28th April 2010
Please Reply to:
1, Edenbridge Road, London E9 7DR

Rob Cairns, Head of Environmental Design, Lee Valley Regional park Authority, Myddelton House, Bulls Cross, Enfield EN2 9HG

Dear Rob,
Response to Walthamstow Marshes Landscape Design Framework and Proposals
This response has been prepared by the Lee Valley Federation. It is supported by the New Lammas Lands Defence Committee and Hackney Marsh User Group

General Comments
1. We strongly welcome this report and support the objectives set out in the brief as described in Pages 5 to 6 of the report. A landscape strategy which recognises in a comprehensive fashion the potential and the importance of the open space and landscape in the southern part of the Lee Valley Park is indeed long overdue.
2. The area embraced by the study (and any subsequent programme of work) is very unclear. The study is entitled Walthamstow Marshes Landscape Study but it also embraces, at the very least, Low Hall, Leyton Marsh, the Middlesex and Essex Beds, the Golf Course and the Old River Lea. However there are omissions (Millfields, St James's Park) and there are areas - Hackney Marsh and Walthamstow Reservoirs - where it is unclear whether they are covered by the study or not.
3.We consider that if the Park Authority is now embracing and articulating an ambition to preserve and enhance the landscape of the Lower Lee Valley, this should explicitly cover the territory at least from Ferry Lane to Eastway (as the area to the South has been pre-empted for the present by the Olympic Games).[1] This area:

**Is by far the largest area of continuous open space within easy reach of Central London;

**Can properly be characterised as regionally important (which we recognise is important from the perspective of the Park Authority);

**Can be a masthead for the Park Authority to match its achievement in Fisher's Green to the North;

**Will help to realise the Park Authority's objective to protect the Lee Valley as a green lung; and.

**Will strengthen the defence of the Park against development pressures.
4.We are extremely confused about the provenance of this document and which institutions have a stake in it. We are unclear how the document sits along side the Lower Lee Valley and Upper Lee Valley strategies and are concerned about the multiplicity of agencies, with differing objectives, which appear to be involved. We also think it regrettable that the Upper Lee Landscape Strategy appears to have been developed behind closed doors and has not been made available to the public. We note but do not fully understand the following passage:
The Marshes are the focus for a range of initiatives and opportunities being promoted by partner organisations. A number of these are associated with the development of the Olympic Park to the south, but others are in response to local development interest and pressure. Each of these initiatives has the potential to impact on the Marshes, and the Authority is seeking to ensure that all such initiatives can be brought together into a coordinated approach that will maximise the collective benefit for the area
We understand the remit of the Park Authority and we would like it to be made clear whether any of the bodies which have funded thus study; or any of the related studies, are pursuing objectives which may be contrary to the objectives of the Park Authority.
5.We have the sense from informal briefings provided to members of LVF and other organisations that there are other initiatives which are linked to but not explicitly mentioned in the current study. Examples which have been mentioned to us are:

**A path through the middle of Hackney Marsh from the Olympic Site to Lea Bridge. This is nowhere set out as a proposal in this study but there is reference to the connection between the proposed new bridge (proposal 2a) and the Hackney Marsh Central Path. This path also appears to be shown as a grey line through Hackney Marsh in the plan on Page 29. We would have significant reservations about this proposal, particularly if the path is intended as some form of hard edged gateway access. We are also rather uncomfortable to see a proposal of this magnitude introduced by this somewhat oblique reference. This underlines the concerns already referred to at 2 and 4 above.

**A cycle path between with West Warwick Reservoir and the railway crossing the Lee Navigation to Markfield Park (which we would wholeheartedly welcome).
We really think it would be helpful if the Park Authority could share the totality of its plans with its critical environmental friends and enlist their participation and support in the improvement of the area.
6.Whilst we consider that the report is generally admirably sensitive to the existing semi-wild character of the marshes and the adjacent areas, we have the sense that the Park Authority and other bodies at points feel a need to impose their own imprimatur, perhaps to create a distinctive brand for the area. (There are comments to this effect, which we disagree with, in the draft Park Development Framework.) Examples are the ambition to remake Sandy Lane and the Aqueduct Path with clay pavers, a Tarmac Black Path and possibly some sort of signature path through Hackney Marshes. We would urge the Park Authority (and other bodies) against expensive branding exercises of this sort. The best open spaces, such as Hampstead Heath, Epping Forest, Wimbledon Common, stand on their own merits without branding and the Park Authority should bear this strongly in mind.
7.A great deal depends on the support of other statutory (or privatised) bodies such as Railtrack, Thames Water and the Environment Agency. We appreciate that the Park Authority (and possibly other agencies) will need to conduct discreet negotiations with these bodies in order to achieve some of the ambitions set out in the Walthamstow Marsh Framework. However, we would also like it to be explicitly stated what are the Park Authority's ambitions to gain access to or through the estates of these bodies. This should be the start of an open and informed public debate about creating improved access and welding the entire area into a great open space for the public to enjoy.
8.We feel that the study ducks issues concerning Thames Water with respect to the Park Authority's ambitions for the Lea Bridge Depot (where the study proposes to reinstate the Black Path but omits any more comprehensive proposals).
9.We consider that there is a huge opportunity to enlarge means of access by bringing the paths beside the flood relief channel into public use[2] and we would like to see this explicitly stated as an ambition of the Park Authority.
10.We have a very great fear that the many excellent proposals contained in this study will now disappear from view - being deemed unaffordable. We would like to see a firm commitment entered into by the Park Authority to put a significant part of its development budget behind the realisation of this study. Priority projects should be identified, costed and - within the limit of available resources - programmed. We would like to see priority being given to: works which improve and increase the means of access such as the Low Hall access path (proposal 15b), and the parish Boundary Bath (proposal 10a) planting schemes to improve the landscape such as margin planting along the eastern fringe of the area. improvements to the Ice Rink/parking/Leabridge Road environment.
Conversely, we would like to see expensive projects such as the paving of Sandy Lane adjourned sine die.
11.Finally, we would like to see ongoing collaboration between the Park Authority and interested environmental groups in the improvement of this area. We note that the consultation over the present study has been somewhat mismanaged[3] and we hope for a positive and constructive dialogue for the future.
12.Finally, the eternal conflict between greater access for people and the encouragement of wildlife and biodiversity must be examined in greater depth.

Comments on Specific Proposals
1.Lammas Land to Back River We generally support the proposals.

We welcome the proposed new bridge across the Lea Back River at the Flood Relief intersection. This bridge would give excellent and desirable access from Waltham Forest to Hackney Marsh, and will in the long-term form a significant new route when combined with pedestrian footbridge access over the rail tracks to Orient Way where there is a significant area of future new housing proposed by Waltham Forest.

We oppose, however, the creation of another path along the Lea Back River on the golf course bank. Wherever a path is created, habitat is fragmented and lost. We believe this proposal is superfluous as there is already a substantial metalled path on the Hackney Marsh side of this part of the watercourse, and a parallel informal track at the lower floodplain level; these paths pass through a magnificent mature belt of trees forming the eastern edge of Hackney Marsh, and there are plans to further enhance the biodiversity of this zone under the Hackney Marsh Masterplan. Excellent views of a largely undisturbed river bank on the other side are available from these paths.
2.Aqueduct Path to Hackney Marshes We have strong reservations about proposals 2a to 2c.
2a, as we understand it would create a new bridge passing from the Middlesex Filter Beds to the Aqueduct Path. There are therefore proposals for four crossings of the River Lea namely the existing Friends Bridge, the new golf course bridge (proposal 1e), the Black Path bridge (proposal 5c) and the Filter Beds bridge (proposal 2a).
In general terms we are strongly in favour of improved means of access but we do not think that this fourth bridge is necessary or desirable. Firstly, it turns the Middlesex Filter Beds, which are both secluded and ecologically important, into a through pedestrian route for dog walkers and others. Second, the proposal to create a though route conflicts with proposals to increase the biodiversity of the northern part of Hackney Marsh. As we have already noted, the plans for a Hackney Marsh Central Path are nowhere explained in this document.
We feel that there needs to be tripartite discussion between the Park Authority, the London Borough of Hackney (which is developing a Hackney Marsh Master Plan) and Hackney Marsh User Group - but we do not in any event consider that this bridge is either appropriate or necessary.
3.Lea Bridge Road In principle, all of the proposals seem acceptable but we think that the proposal for secondary bridges would be extremely expensive and believe that other access improvements within the study area should be given higher priority as they represent better value for money.
We would very much like to see a scheme for access to the flood relief channel providing a new way of crossing between the areas to the north and south of Lea Bridge Road.
We are concerned at the proposal to tidy up the vegetation where the aqueduct path crosses Leabridge Road. Currently this ramp access under Leabridge Road provides a visual and acoustic break between the walking environment and the road and it is one of the merits of this link that the dense vegetation masks the perception of nearby traffic. We would not support any tidying up which opened up lines of sight and hearing between the path and the road, which we think would act to the detriment of the experience of walkers, runners and cyclists using this path.
See also comments at 4 below.
4.Sandy Lane + Ice Rink We note the proposal to reconfigure the Ice Rink Car Park (no details are provided).

We consider that the ice rink continues to disgrace the appearance of Leyton Marsh and ask that a scheme for screening the Ice Rink (which the Park Authority promised in its original application for planning permission) should be highlighted and given priority. It seems to us that the industrial design of the ice rink, the overly large car park and the poor quality of landscape maintenance and design have resulted in a disfigured and utilitarian landscape which strengthens the hand of developers seeking housing and other construction at the Thames Water and Essex Wharf sites.
We consider that the Park Authority should give priority to a high quality landscape scheme to improve views to the ice rink from both Lea Bridge Road and Leyton Marsh.
5.Black Path We agree that there would be some merit in making the Black Path a visible and continuous route across the Marsh, and we support the idea that there should be a new bridge (proposal 5c) across the River Lea at the northern end of the Middlesex Filter Beds[4] and the reservation of a path through the Thames Water depot.
We have strong reservations, or disagree with the following points: (a) The Park Authority seems to have a wish to create the path as a continuous bright line across the Park. We feel that there are corporatist/branding considerations behind this enthusiasm and we would strongly prefer to see a lower profile path. (b) Specifically, we strongly disagree with the proposal for a tarmac path which we think hard-edged and unnecessary. (c) We think that the creation of a north-east/south west alignment to the path around the paddocks would be of little benefit (although we are not adamantly opposed to this).
We also consider that the practical difficulty and cost of creating ramped access to the railway bridge is unlikely to be justified.
6.Aqueduct Path We do not see any advantage in clay pavers and feel that this would be a poor use of scarce resources available for improvement of the area. As already noted, we have reservations about tidying up the access to Lea Bridge Road - we do not oppose the principle but would urge that any tidying up be done with moderation.
7.Bridle Way We are very confused about the Park Authority's bridle way proposals as there seems to be a separate consultation exercise including many more new bridle ways than are contained in this document. We have also had somewhat conflicting versions as to what exactly is proposed for riding on Leyton Marsh and we are unclear which changes are proposed permanently and which experimentally.
We think it would be preferable if all the proposals were taken off the table and re-tendered in one clear consultation document.
8.East-West Path to South Paddocks Agreed
9.Green Path along Flood relief channel We agree with the proposal for a new path but we would urge the Park Authority to press for an additional path along the flood relief channel. It used to be quite easy in practice to gain access to the flood relief channel, e.g. for footballers using Low Hall playing fields to retrieve footballs[5]. We do not understand the safety case for fencing off the flood relief channel which is usually only a few inches deep (and is not intended for drinking) when the banks of the Lee Navigation are unprotected. We strongly urge that the Park Authority publicly endorses the objective of getting the flood relief channel open
10.Parish Boundary Agreed (but the pollarded trees appear to be poplars, not willows).
11.Leyton Marsh All agreed in principle.
12.Clapton Towpath Agreed that improvement needed including re-opening of the towpath opposite Essex Wharf but we would urge against over tidying up or use of clay pavers.
13.Path to West of Navigation - Millfields to Springfield Park We cannot really see that pavers are necessary, still less the colour coding to distinguish this path from the towpath. However, if this path needs to be re-formed for maintenance reasons, pavers would seem to represent an improvement in this case.
14.Walthamstow Marshes We have strong reservations about the proposed extensions of board-walks into the railway triangle and the North Marsh. These areas are already accessible on foot and whilst we recognise that access is more difficult in some ground conditions there is merit in keeping these areas comparatively secluded and increased access will be likely to reduce biodiversity. At the very least, we would ask for wildlife studies to be carried out before any decision is made to increase access to these areas.
Other proposals for this area are agreed.
15.Low Hall Paying Fields We are very strongly in agreement with the objectives expressed here and urge that the Park Authority corporately gives the very highest priority to tie in Low Hall playing fields with the rest of the Park. Low Hall currently feels private, isolated and not particularly welcoming and the activity of Thames Water and others in building fences in recent years has increased the sense of isolation from the remainder of the Park. We also note that the Park Authority context of St James's Park and Low Hall was completely ignored in the recent Parks and Open Spaces draft strategy issued by the London Borough of Waltham Forest. The integration of Low Hall and St James's Park would add very significantly to the area of continuous open parkland and increases the regional justification for devoting resources to the improvement of this area.
We would like to see more than one access from Low Hall to the Walthamstow/ Leyton Marsh area and would like the Park Authority to negotiate a southern access using the existing bridge over the flood relief channel.
We note that the Study proposes a new path along the flood relief channel linking to Elmfield Road and Coppermill Lane. This is a particularly welcome proposal which increases circular access possibilities (but begs the question why there should not be paths along the flood relief channel further to the south).
The study refers to intensifying the naturalisation of the playing field edge. We would observe that at present there is no naturalisation along the southern edge of the playing fields which are particularly harsh and unattractive and a planting scheme here should be given priority.
We consider that the area of trees between Low Hall and St James's Park to be interesting with an unusually diverse number of tree species and suggest some very light touch management plus a tree-spotting trail here.
16.Coppermill Works Agreed
17.Spring Hill Coppermill Lane We agree with these proposals and the idea of taking a path to the base of West Warwick Reservoir is an exciting opportunity. However, if there is a real possibility that West Warwick Reservoir is going to be opened to the public, then there are new and more ambitious access possibilities and we would very much like to know what discussions are tasking place on this point.
Coppermill meadows would benefit from planting on the eastern margin - but possibly this is covered in proposal 16b.

Finally, we very much look to further discussion as the proposals contained in this Survey are taken forward.
With best regards
Yours sincerely

Laurie Elks

[1] There is also a very strong case - perhaps in a second phase, for extending the programme northwards into Tottenham Marshes and adjacent areas.

[2] Obviously, exception can be made for times of flood or high water, when these paths should be closed for public safety.

[3] To be specific - at the last Park Users consultation meeting there was no reference to the totality of the Walthamstow Marsh Survey - only to very specific points in it and the existence of this document only emerged as a result of discussion between Laurie Elks and Dave Miller. The online document is also in parts unreadable.

[4] Although we would want to discourage the Filter Beds as a whole becoming a pedestrian though route

[5] This is a personal recollection from the times when I played football regularly at Low Hall