for delivering housing within the National Park. This included consideration of locations on the edge of the National Park, adjacent to established urban areas. Option F considered development on the National Park’s periphery, immediately adjoining settlements outside the boundary. While existing infrastructure in these areas could help mitigate potential impacts and avoid the most sensitive parts of the Park, the assessment concluded that concentrating development in these fringe locations would restrict the distribution of socio-economic benefits across the wider National Park communities, particularly within its key ‘core’ areas. Options E and G examined a combination of peripheral development with growth in new or existing settlements within the National Park. However, these options were also discounted for the reasons set out in the Sustainability Appraisal. |
| New Forest District Council | Notes the NFNPA’s identification of an objectively assessed housing need target and acknowledges that continued engagement between the NFNPA and the New Forest District Council will be required to address the unmet housing need. | Comments noted. |
| Copythorne Parish Council | Supports reference to improved public transport links and climate change resilience. Queries whether the transport strategy is sufficiently robust. | Support welcomed. The NFNPA has consulted, and will continue to engage with, the relevant Highways Authorities to ensure that transport matters are addressed in line with the Wiltshire and Hampshire Local Transport Plans and the Partnership Plan. Further detail will be set out in the forthcoming New Forest Transport Strategy. |
| Landford Parish Council | Notes that sustainable development is important to prevent character villages and established communities from becoming overwhelmed by development. | Comments noted. |
| Redlynch Parish Council | Notes spelling mistakes, suggest that the Parish’s settlements are listed, and that it is made clear that the village of Redlynch is located within Wiltshire. | The typographical errors in both the policy wording and supporting text for Policy SP1 have been amended. However, it is neither necessary to list the settlements within the Parish, nor to state which authority is has responsibility for infrastructure, etc. The current Duty to Cooperate requirement means that ongoing discussions are being held between relevant neighbouring authorities and the NPA to ensure that any form of proposed development is deliverable over the long term. |
| New Forest Association | Requests that the call for sites process should include – and be biased towards - housing exception sites and sites suitable for back up grazing. | The call for sites process identifies land suitable for development and does not in itself identify land for back up grazing. Rural exception sites cannot be allocated through the Local Plan, though it is recognised that some of the sites submitted may have merit as possible rural exception sites. It is considered that Policy SP55 provides sufficient criteria to assess proposals affecting back up grazing land. |
| New Forest Cycle Working Group | Suggests that reference to active travel links should be made within criterion a). | The policy wording has been amended to refer to active travel links. |
| RSPB | Supports the inclusion of the Sandford Principle in relation to the statutory purposes of the National Park and requests that this is highlighted, along with the duty to co-operate. | Support welcomed. It is agreed that it is important that the duty to co-operate and the Sandford Principle are highlighted within the revised draft Plan and therefore amendments have bene made in the Regulation 19 Submission draft version of the Plan. |
| CPRE Hampshire | Welcomes inclusion of natural capital and recognition of the importance of commoning. Suggests that back up grazing land should be included within the supporting text. | Support welcomed. While the supporting text for Policy SP1 acknowledges the role of commoning, the policy’s focus is specifically on the New Forest’s natural capital. Consequently, references to the availability of back up grazing land are not appropriate within this section. Policy SP55, however, contains provide local planning policy coverage for the protection of back up grazing land. The supporting text to Policy SP55 recognises the increasing pressures on the availability of land for back up grazing. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Broadly supports the policy’s aims but considers the policy approach to renewable, low carbon, and other energy-related infrastructure to be restrictive. | Broad support welcomed and comments noted. The NPA has a statutory duty to promote the socio-economic well-being of communities within the Park, a responsibility that takes precedence over development intended to benefit areas beyond its boundaries. At the same time, the Authority must give priority to conserving landscape character, tranquillity, and existing natural carbon stores such as peatlands and wooded areas. Consequently, the scale and impact of certain low- or zero-carbon technologies and associated infrastructure, including battery storage, may conflict with the Park's primary purposes due to their potential environmental and visual impacts. |
| Gillings Planning on behalf of Trustees of the Barker-Mill Estates (SP33 site promoter) | Welcomes recognition of the role that development has in supporting the objectives of the National Park and its duty to deliver new homes. | Support for policy aims welcomed and comments noted. |
| Vail Williams on behalf of Trant Estates (LAA6 site promoter) | Proposes that the wording for Policy SP1 should specifically direct the reader to the policy on major development. | The Local Plan should be read in the round. It is therefore not considered necessary for Policy SP1 to direct the reader specifically to Policy SP4 (Major Development) or to any other policies relating to particular types or scales of development. Policy SP1 functions as an overarching policy and including a reference to Policy SP4 could imply that SP1 does not apply to other forms or scales of development. |
| Laister Planning on behalf of Paultons Park | Considers that the policy’s definition of sustainable development conflicts with that set out in the NPPF. Requests that the policy refers to sustainable tourism and established visitor attractions. States that the policy places disproportionate emphasis on environmental outcomes and requirements to either deliver a positive impact or to avoid impact are unnecessarily restrictive. | The Authority disagrees with the claim that the policy’s definition of sustainable development conflicts with that set out in the NPPF. The definition set out within draft Policy SP1 reflects the statutory purposes of the National Park and paragraph 11, footnote 7 of the NPPF and provides greater guidance regarding the NFNPA’s expectations for new development. It is not considered necessary to include explicit reference to sustainable tourism or established visitor attractions as these are addressed within policies SP60 and DP61. It is not considered necessary to remove the requirements for development to deliver a ‘positive impact’ on natural capital or to ‘not impact’ protected assets. The policy wording within criterion b) has been reworded to set out that the Park's natural assets should be maintained at the existing level, or enhanced, whichever provides greater gains. |
| Draycott on behalf of landowner | Requests that policies focusing on specific accommodation needs are prepared for: live/work units; key workers; military and Ministry of Defence personnel; staff accommodation; and almhouses. An additional build to rent policy is also requested. | It is not considered necessary to include policies to address the specific accommodation needs set out, or appropriate to include a build to rent policy. The evidence on local housing needs is set out in the New Forest Housing Needs Assessment (Iceni, 2025). Proposals for build to rent properties will be given consideration through the planning application process. |
| Southern Planning on behalf of Haydon Tyres Ltd | Supports the proposed settlement boundary for Cadnam - Bartley but requests that it should be extended to include housing and commercial premises on the north and north-west side of the A31 Romsey Road, reflecting the existing ribbon of development. Proposes that both sides of Romsey Road should be included due to local services and facilities, including restaurants, vehicle services and repairs, car sales and commercial storage. As a gateway into the village from Copythorne, would like the boundary extended to the M27, reflecting the area’s semi-rural, suburban character. | Support welcomed. The proposed boundary for Cadnam - Bartley has been reviewed, and the amendments can be viewed on the interactive Policies Map and in the Proposed Policies Map Changes Regulation 19. |
| Individuals | Broad support for the policy’s aims, particularly for the use of sustainable materials. The term ‘high quality’ is considered unclear and subjective. Some support for expanding the range of Defined Villages. Concerns raised whether work has been undertaken to assess the ability of current infrastructure to cope with more people. | Support welcomed. In planning terms ‘high quality design’ should create functional, sustainable, and locally distinctive buildings and places that enhance wellbeing and add long-term social, economic, and environmental value. Chapter 12 of the NPPF sets out how the planning process should achieve this. The Sustainability Appraisal explored options for distribution of development across the National Park. The approach taken forward is considered the most sustainable option overall. All National Parks accommodate development to meet identified local needs and the New Forest is no different. The New Forest Housing Needs Assessment identifies local housing needs throughout the National Park. There is a significant housing need arising within the National Park and to address this, housing site allocations are being considered. Small-scale development is supported across all National Parks to help meet local needs and sustain communities, services and facilities. Local infrastructure providers and consultees – including Wiltshire and Hampshire County Councils in their respective roles as Lead Local Flood, Education and Highways Authorities – have been consulted throughout the plan-making process. As part of this, the scale of development proposed within the Park has been considered in relation to existing and proposed infrastructure capacity. |
Policy DP2 – General development principles
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Recommends that the general principles also include reference to mitigation and adaptation to climate change, and the incorporation of flood resistance and resilience into building design. | The development principles within the policy wording have now been expanded to reference climate change and flood resistance and resilience. |
| Historic England | Requests that the word ‘natural’ be deleted from the third sentence in relation to ‘natural environment’. | The third sentence of the policy wording relates to natural capital; therefore, it is not considered necessary to omit the word ‘natural’. |
| Southern Water | Would welcome the inclusion of the National Standards for Sustainable Drainage Systems as a required design standard. | Comments noted and reference to the National Standards for Sustainable Drainage Systems has been made within the policy wording. |
| Hampshire County Council | Proposes that development should enhance public health through a holistic approach, and that the Waste Hierarchy principles are set out. | The policy wording and supporting text has been amended to reference the Waste Hierarchy principles, reflect the shift toward a circular economy, and outline how enhanced public health can be achieved. |
| Dorset County Council | Supports the Plan’s focus on small-scale proposals that reflect the area’s character and address the needs of local communities, rather than catering for in-migration. Welcomes the acknowledgement that residents of the Park look towards neighbouring areas to meet their everyday needs and the impact that this has upon those areas. | Support welcomed and comments noted. |
| Copythorne Parish Council | Suggests that the word ‘unacceptable’ is open to interpretation. Queries how adverse impacts associated with traffic and pollution would be addressed in the absence of sustainable travel options. Questions how developments would be measured objectively against subjective aims. | The term ‘unacceptable’ has a specific meaning in planning policy, referring to impacts that result in significant harm to the environment, public health, or local character, as reflected in the NPPF. Criteria (f) and (g) appropriately identify the types of adverse amenity and environmental effects that could be considered unacceptable. Adverse impacts from traffic pollution in areas with limited public transport or active travel infrastructure can be mitigated through a combination of technological solutions and behavioural changes. In parallel, the NPA will work with neighbouring authorities to monitor changes in air quality – including ammonia and acid deposition – across the New Forest's internationally designated sites. Applications will be assessed against the New Forest National Park Design Guide SPD to ensure that they do not cause harm to the character of existing settlements, the surrounding landscape, or the historic environment. |
| Godshill Parish Council | Considers that a site-specific policy should be produced for development at Sandy Balls Holiday Village. | The Authority does not consider that a separate policy for Sandy Balls Holiday Village is required. The policies within the draft Local Plan on heritage, major development, tranquillity and dark skies, holiday parks, and sustainable tourism provide sufficient policy coverage. |
| Sway Parish Council | Supports the references to best practice in energy conservation, reducing the need to travel and enabling active travel. | Support welcomed. |
| New Forest Cycle Working Group | Strongly supports criterion h) and paragraph 4.15. Proposes that reference should be made to cycle standards within criterion i). | Strong support welcomed and the policy wording has been amended refer to cycle standards. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Supports the policy’s aims and the principles of sustainable development, so far as these are practicable and applied reasonably so that they do not render the development of sites unviable. | Support for policy aims welcomed and comments noted. |
| Laister Planning on behalf of Paultons Park | Supports the policy’s aims but considers that it introduces overly rigid and absolute tests. Notes that requiring all development to demonstrate an “overall positive impact” on the ability of the natural environment to contribute goods and services exceeds national policy expectations and risks preventing acceptable development that delivers social and economic benefits. | The Authority disagrees with the claim that the policy introduces overly rigid and absolute tests. The criteria represent common practice considerations for achieving good quality sustainable development. However, the third paragraph of the policy has been reworded to provide clarity and to incorporate socio-economic well-being. |
| Individuals | Broad support for the policy’s aims. Greenbelt should be protected from development. Who determines whether ‘adverse impacts’ are unacceptable queried. Clarification of the terms ‘high quality design’, ‘appropriate’, and ‘sympathetic’ in relation to design standards requested. | Broad support welcomed. While it is incorrect to assume that the New Forest National Park contains greenbelt land, it does contain greenfield sites which the policies in the Local Plan seek to protect. However, New Forest District Council’s planning area is affected by some greenbelt along the south-west boundary and as such, they have set out policies within their Local Plan to address how it is managed within their area of the New Forest. Development management officers assess proposals against planning policy by considering their environmental, traffic, and social impacts. They evaluate all relevant material considerations to determine whether a development would lead to unacceptable adverse effects. Specialists – such as highways authorities, environmental health, and the Environment Agency – are consulted where proposals may affect transport, water quality, flood risk, or land contamination. In planning terms ‘high quality design’ should create functional, sustainable, and locally distinctive buildings and places that enhance wellbeing and add long-term social, economic, and environmental value. Chapter 12 of the NPPF sets out how the planning process should achieve this. ‘Appropriate’ is used to mean development that fits its context in terms of scale, density, and design, while ‘sympathetic’ means that the development should respect, complements, and preserves the character, materials, and appearance of existing buildings or surroundings. When paired together, the aim is to ensure that new development harmonizes with, rather than harms, its site or heritage. |
Policy SP3 – Spatial Strategy
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Wiltshire Council | Supports the approach to addressing housing needs and welcomes that the figure of c.950 additional dwellings over the plan period is considerable deliverable within the context of a nationally protected landscape and will stabilise the National Park’s population and help to support local service provision. | Support for housing need approach welcomed and comments noted. |
| Dorset County Council | Notes that the separation of closely related settlements and the approach of making best use of development sites should be considered. Locating homes and other types of development close to where the need arises reduces commuting and therefore minimises the impact on neighbouring areas. | Comments noted. |
| Test Valley Borough Council | Notes that the proposed scale of windfall development across the Plan period is based on historic trends and suggests exploring whether more recent delivery rates imply that a higher windfall rate may be relied upon. | Comments noted. The windfall data covers a 10-year period up to the end of March 2025, encompassing the COVID-19 pandemic and wider economic fluctuations. This timeframe is considered sufficiently up-to-date and robust to provide a realistic basis for assessing future provision. |
| Copythorne Parish Council | Strongly supports the policy objective of addressing local needs but queries the reason for designating further Defined Villages. Questions whether paragraph 4.19 alludes to transport. | Strong support for addressing local needs welcomed and comments noted. The decision to identify certain settlements as ‘Defined Villages’ reflects their capacity to support sustainable development. These locations offer the broadest range of community facilities, local employment, transport links, and services, making them the most suitable places for accommodating modest future growth in line with national policy. This approach will help sustain and enhance village services, strengthen their contribution to the tourism economy, and support appropriate housing, employment, retail, and community uses, while protecting local character and heritage. As noted within the body of paragraph 4.19, transport links are one of the contributing factors of sustainable settlements and as such, the first bullet point implicitly references that public transport, walking and cycling routes should be sustained and enhanced. However, it should be noted that the NFNPA is not the Highways Authority and that transport is more appropriately addressed in the Partnership Plan and the Hampshire and Wiltshire Local Transport Plans. Consideration will also be given in a future New Forest Transport Strategy. |
| Landford Parish Council | Notes that development must meet local needs. | Comments noted. Proposals for residential or employment development must take account of the housing or employment needs of the local area. The New Forest Housing Needs Assessment identifies that there is a significant housing need arising in the New Forest for 1-, 2- and 3-bedroom properties across all tenures, including affordable housing. The NFNPA seeks to address this need through a suite of policies that aim to deliver housing for commoners, estate workers, agricultural and forestry workers, and local people with an existing connection to the New Forest. The draft Local Plan specifically supports provision of commoners’ dwellings through a bespoke policy. To address the identified housing need within the Park, housing site allocations are being considered, including the site known as 'land to the south of Hamptworth Road'. However, there are insufficient brownfield development sites within the National Park to meet the identified housing need. The viability evidence that supports the draft Local Plan indicates development could viably support a target of 50% affordable housing, which will be tied through the accompanying legal agreement to people in housing need with a confirmed local connection. The accompanying legal agreement will also set out the 'cascade' arrangements, so the affordable housing provides for people in need in the local area. However, targets above 50% affordable housing are likely to render housing delivery unviable. Our evidence shows that development on this site would not have a significant impact on the National Park and its special qualities. |
| Sway Parish Council | Recognises the proposal to increase the quantum of Defined Villages, and the pressure to provide housing while maintaining the National Park’s special qualities. | Comments noted. |
| New Forest Association | Opposes the designation of more Defined Villages, suggesting that this would reduce opportunities for the development of affordable dwellings within their boundaries. Considers that the 30% rule for extensions to small dwellings will be abandoned. Notes that affordable homes are not always achieved through windfall development. | Opposition and comments noted. However, the promotion of some settlements to Defined Villages would not have an adverse effect on the opportunity for new development to bring forward affordable housing. The 30% rule for extensions to small dwellings outside of Defined Villages has been reviewed in light of an assessment of appeal decisions. Windfall sites vary in scale and location, but they can play a valuable role in delivering affordable housing. In rural areas, this is often achieved through Exception Sites. Where on-site provision is not practical – such as on small or infill developments – financial contributions can instead support affordable housing delivery elsewhere. |
| New Forest Cycle Working Group | Notes that increasing the quantum of Defined Villages strengthens the need to amend the New Forest Local Cycling and Walking Infrastructure Plan (LCWIP) to create active travel links to these locations. | Comment noted. The New Forest LCWIP was published and adopted by Hampshire County Council in September 2025. A review is likely after five years. |
| Landford Community Cycling Group | Objects to the proposed designation of Landford – Nomansland as a ‘defined village’. | Objection and comments noted. |
| CPRE Hampshire | Proposes a target of 40 dwellings per annum to stabilise the National Park’s population levels while taking into account the National Park’s very special policy constraints. Suggests that the supporting text should clearly justify the new target of 950 over the plan period or 50 dpa relative to the evidence base. | Policy SP3 sets out a housing delivery target of just under 50 dwellings per annum, based on approximately 950 dwellings over the plan period, which is considered achievable within a nationally protected landscape. Policy SP29 identifies an appropriate and realistic windfall allowance which is informed by nine years of monitoring data and shows higher historic delivery. The Plan takes a cautious approach in light of significant environmental constraints, including extensive habitat designations and limited development opportunities. The Authority considers the housing strategy to be justified and appropriate to the National Park context, supporting population stability and local services while respecting landscape and environmental sensitivities. More detail is set out in the Sustainability Appraisal and the Housing Topic Paper. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Supports and welcomes the policy’s aims, including recognition that where the specific locational needs for commoners, estate workers or agricultural dwellings are unmet, housing development might be permitted outside of defined settlement boundaries. Proposes that the definition of estate works is broadened. | Support for policy aims welcomed and comments noted. |
| Carter Jonas on behalf of Fawley Waterside Ltd | Supports the Authority’s constrained housing target but considers that the same approach should be applied to economic development within the National Park. | Support for the housing target and strategy welcomed. It is recognised that the local economy is diverse. As such, the redevelopment of brownfield employment land, along with proposals for small-scale starter units, offices, and rural business units within the settlement boundaries of the Defined Villages, is supported. Nevertheless, the Economic Needs Assessment identifies a requirement for circa 13,000 sqm of additional employment floorspace. Given the limited capacity within the National Park to accommodate this level of growth through redevelopment, extension, or intensification of existing sites, the allocation of the site known as ‘Land north of Fawley Waterside’ is considered essential to meeting this identified need. |
| Gillings Planning on behalf of Trustees of the Barker-Mill Estates (SP33 site promoter) | Welcomes the review of the settlement hierarchy and the continuing designation of Ashurst, Brockenhurst, Lyndhurst, and Sway as Defined Villages. Notes the local plan’s ambition to deliver an additional 950 dwellings within the New Forest National Park between 2024 and 2043 to address its needs and maintain the vitality of local communities and support local services. Support the identification of new sites that when combined will deliver circa 315 dwellings. | Support welcomed and comments noted. |
| Turley on behalf of Pennyfarthing Homes (LAA31 site promoter) | Considers that the emerging review Local Plan and associated evidence base rightly acknowledges the need for a different approach to assessment and meeting the needs of the National Park, than is the case for adjacent local planning authorities. Notes that the National Planning Policy Frameworks confirms that the scale and extent of development in a National Park should respect the great weight to be given to conserving and enhancing the landscape and scenic quality of such areas and that this is evident through the emerging evidence base that informs the plan. | Comments noted. |
| Draycott on behalf of landowner | Suggests that it is not clear when settlement boundaries will be altered to include relevant allocated sites that currently lie beyond the boundary. | Amendments to the defined village settlement boundaries are set out in the accompanying schedule of amendments to the Policies Map. As a general rule, settlement boundaries will be amended at the next available opportunity once the site allocation has been completed. |
| Black Box Planning on behalf of Gervis Property Company Ltd (site promoter) | Supports the overall direction of the draft Local Plan’s spatial strategy. | Support welcomed. |
| Lucid Planning (SP40 site promoter) | Supports increasing the list of Defined Villages to assist in responding to larger housing need targets buts questions the approach to limiting the housing target to 950 homes across the Plan period. Suggests that in settlements other than Defined Villages, limited windfall housing provision on ancillary garden land should be taken into account, and that the larger site allocations could be used to provide off-site BNG for smaller, more constrained sites. | Support for increasing the number of Defined Villages to assist in meeting housing need welcomed and comments noted. It is agreed that the supporting text and supporting evidence base should set out clearly how the figure of 950 dwellings to be delivered over the plan period was derived. It is not considered appropriate to include housing provision on ancillary garden land in settlements without defined boundaries. Where feasible, most of the allocated sites will be expected to provide on-site BNG but it is not anticipated that these sites will be used to provide off-site BNG for other sites. |
| Individuals |
Responses were mixed but there was some stated support for the policy’s aims and a minor degree of support for the proposed site allocations in Redlynch and Landford – Nomansland. Strong objections were raised to the proposed designation of Landford – Nomansland as a Defined Village. Respondents noted that, even when considered together, the settlements do not offer as wide a range of services and facilities as the four existing Defined Villages. Many respondents considered Landford and Nomansland to be separate communities, each with distinct characteristics and identities. Some respondents felt that Defined Village designation would weaken planning controls and give greater scope for development within the village. Concerns were raised that designation as a Defined Village, including the loss of the 30% rule, could lead to higher levels of development being approved. Infill within hamlets and smaller villages was proposed.
The proposed site allocation at Landford and the Defined Village designation for Landford – Nomansland were considered incompatible with the statutory purposes of the New Forest National Park and contrary to policies in the adopted Local Plan 2016–2036. Respondents objected strongly to the proposed Landford site allocation, citing concerns about flooding, sewerage, traffic, environmental impacts, limited local facilities and whether the proposed 30 dwellings would amount to major development. Several respondents referred to a Landford Parish Council survey of existing residents, which they considered demonstrated that there is no need for affordable housing in the village. Others noted that the New Forest National Park’s population is in decline and argued that further residential development is therefore not warranted. Further concerns related to the current lack of shops, schools, healthcare facilities and transport links in Landford and Nomansland. Inclusion of properties to the north of Chinham Road, Bartley within the proposed settlement boundary for Cadnam – Bartley requested. |
Support for the policy’s aims welcomed and strong objection to the designation of further Defined Villages and the proposed site allocation at Landford noted.
The option of distributing development evenly across the National Park, without applying a settlement hierarchy, was examined through the Sustainability Appraisal (Option D). This approach was discounted because it would generate higher infrastructure requirements and environmental impacts, while failing to deliver clear or coherent strategic benefits. The proposed Landford and Nomansland boundary and Hamptworth Road allocation are not considered to conflict with the National Park Authority’s statutory purposes or the duty to support the social and economic wellbeing of Park communities. The Settlement Hierarchy Topic Paper sets out the rationale for reviewing the spatial strategy, and national policy requires reasonable alternatives for meeting housing need to be considered. Landford and Nomansland previously shared a Housing Policy Area boundary for many years prior to the adoption of the National Park Core Strategy in 2010.. The proposed settlement boundary is slightly smaller, broadly follows existing built form, and relates to a community with basic services including a school, shop, pub, recreation ground, village hall and church. As Defined Villages, limited development would be focused within the boundary, helping reduce incremental encroachment of the countryside, while sustaining local services. Although Landford has fewer services than some Defined Villages, it does have some basic services for a rural village and the scale of development proposed is modest. A Defined Village designation does not weaken planning controls. Properties within settlement boundaries remain subject to those controls. A potential 30-home scheme is not major development under NPPF paragraph 190, and evidence indicates no significant harm to the National Park or its special qualities. The National Park has a significant housing need and insufficient brownfield land to meet it, so greenfield site allocations are being considered. Although the NFNP population has slightly declined and is expected to grow only minimally, new homes are needed to stabilise communities and rebalance the housing stock, which is dominated by larger homes, towards smaller, affordable, accessible and specialist accommodation through Policies SP29, SP30 and SP31. This evidence supports allocations such as land south of Hamptworth Road, where a 50% affordable housing target could be legally secured for eligible local people from within the parish or an adjoining parish. Infrastructure providers have been consulted throughout plan-making, with the proposed quantum of development assessed against existing and proposed capacity. Wiltshire Council considers the site acceptable in highways terms and confirms local school capacity (with declining school rolls). The LLFA has confirmed the majority of the site is in Flood Zone 1, with no mapped surface water issue requiring a Level 2 SFRA. Southern Water confirms wastewater capacity. Around 30 dwellings would support local facilities, including a school with a declining roll. Where local infrastructure improvements are needed, developer contributions will be sought at application stage. Paragraph 5.15 refers to a regular, not frequent, bus service. Using parish population data – rather than settlement data – is consistent with the wider Settlement Hierarchy approach and provides a standard basis for assessing access to shared services and facilities. Comments on the proposed defined village boundary for Cadnam-Bartley are noted and amendments to the boundary have been proposed at the Regulation 19 stage. |
Policy SP4 – Major development in the National Park
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Copythorne Parish Council | Supports the policy aims but voices concerns regarding urbanisation from major development. Asks what national considerations would override the statutory purposes of the National Park. | Comments noted and support welcomed. National considerations – such as major infrastructure, significant economic development, or national security – may provide the exceptional circumstances required for major development to be supported, as per paragraph 190 of the NPPF (2024). In cases where conservation and public enjoyment conflict, the Sandford Principle applies, giving priority to conservation. |
| Sway Parish Council | Supports the addition of Whole Estate Plans. | Support welcomed. |
| Go New Forest CIC | Has concerns that application of the ‘major development test’ to future proposals for the enlargement and diversification of large, long-established visitor attractions would be too restrictive. | The policy wording and supporting text have been amended to become more flexible in relation to major visitor attractions. |
| Carter Jonas on behalf of Fawley Waterside Ltd |
Supports references to the Solent Freeport within the Local Plan.
Disputes that the site meets the definition of previously developed land and suggest that it appears to have been significantly rewilded. Queries the need to allocate ‘Land north of Fawley Waterside’ for employment use, stating that reliance of growth at the site of the former Fawley Power Station should avoid unnecessary development within the National Park. |
Support welcomed and comments noted.
It is incorrect to conclude that the site does not meet the definition of previously developed land (PDL) in the NPPF. The site has a clear history of development, having been used as a fuel storage facility and later as a waste recycling and transfer facility, none of which are excluded from the NPPF definition of PDL. While the land has more recently been subject to unauthorised waste dumping, it is recognised that this does not constitute development. Irrespective of this, the NPPF excludes land used for waste disposal by landfill only where restoration has been secured through development management procedures, which has not occurred in this instance. Parts of the site therefore continue to meet the definition of PDL. Paragraph 187(f) of the NPPF (2024) requires planning decisions to contribute to and enhance the natural environment, including through the remediation of degraded and contaminated land. The site to the north Fawley Waterside, while partially vegetated, is a partly previously developed site. Redevelopment therefore provides an opportunity to secure appropriate investigation, remediation and long-term environmental improvement in accordance with national planning policy and does not conflict with the statutory purposes of the National Park. In the absence of development, that remediation is unlikely to come forward. The allocation is therefore justified as a proportionate means of securing the restoration and productive reuse of a degraded site while helping to meet an evidenced need for 13,500 square metres of additional employment land. Opportunities to meet that need elsewhere in the National Park are limited. |
| Vail Williams on behalf of Trant Estates (LAA6 site promoter) | Supports the retention of a policy on major development. | Support welcomed and comments noted. |
| Laister Planning on behalf of Paultons Park | Regards the definition of “major development” as vague and subjective, creating uncertainty and risk over whether routine operational improvements to visitor attractions could trigger the exceptional circumstances test. Considers that the requirement for ‘Whole Estate Plans’ for enlargement and diversification of major tourist attractions is not supported by national policy or evidence and risks imposing unreasonable cost and delay, contrary to the NPPF. | The Authority disagrees with the assertion that the policy requires a clearer definition of ‘major development’ and that the requirement for Whole Estate Plans should be limited. The draft Local Plan already provides sufficient clarity on what constitutes major development within the National Park. It explains that major development includes proposals with the potential for long-term impacts on landscape, wildlife, or cultural heritage due to their scale, form, or nature. This is underpinned by footnote 67 of the NPPF (amended February 2025) which requires consideration of a proposal’s nature, scale, and setting, and whether it could significantly undermine the Park’s statutory purposes. The Plan also recognises that tourist attractions and holiday parks play an important role in the local economy, and therefore each proposal is assessed on a case-by-case basis against established criteria to ensure that the Park’s statutory purposes are safeguarded while fostering the socio-economic well-being of local communities. Paragraph 190 of the NPPF sets out the high-level criteria, which are further detailed within the policy wording for greater clarity. Additionally, the requirement for Whole Estate Plans provides further guidance to landowners and developers, while reinforcing the Plan’s broader green objectives. It is an approach that is included in the adopted New Forest National Park Local Plan (2019) and several other adopted National Park Local Plans. |
| Individuals | Broad support for the policy’s aims. Proposed site allocations considered to constitute major development and that brownfield sites should be used. Development opposed within the National Park. Enlargement of major tourist attractions should only be allowed in exceptional circumstances. A comprehensive Transport Assessment should be required for major development. Would like the policy wording to relate more clearly to the overriding statutory purposes of the National Park. Detrimental socio-economic impacts for local residents from development have not been considered. | Broad support welcomed and comments noted. There are no major developments proposed within the draft National Park Local Plan and insufficient brownfield sites to meet local needs. In addition to focusing on the two statutory purposes that the National Park was designated for, the Authority also has a duty to foster the economic and social wellbeing of local communities within the Park (Section 62(1) of the Environment Act 1995 (as amended), and the tourism and leisure sectors can offer significant opportunities for local employment. Setting out the key issues and potential solutions in an assessment helps focus discussions between officers and developers, supporting clearer decision-making. While this does not guarantee consent, it ensures that proposals with potential impacts on the National Park and its special qualities are properly evaluated, in line with paragraphs 189 and 190 of the NPPF. Transport considerations – including the need for Transport Assessments or Statements and criteria for new or enhanced transport infrastructure – are addressed under draft Policy DP65. Major developments will be assessed against both SP4 and DP65. |
Policy SP5 – Land to north of Fawley Waterside
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Opportunities to enhance and restore the watercourse to the eastern boundary of the site should be explored as part of any proposal for development. | The policy wording has been amended to set out that opportunities to enhance and restore the watercourse to the site's eastern boundary should be explored. |
| Historic England | Requests that reference to the historic environment and historic landscape character is included respectively within the policy wording, and support text. | The supporting text has been expanded to include historic landscape character, and reference has been made to the historic environment within the policy wording. |
| Southern Water | Advises that a preliminary assessment has confirmed that existing local sewerage and water infrastructure to the site currently has capacity to accommodate the demand forecast for this proposal. | Comments noted and welcomed. |
| Hampshire County Council | Proposes that the policy sets out that opportunities for active travel networks should be created, a transport assessment should be required and transport issues addressed through mitigation and/or contributions, and that a drainage strategy must accompany any scheme coming forward on this site. | The policy wording has been amended to reference public transport networks, and to include a requirement for a drainage strategy and transport assessment, design and mitigation/contributions. |
| New Forest District Council | States that unclear if the location of the site will be able to provide for the economic needs of the Park. Suggests that more dispersed, small‑scale employment provision in or near established Park settlements could offer a more resilient and locally appropriate strategy consistent with actual employment trends and the Park’s duty in relation to economic and social well-being of local communities. Notes that the delivery timescale may be uncertain due to the site’s known delivery challenges. | The spatial options for employment development have been considered through the Sustainability Appraisal process. Not all employment needs across the Plan period will be met on this site. For example, draft Local Plan policies support the extension and redevelopment of existing and new small-scale employment sites within and adjacent to existing settlements across the National Park, particularly the seven Defined Villages. Employment needs will be addressed through a combined approach: dispersed, criteria-based support for employment sites alongside a strategic allocation north of Fawley Waterside. This approach will provide flexibility over the plan period while recognising the location’s strategic importance. |
| Copythorne Parish Council | Supports the policy’s aims but expresses concerns regarding traffic congestion and that the Waterside area will become “one vast Freeport”. | Support welcomed. There are no plans to redevelop the entirety of the Waterside area into a Freeport, and the statutory purposes of the National Park would not support this. |
| Landford Parish Council | Notes that back up grazing land for commoners must not be lost to development. | Comments noted. |
| New Forest Association | Considers that the site has potential as back up grazing land. Does not accept that the need for further employment floorspace warrants the allocation of this site. | The site’s historic use for contaminated waste disposal renders it unsuitable for grazing unless detailed investigation and appropriate remediation or management measures are undertaken. Taking account of sites with existing planning permission, the Economic Needs Assessment identifies a shortfall of 12,390 sq.m of employment floorspace over the plan period. As set out in the 'Thriving Local Economy' chapter of the draft Local Plan, meeting this need is challenging due to the dispersed nature and small scale of much of the existing employment stock. The Authority has therefore identified a strategic employment allocation at Fawley Waterside, alongside a focus on redevelopment, refurbishment and intensification of existing sites. |
| New Forest Cycle Working Group | Supports criterion iii) but suggests that the cycle parking standards should be revised. | Support welcomed. The cycle standards have been reviewed and considered appropriate for the level of development within the National Park. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Broadly supports the policy’s aims. Request that the supporting text should refer to the entire site’s historic uses for fuel storage and waste management, need for significant remediation, and recognise its status as previously developed land. Proposes that the policy wording is amended to permit energy storage facilities, new electricity and digital infrastructure and that the permitted floorspace is increased to 20,000 to 30,000 sq.m. Considers that it is not necessary, appropriate or commercially viable to allocate a large part of the site for nature recovery / green space use. Suggests that biodiversity net gain should be delivered off-site. | Broad support welcomed and comments noted. Further supporting text has been provided to outline the historic use of the site, confirm its designation as previously developed land, acknowledge the presence of legacy contamination and the need for substantial remediation. As set out in our reply to the respondent's comments on Policy SP1, it is not appropriate to extend the site's proposed use to include energy storage or new electricity and digital infrastructure. Given that nature conservation and recovery are central to the NPA's statutory purposes, it is reasonable to expect the site to contribute to these objectives. Delivery of biodiversity net gain must follow the mitigation hierarchy, demonstrating that on-site, in-kind habitat creation has been fully explored and is not feasible. On-site gains must be maximized before any off-site solutions are considered, which are acceptable only as a last resort. |
| Individuals | Broad support for the policy’s aims but concerns expressed that the whole of the Waterside area will eventually be developed into a Freeport. | Broad support welcomed. There are no plans to redevelop the entirety of the Waterside area into a Freeport, and the statutory purposes of the National Park would not support this. |
Policy DP6 – Infrastructure provision and developer contributions
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Southern Water | Would welcome and support the inclusion of a policy requirement that ‘appropriate new and improved utility infrastructure will be permitted in order to meet the identified needs of the community’. | The policy wording has been amended to set out that appropriate utility infrastructure will be permitted. |
| Copythorne Parish Council | Requests that more information be provided regarding interactions with local residents to determine the extent of new/improved infrastructure needs. Suggests that the re-opening of the Hythe Ferry should be taken into consideration. | As part of the Local Plan process, the Authority has prepared an Infrastructure Delivery Plan, setting out existing infrastructure provision and future needs over the Plan period. It includes information from key stakeholders, such as Hampshire County Council, Wiltshire Council and utilities providers, to set out what infrastructure provision is required, where the funding will come from, who will provide this, and when it will be implemented. Financing the re-opening of the Hythe Ferry is beyond the remit of the local planning authority. |
| Landford Parish Council | Notes that infrastructure provision must support local communities without compromising the special qualities of the New Forest. | Agreed. |
| Lyndhurst Parish Council | Would like the NPA to adopt the Community Infrastructure Levy (CIL) as a mechanism to provide and enhance local infrastructure through development contributions. | The Government is currently reviewing the developer-contribution framework, including the Community Infrastructure Levy (CIL). To date only one English national park authority has implemented CIL (the South Downs) and the New Forest National Park Authority currently has no plans to do so. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Supports the policy wording that ‘regard will be had to economic viability considerations at the site-specific level’ given that demands for excessive financial contributions can preclude site delivery. Recognises that in some cases, development may need to contribute to the delivery of improved infrastructure, where this cannot be accommodated on site. However, considers that contributions towards off-site infrastructure in respect to Policy SP5 would be limited, and where financial contributions are sought these would be clearly justified. | Support for policy aims welcomed and comments noted. |
| Individuals | Support for the policy’s aims. Would like the supporting text to make it clear that developers and the NFNPA must consult with local communities to determine what infrastructure provision is required. Suggests that the policy wording is strengthened to require assessments for traffic, infrastructure, and drainage when development of multiple dwellings is proposed. | Support welcomed. Ultimately it is a decision of the local planning authority – working with statutory consultees and utility providers – to assess what infrastructure provision is required. Development proposals must follow the drainage hierarchy set out in Planning Practice Guidance to ensure that all surface-water drainage options are fully considered. As set out in draft Policy DP65, where development proposals are likely to have significant transport implications, these will need to be accompanied by a Transport Assessment or Statement to demonstrate. While the development proposed within the New Forest generally does not require new transport infrastructure, the Authority will work with Hampshire County Council and Wiltshire Council to direct transport contributions from larger schemes toward necessary improvements. |
Chapter 5 – Climate Change
There were a total of 32 representations relating to this chapter. A summary of the main issues raised is set out below.
Policy SP7 – Safeguarding and improving water resources
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Supports reference to sustainable drainage systems (SuDS) and the inclusion of a water efficiency standard. Notes that the entire National Park is subject to serious water stress. Recommends expanding criterion a) to make reference to natural flood management techniques. | Support welcomed. Policy wording has been updated to refer to natural flood management techniques. |
| Natural England | Welcomes reference to nature-based solutions in relation to SuDS but advises that these could have a wider role in addressing climate change adaptation and mitigation. Advocates that a policy is included to specifically address climate change. | Support welcomed. Policy SP9 ‘Sustainable Construction’ focuses on the ways that new development can address climate change. |
| Historic England | Suggests that the inclusion of examples of SuDS measures within policy criterion c) elevates these above other options and proposes moving these into the supporting text. Expresses concerns regarding the potential effects of SuDS on archaeological remains. | The Authority does not agree that by including examples of common SuDS measures, these are promoted above other options. Each SuDS will be designed to reflect site-specific requirements. The archaeological sensitivity of any site will be assessed through the development planning process prior to implementation of any agreed SuDS. |
| Hampshire County Council | Supports criteria a) and b) but recommends a more flexible to approach to acknowledge that SuDS may not be appropriate for some forms of development, such as petrol stations and car washes. | Support welcomed, comments noted and additional wording has been included within the supporting text to recognise that not all forms of development are appropriate for SuDS. |
| Test Valley Borough Council | Supports the policy aim to set a water efficiency standard of 100 litres per person per day. | Support welcomed. |
| Brockenhurst Parish Council | Agrees with the policy’s aims. Concerns raised regarding controls to reduce flooding from run-off. | Support welcomed. While it is acknowledged that the NPA is not the lead local flood authority, it should be noted that the Authority still has influence over wider strategic flood risk matters i.e., local planning authority/Hampshire County Council steering groups. |
| Copythorne Parish Council | Supports reference to the climate change emergency and Race to Zero initiatives, along with preference for Nature-based Solutions. Agrees with improving water efficiency but notes that this could be difficult to enforce. Proposes that paragraph 5.25 should record that Bartley, along with Cadnam, is a known surface water flooding area. | Support welcomed however it is not considered appropriate to list known areas within the National Park that are subject to surface water flooding within the supporting text, as the levels of flood risk is likely to change over time – either increasing or reducing following planned interventions. |
| Landford Parish Council | Supports protection of the natural environment from the impacts of development. | Support welcomed. |
| Sway Parish Council | Supports the policy aims and appreciates additional clarity and detail on the integration of SuDS into developments. Welcomes the inclusion of a water efficiency standard. | Support welcomed and comments noted. |
| Southern Water | Welcomes and supports the policy’s aims, particularly the inclusion of a water efficiency standard. Proposes additional wording to set out the requirements for new development to address surface water run-off and prevent pollutants entering watercourses. Advocates prioritising on-site surface water management through SuDS provision, to reduce surface water from entering the sewerage network. Recommends an additional criterion to set out that, should a groundwater Source Protection Zone lie within a site’s boundaries, that this must be protected. | Support welcomed and proposed changes agreed. |
| Woodland Trust | Supports the policy’s aims, in particular criterion c). | Support welcomed. |
| Gillings Planning on behalf of Trustees of the Barker-Mill Estates (SP33 site promoter) | Supports the policy’s aims but expresses concerns regarding introduction of a maximum daily water efficiency standard of 100 litres per person, or lower if stipulated by future national standards. | Support welcomed and comments noted. However, the New Forest is identified as an area of serious water stress and as such, a minimum water efficiency standard is considered justified. |
| Individuals | The inclusion of greater detail regarding climate change, and the development of policies that incorporate climate change resilience welcomed. Suggested that criteria a), b) and c) should state ‘must’ instead of ‘should’. Proposed that the policy should ensure that the design of storm drainage systems for new developments will not increase flood risk to existing residents’ properties. Strong objection to the proposed site allocation in Landford. Issues with the existing sewerage system noted and that pollution from sewage or run-off entering the River Blackwater would be harmful to the river’s ecosystems and impact on Sea Trout spawning grounds. | Support welcomed and comments noted. It is agreed that criterion a) of the policy should be strengthened to state that development must take account of flood risk and this has been implemented. However, it is not considered appropriate to change the wording in criteria b) and c). Policy SP7 aims to safeguard and improve water resources, rather than focus on preventing flooding. Policy SP8 addresses flood risk. Hampshire County Council are the flood authority and lead on flood related matters across Hampshire. Strong objection to proposed site allocation in Landford noted. Local infrastructure providers – including Wiltshire Council in their respective roles as Lead Local Flood and Highways Authority – have been consulted throughout the plan-making process. As part of this, the proposed scale and distribution of development has been assessed in relation to existing and proposed infrastructure capacity. |
Policy SP8 – Flood risk
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Strongly recommends that the policy wording is strengthened to set out the requirements and align more fully with the National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG). | It is agreed that the policy would benefit from greater alignment with the NPPF and PPG and it has been revised to reflect this. |
| Historic England | Recommends referring to the historic environment within paragraph 5.27. | The supporting text has been amended to refer to the historic environment. |
| Hampshire County Council | Supports the aims of policy but advises that criterion a) should be expanded to include ‘from any source’. Suggests that criterion b) should set out that certain types of development may be permissible in high-risk flood zones assuming that it is safe and does not increase flood risk elsewhere. Proposes that the definition of high flood risk areas is amended and transferred to within the supporting text. Supports the reference to Catchment Management Plan policies within criterion d). Suggests that paragraph 5.25 should make it clear that flood zones relate to fluvial and coastal flooding only. | Support welcomed, comments noted and the proposed changes are agreed to and have been made within the Regulation 19 Submission draft Local Plan. |
| Brockenhurst Parish Council | Expresses concerns regarding the influence of the NPA on flood protection matters. | While it is acknowledged that the NPA is not the Lead Local Flood Authority, it should be noted that the Authority still has influence over wider strategic flood risk matters, i.e., local planning authority/Hampshire County Council steering groups. |
| Copythorne Parish Council | Proposes that paragraph 5.25 should record that Bartley, along with Cadnam, is a known surface water flooding area. | It is not considered appropriate to list known areas within the National Park that are subject to surface water flooding within the supporting text, as the levels of flood risk is likely to change over time – either increasing or reducing following planned interventions. |
| Landford Parish Council | Agrees that water habitats should be protected. | Support welcomed. |
| Sway Parish Council | Supports the requirement for developers to evidence a catchment-based approach to flood risk management. | Support welcomed. |
| Individuals | Broad support for the policy’s aims. Objections to the proposed site allocations, with concerns that development of these sites would increase existing flood risk from run-off and that sewerage systems are already struggling. Proposes that the policy should ensure that new developments will not increase flood risk to existing residents’ properties. | Broad support welcomed. Statutory consultees - including Wiltshire and Hampshire County Councils in their respective roles as Lead Local Flood and Highways Authorities – have been consulted throughout the plan-making process. The policy wording for the site allocations has been amended where necessary to highlight the need to provide further information on flood risk at the planning application stage. |
Policy SP9 – Sustainable construction
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Historic England | Would like reference made to the historic environment within paragraph 5.35. | Reference to the historic environment should be taken as a given under the ‘built environment’. Other policies within the draft Local Plan, such as Policy SP24, consider the role of the historic environment in mitigating climate change. |
| Hampshire County Council (Lead Local Flood Authority) | States that the Lead Local Flood Authority has reviewed the policy recommendations made within Partnership for South Hampshire Level 1 Strategic Flood Risk Assessment (SFRA) (2024), Green Infrastructure, Flooding & Water Management - Partnership for South Hampshire, and Strategic Flood Risk Assessment - New Forest District Council. Advises that the SFRA evidence base should be used to identify where the flood risk needs require local policies in the Local Plan. Notes that criterion f) states: ‘Avoid development in places at highest risk of flooding/coastal erosion’. Suggests reviewing policies SP8 and SP9 to confirm parts f) and b) are not duplications and have different aims. Observes that this appears to be doing the same thing as SP8 b). Considers Public Health to be a holistic factor and recommends that opportunities to address this should be included throughout the Local Plan. | Supporting text has been amended to set out that public health factors should be incorporated into the design and construction of developments. The wording addressing flood risk from coastal, fluvial, surface water, or coastal erosion within SP7, SP8 and SP9 reflects the aims of each policy and as such, it is not considered that duplication occurs; therefore, no changes are required. |
| Brockenhurst Parish Council | Notes that gas and oil boilers are sources of carbon emissions. | While legislation still permits the installation of oil boilers, the government is preparing to phase out gas boilers through adoption of the Future Homes Standard. |
| Copythorne Parish Council | Supports the policy’s aims. Proposes minor amendments to the policy’s wording and queries how improvements to building standards could be applied to extensions and thermal upgrades. | Support welcomed. Extensions and thermal upgrades to residential housing are likely to be considered ‘permitted development’ and would not require planning permission. |
| Landford Parish Council | Notes that sustainable construction should enhance the natural environment and ecological processes and not be compromised by them. | Comments noted. |
| Sway Parish Council | Welcomes the range of matters covered by the policy, in particular the requirement for bird bricks. Recommends additional wording in relation to artificial nesting habitats. | Support welcomed and comments noted. However, it is not considered necessary to include additional wording about artificial nesting habitats as this is set out in greater detail within Policy SP13. |
| Woodland Trust | Supports the policy’s aims, in particular criterion d). Suggests that the policy wording should be expanded to include a new criterion regarding maximising the use of nature-based solutions. | Support welcomed. Maximising the use of nature-based solutions is addressed throughout Chapter 5. |
| Carter Jonas on behalf of Fawley Waterside Ltd | Notes that the Local Plan should reflect national level changes to policies and guidance. | Comments noted. |
| Individuals | Reference to surface water flooding within the policy wording proposed. Reference to The Royal Institute of Chartered Surveyors (RICS) Whole Life Carbon Assessment for the Built Environment suggested. Opposition to development of greenbelt land. | The policy already addresses flood risk. It is not considered necessary to refer to the RICS Whole Life Carbon Assessment as the NFNPA does not require carbon assessment as part of the development process, although this may be a future consideration. While it is incorrect to assume that the New Forest National Park contains greenbelt land, it does contain greenfield sites which the policies in the Local Plan seek to protect. Please note that New Forest District Council is affected by some greenbelt along the south-west boundary and have set out policies within their Local Plan to address how it is managed within their area of the New Forest. |
Policy SP10 – Renewable energy
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Historic England | Recommends noting the significance of heritage assets, and the contribution to significance made by their setting, within criterion c). | The policy has been amended to incorporate the proposed additional wording. |
| Dorset County Council | Supports the policy aims. | Support welcomed. |
| Brockenhurst Parish Council | Strongly agrees with encouraging renewable energy installations but does not support a complete ban on the use of renewable energy within SSSI areas. | Strong support for renewable energy welcomed. Policy SP10 outlines that proposals for renewable energy development with is likely to have an adverse effect on designated nature conservation sites will not be permitted. This policy, in combination with Policy SP12, is intended to recognise the need to protect the special qualities of the New Forest and to guide development for renewable energy to more sustainable locations where the scale is appropriate. It reflects the protection afforded to SSSI as nationally important sites for nature conservation. |
| Copythorne Parish Council | Proposes that the policy should encourage installation of solar panels above car parks and car ports. Opposes ground-mounted solar panels in residential gardens. | Comments noted. The policy advocates for appropriately sized solar development that utilises brownfield development rather than greenfield or residential gardens. |
| Landford Parish Council | Considers that renewable energy should be explored and employed to reduce dependency on fossil fuels. | Comments noted. |
| National Grid Electricity Transmission | Advises that demand for cleaner energy will rise as the national grid (NGET) looks to decarbonise. National planning should note the Government’s target of net zero by 2050. NGET is looking to advocate for offshore wind and subsea connections. | Comments noted. |
| CPRE Hampshire | Suggests that the policy should advocate the use of solar panels on existing roofs, car parks within settlement, and brownfield land, subject to landscape and heritage considerations. | Development for renewables is encouraged to take a brownfield-first approach and should be designed to have minimal impact on the landscape character under SP10. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Considers that the policy aims should allow for other forms of energy-related infrastructure, such as battery energy storage systems (BESS), to support development of large-scale renewable projects outside of the National Park. | Both the current (December 2024) and emerging versions of the National Planning Policy Framework (NPPF) outline that applications for major development, which in the context of national parks includes BESS, should be permitted only in exceptional circumstances. The statutory purposes of the National Park require that its special qualities are protected. As such, any development permitted within the Park should directly benefit communities within the Park, which cannot be assumed would be the result of expanding the scope of the policy to include energy-related infrastructure serving development beyond the National Park’s boundaries. The policy does not preclude energy-related infrastructure, but this would be subject to consideration under the development planning process. |
| Vail Williams on behalf of Trant Estates (LAA6 site promoter) | Would like Policy SP10 to be amended to note that where development meets more than identified local business / community need, the proposed development will be considered under the major development policy SP4. | This is implicit within the Local Plan, with a policy specifically aimed at proposals for ‘major development’. |
| Draycott on behalf of Guy Anderson | Proposes that an additional criterion is included within the policy wording, setting out that all existing temporary permissions for solar and other renewables will become permanent in order to support the Authority’s ecological and decarbonisation agenda. | It is not agreed that existing temporary permissions for renewable energy sites should automatically become permanent. Temporary permissions for renewables have bene granted because there is an acknowledged impact form the development where it would not be appropriate to grant permanent consent. Landowners are not precluded from taking forward such proposals through the planning application route. |
| Egdon Resources on behalf of BioSouth Energy Limited | Considers that the policy aims should allow for other forms of energy-related infrastructure, such as underground electricity cables, to support development of renewable energy projects outside of the National Park and proposes amendments to policy wording. | Proposals for renewable energy should evidence meeting a local need and be considered 'small-scale' under SP10. Where this is not the case, proposals will be considered under the major development policy SP4. The criteria set out within the suggested new policy wording is already established within other Local Plan policy, i.e., landscape character, important nature sites, the historic built environment. Amending SP10 to include criteria for only underground cabling (for renewable energy) is too prescriptive for a Local Plan that already centres around the impact of development in the New Forest. |
| Individuals | Support for the policy’s aims but suggestion made that focus should be made on protection of the New Forest’s landscape, character, special qualities and communities, rather than contributing to national climate change targets. Support for the use of renewable energy but potential incompatibility with historic buildings noted. | Support welcomed and comments noted. While the NFNPA is keen to support the transition to renewable energy, the primary purposes for the designation of the National Park, alongside its duty to foster the economic and social well-being of communities within the Park, take precedence. Policy SP23 will continue to inform the installation of renewable energies within historic buildings. |
Chapter 6 – Protecting and Enhancing the Natural Environment
There were a total of 36 representations relating to this chapter. A summary of the main issues raised is set out below.
General comments relating to Chapter 6
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Natural England | Proposes that a bespoke policy to safeguard soils is prepared. | A bespoke policy is not considered necessary; however, existing policies have been strengthened to protect soils from development, with supporting text recognising their intrinsic value and their role in underpinning ecosystems and the services that they provide. |
| Historic England | Recommends including reference to the historic environment within the opening paragraph. | The chapter’s opening paragraph has been amended to refer to the setting of heritage assets. |
| Hampshire County Council | Recommends that the policies within Chapter 6 better emphasise the importance of accessible and inclusive green and blue spaces within developments. | The importance of accessible and inclusive green and blue infrastructure spaces has been emphasised throughout the Natural Environment chapter. |
| Sway Parish Council | Supports the intention to monitor air pollution and the commitment to support other authorities in development mitigation strategies should these prove warranted. | Support welcomed and comments noted. |
Policy SP11 – Nature conservation sites of international importance
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Advises that the policy should set out that contributions to the NPA’s Habitat Mitigation Scheme and/or the Bird Aware Solent Strategy will enable developer-led mitigation proposals to be secured and managed in perpetuity. | The policy wording has been updated to set out that developer-led mitigation proposals will be secured and managed in perpetuity. |
| Natural England | Welcomes opportunity to address recreational pressures from new development and supports the inclusion of nutrient neutrality. However, they advise that nutrient neutrality mitigation measures should still be required even if the condition status changes to favourable, and that developer-led mitigation proposals should be secured and managed in perpetuity. Recommends additional forms of development that could contribute to either nitrate or phosphate pollution should be subject to the policy criteria. Suggests that bespoke policies are prepared for each internationally designated nature conservation site within the National Park. | Support welcomed and comments noted. Guidance provided by national government is clear in setting out that in respect to nutrient neutrality mitigation measures apply to forms of overnight accommodation – it does not stipulate that other types of development are caught by the requirement. Expanding eligible developments to include proposals for new commercial or industrial facilities could lead to double counting where workers also live within the catchment zone. Where new road schemes or commercial or industrial development such as waste management facilities are proposed, consideration will be given to potential pollution during the planning application process. Changes in agricultural practices are typically beyond the remit of the planning system. The Authority does not consider that there is any material benefit in developing bespoke policies for each of the internationally designated nature conservation sites that lie within the National Park as it is considered that the wording of Policy SP11 is sufficient. |
| Historic England | Recommends making reference to the New Forest’s historic landscape character, and the New Forest Farmstead and Landscape Statement within the supporting text. | The supporting text has been amended to refer to the historic landscape character, and the New Forest Farmstead and Landscape Statement, respectively. |
| Test Valley Borough Council | Acknowledges that the main areas of strategic cross-boundary planning are identified as habitat protection and housing provision. | Comments noted. |
| Copythorne Parish Council | Would like the final paragraph of the policy to make it clear that exceptional circumstances would be required for development proposals to be considered. Queries why other forms of development are not required to demonstrate nutrient neutrality. | The final paragraph has been amended to make it clearer that exceptional circumstances would be required. Government advice confirms that it is housing and other forms of development that comprise overnight accommodation that is required to demonstrate nutrient neutrality. |
| Landford Parish Council | Acknowledges the New Forest’s uniqueness, that it supports many species that lack habitat elsewhere, and that internationally designated nature conservation sites need to be preserved and expanded. | Comments noted. |
| New Forest Association | Expresses concerns that the policy does not address provision of alternative sites to reduce recreational impacts and opposes acknowledging that avoidance or mitigation may not always be possible. | The policy focuses on protection of nature conservation sites, rather than provision of alternative natural greenspaces, which is within Policy SP15. While the policy – aligned with the National Parks' statutory purposes – seeks to protect internationally important nature conservation sites, it is possible that there may be circumstances where avoidance or mitigation is not achievable. It is therefore essential to acknowledge this and to clearly set out the Authority's expectations; the wording in paragraph 6.13 addresses this scenario. |
| RSPB | Would welcome further reference to strategic mitigation that coordinates and complements adjacent local authority plans and policies. | The supporting text has been amended to refer to the NFNP Recreation Management Strategy. |
| CPRE Hampshire | Questions the continuing appropriateness of the 400m buffer in the face of intense recreational pressures. Proposes that a specialist study is undertaken to understand the complex relationships between the HRA impacts and commoning. Suggests that it may be appropriate to seek a developer contribution for the protection and purchase of back up grazing. | The 400m buffer zone relates more specifically to urban edge impacts, rather than in-combination recreational impacts. Natural England has supported the Authority’s approach through the Local Plan and supporting HRA. |
| Individuals |
Broad support for the policy’s aims. Considers that the policy gives a ‘green light’ to development of protected sites. Queries how judgement is made – and who is responsible for – permitting development on SSSIs; considers that SSSIs are not subject to genuine protection.
The following amendments are proposed: - Changing the third sentence of the first paragraph to: If this is the case, the Authority will look at options to mitigate negative impacts. Compensation will only be considered a suitable mitigation measure if there are no alternatives. [to reflect the mitigation hierarchy] - Deleting ‘through its lifetime’ from the end of the second paragraph. [to take into consideration potential long-term impacts from pollutant leaching, etc.] |
Support welcomed. The policy wording sets out that the Authority will assess each case on its merits. However, exceptional circumstances would be required to permit development. It is incorrect to state that SSSIs – and other nature conservation sites – are not subject to protection. More than half of the New Forest National Park is subject to nature conservation designations, which is considerably more than any other national park. When planning applications which may affect protected areas are received, stakeholders such as the Natural England, the Environment Agency and relevant interest groups are consulted in addition to the Authority’s own, in-house ecologists. The NFNPA is also a district licensing authority for sites where Great Crested Newts could be present. While it is possible that some forms of development could potentially take place on protected sites, this would only occur under exceptional circumstances case where it could be demonstrated that the development was imperative, in the wider public interest and that the public benefit would definitively outweigh the harm to the protected habitat, such as critical utilities infrastructure or national security/defence. The policy has been subject to scrutiny through the Habitats Regulations Assessment (HRA) and by Government statutory consultees who are content with the wording. |
Policy SP12 – The natural environment – nationally, regional and locally important sites
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Supports the policy aims and commends reference to the Local Nature Recovery Strategies and to the protection, maintenance, and enhancement of the water environment. Advises that the policy wording should make it clear that no direct loss of SSSI land or features will be permitted. | Support welcomed and comments noted. The policy wording has been amended to set out that no direct loss of SSSI land or features will be permitted to safeguard from incremental loss. |
| Natural England | Supports the policy’s strategic approach to nature recovery but advises that the wording should be strengthened to include clear provisions for the protection of the New Forest’s SSSIs. | Support welcomed and the policy wording has been strengthened to ensure that nationally important habitats are safeguarded from incremental loss. |
| Wiltshire Council | Advises that the proposals within the draft Local Plan have some potential to affect internationally protected sites outside of the National Park. | The supporting text now acknowledges internationally designated nature conservation sites beyond the Park's boundary. These cross-boundary impacts are also picked up in the HRA of the Regulation 19 Submission draft Local Plan. |
| Dorset County Council | Supports the policy aims. | Support welcomed and comments noted. |
| Copythorne Parish Council | States that the policy wording contradicts itself. | While the existing paragraph sets out that development on a Site of Special Scientific Interest would only be permitted if the “benefits of the development clearly outweigh” the impacts on an SSSI, additional wording to aid clarity has been included. |
| Landford Parish Council | Acknowledges that the natural environment of the New Forest is unique and requires protecting. | Comments noted. |
| Woodland Trust | Supports the policy aims, particularly the reference to the Local Nature Recovery Strategies. Advises that the policy should set out that development that could have negative impacts on irreplaceable habitats should be refused, unless wholly exceptional reasons can justify this and a suitable compensation strategy is implemented. | Support welcomed and comments noted. Reference to irreplaceable habitats has now been included within the policy wording. |
| RSPB | Supports the policy aims and reference to Local Nature Recovery Strategies. | Support welcomed. |
| Individuals | Support for the policy’s aims. The second and third sentences considered to contradict one another. Protection from Oak Processionary Moth queried. Greater protection of reptiles and ground-nesting birds from tourism and uncontrolled dog walking required. | Support welcomed and comments noted. The wording has been amended to aid clarification of the second and third sentences. Protection of trees from the Oak Processionary Moth is beyond the scope of the Local Plan and is more appropriate to the context of the New Forest Partnership Plan. Policy SP12, along with other policies within the draft Local Plan, seeks to protect nature conservation sites – and the species that are reliant on these – from both development and recreational impacts. Policy SP13 now makes explicit reference to reptile hibernacula as part of a suite of biodiversity enhancement measures that new development would be expected to incorporate. |
Policy SP13 – Biodiversity Net Gain
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Supports the policy aims and the reference within the supporting text to the benefits of BNG to the aquatic environment. Advocates encouraging consideration of the aquatic environment within the policy wording. | Support welcomed and the policy wording has been amended to encourage consideration of the aquatic environment. |
| Natural England | Welcomes the policy’s aims and supports the use of the Local Nature Recovery Strategies to guide effective implementation of BNG and conservation of protected and notable species. Suggests that the policy should include consideration of geodiversity conservation. Advises that the policy should set out the BNG strategy in greater detail and should seek to achieve wider environmental gains, such as natural capital benefits. | Support for the policy welcomed and comments noted. The Authority understands that there are no geological sites or features within, or within reasonable proximity of, the Park that would require consideration. However, the policy wording has been amended to set out the BNG strategy, to advise that wider environmental gains will be sought, and to expand upon the aims of the Green Halo Partnership. |
| Copythorne Parish Council | Supports the requirement for bird bricks in new development. Questions how a 10% net gain in biodiversity will be ensured. | Support welcomed. Habitats created or enhanced to deliver BNG are secured and managed for a minimum of 30 years through appropriate legal mechanisms such as Section 106 agreements and Conservation Covenants. A Habitat Management and Monitoring Plan is required from the applicant, and this sets out long-term management, monitoring, and remedial measures. Where BNG is delivered off-site, land is registered on the national register, and monitoring reports are required to be provided to the Authority to ensure compliance over the minimum statutory 30-year period. |
| Landford Parish Council | Supports the aims of BNG. | Support welcomed. |
| Sway Parish Council | Supports the policy’s aims but would welcome greater clarity regarding the mitigation hierarchy. Welcomes reference to Swifts but recommends that reference be made to other red-listed species, such as House Martins and suggests that architectural features such as deep eaves and gables ends are encouraged for new development. | Support welcomed. The policy wording has been amended to set out the BNG strategy. Gable ends are not mandatory in the New Forest National Park Design Code, but they align with local vernacular and are appropriate when reflecting established built form. Deep eaves can be substituted with integrated features - such as bird bricks or nesting cups - to provide nesting opportunities for small bird species. Swift bricks, though designed for swifts, also support sparrows and other species, while house martins and swallows prefer nest cups. Best practice guidance in BS 42021 and CIEEM, as referenced within the policy's final paragraph, supports using wall-sited features, including nest cups where appropriate. |
| Woodland Trust | Advocates that the NPA should be ambitious in its aims and consider a Biodiversity Net Gain uplift greater than the minimum legal requirement of 10%. | Proposals to exceed the mandatory 10% Biodiversity Net Gain (BNG) requirement support National Park purposes but must be balanced against the National Planning Policy Framework’s (NPPF) presumption in favour of sustainable development and the risk of making schemes unviable when combined with other obligations (e.g., affordable housing) and rising construction costs. The Government has signalled that it expects local planning authorities to stick to the 10% BNG figure. |
| RSPB | Advocates that the NPA should be ambitious in its aims and consider a Biodiversity Net Gain uplift greater than the minimum legal requirement of 10%. | Proposals to exceed the mandatory 10% Biodiversity Net Gain (BNG) requirement support National Park purposes but must be balanced against the National Planning Policy Framework’s (NPPF) presumption in favour of sustainable development and the risk of making schemes unviable when combined with other obligations (e.g., affordable housing) and rising construction costs. The Government has signalled that it expects local planning authorities to stick to the 10% BNG figure. |
| CPRE Hampshire | Considers that there is competition for land to use for either BNG or back up grazing. Proposes that BNG should not be prioritised over back up grazing and queries whether the two uses can coexist. | The National Park Local Plan plays an important role in safeguarding land for back up grazing. To date there is limited evidence that BNG delivery is impacting on the stock of land available for back up grazing, and the two are not incompatible. While BNG is a mandatory requirement, it does not supersede the long-standing environmental protections that underpin agricultural and commoning rights. Within this policy framework, Policy SP55 is considered to provide robust and adequate criteria for assessing development proposals, such as habitat banks and off-site provision of biodiversity net gain, that could affect back up grazing land. |
| The Hampshire Ornithological Society | Advocates that the NPA should be ambitious in its aims and consider a Biodiversity Net Gain uplift greater than the minimum legal requirement of 10%. Would welcome greater clarity regarding the mitigation hierarchy. Welcomes reference to Swifts but recommends that reference be made to other red-listed species, such as House Martins and suggests that architectural features such as deep eaves and gables ends are encouraged for new development. | Proposals to exceed the mandatory 10% Biodiversity Net Gain (BNG) requirement support National Park purposes but must be balanced against the National Planning Policy Framework’s (NPPF) presumption in favour of sustainable development and the risk of making schemes unviable when combined with other obligations (e.g., affordable housing) and rising construction costs. It is agreed that the policy wording should set out the BNG strategy. Gable ends are not mandatory in the New Forest National Park Design Code, but they align with local vernacular and are appropriate when reflecting established built form. Deep eaves can be substituted with integrated features - such as bird bricks or nesting cups - to provide nesting opportunities for small bird species. Swift bricks, though designed for swifts, also support sparrows and other species, while house martins and swallows prefer nest cups. Best practice guidance in BS 42021 and CIEEM, as referenced within the policy's final paragraph, supports using wall-sited features, including nest cups where appropriate. |
| NatureSpace Partnership | Requests that reference is made to the NPA as holder of a Great Crested Newt Organisational (or District) Licence. | The supporting text has been updated to reference the District Licensing Scheme for Great Crested Newts. |
| Tor & Co. on behalf of the Cadland Estate (SP5 site promoter) | Considers that most, if not all, of the required BNG would be more suitable delivered through off-site provision, within the Cadland Estate’s wider landholding. | Comments noted. Due to the size of the site, it is anticipated that the full BNG requirement can be accommodated on site. Should this not be the case, the national system for BNG enables off-site delivery. |
| Individuals | Supports the policy’s aims, particularly the importance given to establishing coherent ecological networks. Concerns that developers can purchase BNG credits instead of on-site provision. States that universal nest bricks, which meet BS 42021, should be specified to ensure that swifts are able to utilise these. Does not believe that BNG is effective and queries the long-term monitoring process. States that greenbelt land should not be developed. | Support welcomed and comments noted. BNG implementation is subject to a strict hierarchical system set out by the Government. National BNG credits can only be purchased as a last resort, but on and off-site delivery is enabled by the national system. As the list of protected species is too long to include/list provision for, the policy now includes a range of biodiversity enhancement features that new developments will be expected to incorporate. Bird bricks are listed amongst these, and it is set out that these should be specified and located in accordance with best-practice guidance such as BS 42021 or CIEEM standards. The supporting text has been amended to note that universal nest bricks are the best option as they can be utilised by a variety of bird species. Habitats created or enhanced to deliver BNG are secured and managed for a minimum of 30 years through appropriate legal mechanisms such as Section 106 agreements and Conservation Covenants. A Habitat Management and Monitoring Plan is required from the applicant, and this sets out long-term management, monitoring, and remedial measures. Where BNG is delivered off-site, land is registered on the national register, and monitoring reports are required to be provided to the Authority to ensure compliance over the minimum statutory 30-year period. While it is incorrect to assume that the New Forest National Park contains greenbelt land, it does contain greenfield sites which the policies in the Local Plan seek to protect. However, New Forest District Council is affected by some greenbelt along the south-west boundary and have set out policies within their Local Plan to address how it is managed within their area of the New Forest. |
Policy SP14 – Landscape character
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Natural England | Welcomes consideration of the National Park’s natural beauty and special qualities. Welcomes and supports references to the New Forest National Park Landscape Character Assessment, and The Landscape Action Plan. | Support welcomed and comments noted. |
| Historic England | Welcomes reference to cultural heritage and suggests expanding criterion d) to reveal what is most important. | The policy wording has been reinforced to set out that landscape schemes should assist in supporting the significance of the New Forest's assets. |
| Hampshire County Council | Suggests that the contribution that landscape design can make to make to addressing climate change and aiding public health should be noted. | The supporting text has been amended to set out how landscape design should contribute to climate resilience and human health. |
| Copythorne Parish Council | Strongly agrees with criterion c) but has concerns that not all new development will be able to enhance the character of the New Forest’s landscapes. | Support for criterion c) welcomed and comments noted. |
| Landford Parish Council | Advises that support for the commoning community and free-roaming livestock is required to maintain the New Forest’s landscape character. | Comments noted. |
| Woodland Trust | Supports the aims of the policy, particularly that landscaping schemes should reinforce local character and use native plant species. Suggests that developers should be encouraged to use plants from UK sourced and grown stock to reduce the risk of imported pests and diseases, while reducing the carbon footprint of the supply chain. | Support welcomed and the policy wording has been updated to include reference to biosecurity measures. |
| Carter Jonas on behalf of Fawley Waterside Ltd | Welcomes the policy’s focus on placemaking and design. | Support welcomed and comments noted. |
| Lucid Planning (SP40 site promoter) | Shows support for the policy but contends that it should recognise that there will be some localised change in the landscape context where larger scale development is to take place. | Broad support welcomed. The supporting text for Policy SP14 acknowledges that the New Forest's distinctive landscape character is subject to pressure from a range of ongoing trends and influences, including development. While the draft Local Plan does not rule out large-scale development, it requires proposals to demonstrate that impacts have been avoided or minimised, with major development subject to additional criteria aimed at reducing harm. |
| Individuals | Support for the policy’s aims. Requirement for a professional landscape visual impact assessment (LVIA) suggested. Amendments proposed include adding ‘only’ to the second sentence and ‘surrounding’ to criterion c). | Support welcomed and the policy has been amended to set out that an LVIA is required for proposals that are significant in terms of scale and/or landscape impact. Amending the second sentence of the policy to read “will only be permitted” would not comply with the requirement for planning policies to be positively worded. However, the wording within criterion c) has been amended to read “between, within, and surrounding settlements”. |
Policy SP15 – Green & Blue Infrastructure
| Respondent | Summary of representation | NPA response |
|---|---|---|
| Environment Agency | Supports the policy aims but suggests that the supporting text makes more reference to water environments. | The supporting text has been amended to make greater reference to aquatic environments. |
| Natural England | Advocates noting the link between green and blue infrastructure (GBI) with Local Nature Recovery Strategies (LNRS). Proposes that the policy is divided into five interlinked policies setting out the five headline GI Framework standards. Suggests that the policy sets out clear expectations in terms of GBI provision, over and above the provision of open space. | While it is acknowledged that the policy wording should place greater emphasis on how green and blue infrastructure aligns with the LNRS, it is not considered necessary to introduce individual policies for each of the five headline Green Infrastructure Framework standards, as these standards have limited relevance to the New Forest National Park. Where applicable, their objectives are already will be reflected in the existing policy wording and supporting text for green and blue infrastructure and are addressed elsewhere within the draft Local Plan. Nevertheless, it is agreed that clearer expectations in relation to GBI provision, in addition to those already established for open space, should be set out and the text has been updated to reflect this. |
| Historic England | Suggests that an additional criterion should be included which acknowledges the potential multiple benefits to be delivered through integrated management of the historic and natural environments. | A new criterion has been included within the policy wording to recognise the need for integrated management of the natural and historic environment. |
| Dorset County Council | Suggests that there may be instances where provision of SANG within the National Park may be the most effective option to mitigate the pressures of development on internationally designated nature conservation sites. | SANGs are intended to divert recreational pressure away from sensitive sites by providing alternative locations for informal recreation. However, the National Park is itself a highly sensitive, designated landscape of national and international ecological importance, where increased recreational use can conflict with its statutory purposes. SANGs are typically located in areas of lower biodiversity value and often include managed features such as enhanced paths, signage, and parking to attract visitors. Such interventions and increased visitor numbers may be incompatible with the conservation objectives, landscape character, and ‘wild’ qualities of the National Park. SANGs are not precluded within the National Park, but as a principle they should be located close to the developments they serve. |
| Copythorne Parish Council | Supports cross-boundary and partnership working to develop green and blue infrastructure. Agrees that introducing Suitable Alternative Natural Greenspace (SANG) within the National Park, to mitigate the effects of new development beyond its boundaries would be inappropriate. | Support welcomed and comments noted. |
| Sway Parish Council | Welcomes the inclusion of blue infrastructure and increased emphasis on health benefits. | Support welcomed. |
| New Forest Association | Requests that reference to provision of SANG within the National Park under exceptional circumstances be removed from the policy wording. | It is not considered necessary to amend the final sentence of the policy wording. The policy does not anticipate the provision of SANG within the National Park but includes flexibility to accommodate genuinely unforeseen and exceptional circumstances and SANGs are not entirely precluded within the nationally protected landscape of the National Park. The NFNPA have no jurisdiction over other the geography of other local planning authorities and cannot set out that neighbouring districts should provide SANG to reduce recreational pressures within the Park. The assertion that the provision of Suitable Alternative Natural Greenspace (SANG) is “derived from dubious sources” is incorrect. SANG may be delivered and managed by a Council using developer contributions, or by independent third-party landowners. In some cases, large developments may provide their own on-site or off-site SANG where this can be appropriately upgraded to meet required standards. |
| Woodland Trust | Supports the policy aims of addressing connectivity, access, and habitat protection. | Support welcomed. |
| CPRE Hampshire | Supports the principle of the NPA working collaboratively with neighbouring authorities and agrees that SANG is not appropriate within the National Park. Suggests that the policy could recognise that back up grazing should be identified and designated to avoid conflict with other land uses. | Support welcomed and comments noted. It is considered that policy SP55 provides sufficient criteria to assess development affecting back up grazing land and provide long term support for agricultural land. Back up grazing is a resource that can move and change over time, as so it does not lend itself to being easily mapped on a Loal Plan that looks forward to 2043. |
| Individuals | Support for the policy’s aims and the importance of green and blue infrastructure for maintaining good mental and physical health noted. Inclusion of further information about blue infrastructure within the supporting text suggested. An additional criterion to address pressure from development on nature conservation sites proposed. Proposed that “nationally
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