Memorandum submitted by the British Association
for Shooting and Conservation (DMB 45)
The British Association for Shooting and Conservation
(BASC) would like the following points to be considered by the
Environment, Food and Rural Affairs Committee.
1. BASC's view is that sufficient public
access exists on the English coastline. BASC questions why so
much money, time and effort is being spent on legislative proposals
for the creation and extension of access, when existing access
is poorly used and many access routes are in disrepair.
2. There are many instances where landowners
and occupiers have entered into voluntary or permissive new access
agreements, through the Countryside Stewardship Scheme and the
Higher Level Stewardship Scheme (HLS). New access under such schemes
is provided where there is a demonstrable need, and require that
the route does not impact on conservation objectives. Providing
new coastal access through targeted HLS agreements would ensure
new access routes were needed, cost-effective and well managed.
3. If coastal access is legislated for through
the Marine Bill, despite the lack of a demonstrable need and despite
the high cost to the taxpayer, then BASC has outlined the accompanying
points 4-14 in its views of the existing proposals.
4. BASC welcomes the publication of Natural
England's outline scheme for coastal access, to accompany the
coastal access provisions in the draft Marine Bill. The outline
scheme provides the key principles under which alignment of a
coastal trail would be based.
5. BASC welcomes a consultative approach
at a local level, with the first stage in that approach involving
landowners and occupiers, inclusive of those with shooting interests
on that land.
6. BASC welcomes the fact that the scheme
will not include provisions relating to "higher rights"
on the coast such as horse-riding or cycling, and seeks assurances
that this will be retained.
7. BASC recommends that members of the public
using the coastal "trail" be required to keep dogs under
close control and that dogs be kept on leads at all times on areas
of "spreading room". This would not include the use
of working dogs being supervised by landowners, occupiers or involved
in sporting shooting.
8. BASC welcomes the fact that with regard
to Natura 2000 sites Natural England will have a duty to carry
out an appropriate assessment (in accordance with the Habitat
Regulations) to consider the implications of a coastal `trail'
and an area of `spreading room' within such sites.
9. BASC welcomes recognition of the fact
that although some areas of mudflats and saltmarsh are used as
beaches by local people, more extensive inter-tidal areas of this
type are generally unsuitable for open-air recreation by the public.
10. Given the sensitive and dangerous nature
of mudflats and saltmarsh and the fact that wildfowling is managed
in these areas BASC recommends that these areas are defined as
excepted land for "spreading room" seaward or landward
of the "trail". In BASC's view this would be consistent
with Natural England's stated position that it does not regard
it as a priority to offer access to saltmarsh and mudflats.
11. BASC welcomes the inclusion of specific
guidance on shooting in the outline scheme, and the commitment
to work with shoot managers regarding access routes on land that
is shot over. BASC supports the alignment of any `trail' to the
seaward side of woodland managed for shooting and any land regularly
used for driven shoots. BASC recommends that shooting interests
need in general to be considered in terms of where the `trail'
is aligned—to be provided for in local consultation with
landowners and occupiers. BASC would like to see the same provisions
made for land used for wildfowling and rough shooting.
12. The proposed arrangements for limiting
occupiers' liability will still mean that additional costs relating
to managing access will have to be met by occupiers.
13. BASC welcomes the proposals for land
falling within paragraph 1 of CROW Schedule 1 as excepted land,
cropped land and intensive grassland. BASC seeks assurances that
the crops grown to benefit game and wildlife, which may remain
in the ground for two years, are also recognised as excepted land.
14. BASC recommends that fair and proportionate
compensation should be paid to landowners where a new coastal
"trail" and/or "spreading room" is legislated
for on their land.
Dr Conor O'Gorman
Land Management Policy Officer
The British Association for Shooting and Conservation
May 2008
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