Our response to the LVRPA’s draft Biodiversity Action Plan

Since its inception, Save Lea Marshes has banged on the LVRPA’s door and asked to join conversations about how the marshes are managed. Our entreaties have, largely, gone unheard. And then we discovered that the LVRPA was consulting on its draft Biodiversity Action Plan (https://www.leevalleypark.org.uk/en/content/cms/corporate/enhancing-the-valley/bap-consultation/) and we jumped at the chance to have our say. This is our response to the consultation.

Firstly, we welcome the opportunity for local people to comment on the Lee Valley Regional Park Authority’s plans relating to biodiversity, as this is something that has not happened as much as we would have liked in the past. There are, however, a number of issues with the plan as it currently stands. These are as follows:

1. This ‘plan’ contains many words describing the historical context and the current situation and very few words explaining exactly what you are planning to do. It is also missing all the maps. And without a clear understanding of exactly what you are planning to do – what your vision is and how you intend to move from the here and now towards that vision – it is almost impossible to provide cogent feedback (or, I would have thought, create SMART targets). The devil is in the detail, and we simply do not have the detail to comment on. To take just two examples:

    • You state that you want the community involved, but you do not mention how you intend to do this. As a group that represents the local community, we wanted to be able to comment on how likely your actions are to succeed, but we do not know what they are.
    • You state, ‘This species [creeping marshwort] will benefit from special management aiming to increase its cover, prevent it from being ousted by more vigorous competition and buffer it from extreme changes in water levels.’ Again, we might have been able to comment on the effectiveness – or otherwise – of your proposals for managing this species if you had provided them.

2. This plan does not explain how you intend to uphold the values of the biodiversity action plan in the face of conflicting pressures from other parts of the LVRPA. How will biodiversity be protected from, for example, plans to hold events on land managed as meadow or plans to sell off large swathes of green space for development?

3. It was challenging to determine why you have chosen to focus on the species and habitats you include in the plan. What is your rationale for including them? Your starting point, in most cases, seems to be to understand current distribution, but surely you already have such information to justify the inclusion of a species or a habitat? If not, would it not be worth taking a further step back and examining the diversity of species and habitats across areas of the park first, and then deciding which need their own action plans? If you do have such information, we would have liked to see it in the plan. Similarly, there is very little mention of the conservation status of the species and habitats that you mention, making it challenging for a lay person to determine whether or not your priorities should be challenged. For example, Barbel has been included because it is a good species to engage fishermen and the general public, whereas the European Eel – which you acknowledge is globally red-listed and is, from a conservation point of view, much more important – is not a priority for you.

4. This plan lacks a commitment to manage invasive non-native species without recourse to spraying pesticides and herbicides.

Save Lea Marshes would welcome further and fuller opportunities to engage in a meaningful way in developing a robust biodiversity action plan, that puts biodiversity and the protection and celebration of nature at the heart of the Lee Valley Regional Park’s vision, and look forward to hearing from you.

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