Written evidence submitted by The Wildlife Trusts

Executive Summary

• The Wildlife Trusts believe that the HS2 Phase 1 Environmental Statement does not reflect the route-wide environmental impacts and is so seriously deficient as to be inadequate. 

• The Wildlife Trusts believe the Environmental Statement is not fit for purpose and is unacceptable given the scale of HS2. 

• Despite the stated intent of HS2 Ltd that the development should result in ‘no net loss to biodiversity’, and based on the incomplete evidence presented in the Environmental Statement, it is clear that the result of constructing the railway will damage and destroy more wildlife habitat and populations of wild species than will be replaced.  The consequence of building HS2 Phase 1 will be a net loss of biodiversity. 

• However, HS2 does provide an opportunity to be an exemplar in how a major infrastructure development can be used to restore the natural environment.  The Wildlife Trusts would like to see a much more ambitious and integrated strategy for mitigation and compensation along the route that considers not only the direct impacts but how mitigation and compensation can be used to improve the wider landscape by buffering and linking existing habitat to protect, restore and enhance ecological networks. 

• The Wildlife Trusts own research shows that significant investment in green infrastructure, habitat restoration and creation as part of HS2 is both affordable and cost-effective. 

Background and introduction

1. There are 47 Wildlife Trusts across the whole of the UK, the Isle of Man and Alderney. We are working for an environment rich in wildlife for everyone. With more than 800,000 members, we are the largest UK voluntary organisation dedicated to conserving the full range of the UK’s habitats and species whether they be in the countryside, in cities or at sea. More than 150,000 of our members belong to our junior branch, Wildlife Watch. We manage 2,300 nature reserves covering more than 90,000 hectares; we stand up for wildlife; we inspire people about the natural world and we foster sustainable living. The Wildlife Trusts have a collective vision to create A Living Landscape and secure Living Seas for the whole UK.

2. The Wildlife Trusts welcome the Environmental Audit Committee inquiry into HS2 and the environment and the opportunity to comment.  We would also welcome the opportunity to give oral evidence to the Committee. 

3. The Wildlife Trusts have an agreed position on High Speed Rail 2[1].  We recognise the need for an efficient and sustainable transport system and we support moves to a low carbon economy.  We therefore take the view the High Speed Rail has the potential to be part of the nation’s sustainable transport and communications system. 

4. Phase 1 of the proposed HS2 route directly affects the following seven Wildlife Trusts:

a)      London Wildlife Trust

b)     Herts and Middlesex Wildlife Trust

c)      Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust (BBOWT)

d)     The Wildlife Trust for Bedfordshire, Cambridgeshire and Northamptonshire

e)      Warwickshire Wildlife Trust

f)       The Wildlife Trust for Birmingham and the Black Country

g)     Staffordshire Wildlife Trust

Extent to which specific route-wide environmental impacts are adequately reflected and addressed in the Environmental Statement

5. Based on the evidence we have accumulated, including evidence gathered by the individual Wildlife Trusts directly affected by the HS2 Phase 1 preferred route, it is clear that the HS2 Phase 1 Environmental Statement does not reflect the route-wide environmental impacts and is so seriously deficient as to be inadequate.

6. The Wildlife Trusts believe the Environmental Statement is not fit for purpose and is unacceptable given the scale of HS2.  We are concerned that the ecological baseline is incomplete and has been compiled using methodologies which do not meet standards that could be reasonably expected.  There is a general impression that the work has been rushed, and that had more time been allowed to compile ecological baseline information, then the final Environmental Statement could have been more complete. This would have provided a more robust evidence base and assessment of likely impacts:

a)   upon which to develop measures to mitigate and to compensate for the expected impacts; and

b)   upon which Members of Parliament may reach a properly informed decision on the way to proceed at Second Reading of the HS2 Hybrid Bill.

7. The Environmental Statement contains incomplete survey information and data collection and therefore the ecological baseline data is incomplete.  From the information provided, it is unclear whether surveyors have visited many of the sites potentially affected.  In those areas that have not been surveyed, the approach is described as “precautionary” but appears to rely on informed guesswork.  It also appears that the “precautionary” principles have not been applied consistently resulting in features either being undervalued or omitted from the impact assessment.  BBOWT has estimated that approximately 64% of the entire route for HS2 has not been surveyed for protected species and for wildlife habitats.  Whilst in Staffordshire, just 63% of the sites within Community Forum Area (CFA)16 to CFA22 that were proposed for more detailed NVC survey were surveyed. 

8. Section 9.5.5 of the Environmental Statement states:

“The assessment will consider all ecological receptors with the potential to be directly or indirectly affected by the Proposed Scheme, including sites designated for their nature conservation value, legally protected or otherwise notable species, and habitats.” [our emphasis]

However, in Staffordshire, only legally protected mammals have been surveyed for and assessed.  This means that impacts to several key mammal species (e.g. brown hare, harvest mouse) have not been assessed at all and there is no mitigation or compensation proposed for them.

9. The Environmental Statement fails to appropriately take into account non-statutory sites (e.g. Local Wildlife Sites).  For example, in some instances, they are omitted entirely and in others seen as proposed areas for habitat creation where habitat already exists. 

10. The survey methodologies and effort applied during the baseline surveys do not appear to be consistent with the agreed approaches set out in the Scope and Methodology Report (SMR) Addendum Report: Ecological Field Survey Methods and Standards[2].  The Volume 5 Ecology Data Reports[3] show evidence of sub-optimal survey timings, poor site selection and patchy completion of survey work along the route.  The Environmental Statement should also set out more clearly the precautionary approach being undertaken where full surveys have not been possible. 

11. As an example, BBOWT commissioned a review of the approach taken by HS2 Ltd to assess the possible impact of HS2 on the Bechstein’s bats and also the impacts of the mitigation proposals.  The review[4], carried out by the University of Leeds has found that unless major changes are made to the route, HS2 (including the mitigation proposals) could result in the local extinction of one of the UK’s rarest mammals. 

12. HS2 Ltd has failed to make available GIS layers that include important spatial information such as the extent of land required; where HS2 Ltd has undertaken surveys; and areas proposed for landscape and ecological mitigation and compensation. 

13. The Environmental Statement has not considered changes to the baseline brought about by positive action for nature conservation.  The Wildlife Trusts ‘believe that the statement for Future Baseline: Operation (Year 1 2026) in the CFA documents of “There are no known committed developments or changes to management in this [area] that will affect the operational baseline” is misleading as it should also include environmental trends’.  Not only is climate change a trend, but future changes in agri-environment schemes, water abstraction licencing, species declines or expansions, planning biodiversity enhancement projects are all factors that should have been considered when judging the significance of impacts over the life of the scheme. 

14. The Wildlife Trusts (and others) have identified significant areas where we are taking a landscape scale approach to restoration of the natural environment (see Annex 1).  This is both through a series of Living Landscape schemes (TWT-led landscape scale approach to nature conservation) and also areas that have been identified for restoration based on existing biodiversity opportunities.  It is not just The Wildlife Trusts that are taking a more restorative approach to nature conservation and many partnerships are developing their own landscape-scale approaches.  As a result of the actual and planned work in these areas there will be improvements to the environmental baseline.  However, omitting reference to these approaches within the Environmental Statement provides clear evidence of the lack of knowledge about the ecological landscape effects of HS2. 

15. The Environmental Statement also fails to assess the cumulative and in-combination impacts on the landscape as a whole.  The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 specify information for inclusion in an Environmental Statement and includes reference to the cumulative effects of development. 

16. There has been inadequate consideration of the losses of numerous small scale features of importance to both people and wildlife such as tree lines, hedgerows, field margins and ponds.  Nor is there any evidence to suggest that the impacts on ecological network function and resilience have been investigated or dealt with at all within the Environmental Statement. 

17. It appears that HS2 Ltd has selectively reported data and/or not included all the information available to them including data from Local Biological Records Centres (LRCs).  LRCs are organisations that hold and disseminate vast amounts of information relating to the biodiversity of a region.  It also seems that, for some of The Wildlife Trusts along the route, the input and advice they have provided to HS2 Ltd during earlier stages of the consultation process has been ignored. 

18. Within the Environmental Statement, no cross reference is made within the ecology impact assessments to impacts in other sections such as agriculture, forestry and soils, land quality, or water resources, which might also impact on ecology. 

19. Whilst the Environmental Statement considers the impact on noise and disturbance, there is no consideration or mitigation for how these impacts might affect a site in terms of its use as a nature reserve.  For example, at BBOWT’s Calvert Jubilee Nature Reserve, HS2 Ltd do not appear to have considered that there is any significant effect on the value of the site as a nature reserve from the noise and intrusion from both the line (along the length of the site) and the proposed maintenance depot (at the northern end of the reserve).  In addition, the route will cut through the Colne Valley.  This is the first significant area of countryside to the west of London and provides thousands of people with a local opportunity to experience and engage with nature. 

20. The non-technical summary of the Environmental Statement suggests that HS2 will achieve ‘no net loss of biodiversity’.  For example, it states “In line with Government policy, HS2 Ltd is seeking to achieve no net loss in biodiversity.”  However, it contains very minimal information and includes only examples rather than a summary of all the impacts and measures to be undertaken.  There is no reference made at all in the non-technical summary to there being a significant resident effect on barn owls of the proposals.  The proposed mitigation amounts to no more than a promise to talk to landowners about providing alternative nesting sites. 

21. We would go as far as to say that, based on the information provided, it is impossible to gauge the full ecological consequences of HS2 from the published Environmental Statement. 

Overarching systems and processes which will guide how environmental considerations are taken into account

22. The Government’s Natural Environment White Paper[5] (2011) states very clearly that “the Government wants this to be the first generation to leave the natural environment of England in a better state than it inhered” and that we need to create a “resilient ecological network across England” (pg 3).  It went on to say “We will move from net biodiversity loss to net gain, by supporting healthy, well-functioning ecosystems and coherent ecological networks”.  The National Planning Policy Framework[6] (2012) also stated “pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people’s quality of life, including (but not limited to):.. moving from a net loss of biodiversity to achieving net gains for nature”.  In addition, HS2 Ltd’s own sustainability policy makes a commitment to achieving no net loss of biodiversity across the delivery of the HS2 project[7]. 

23. The consequence of building HS2 Phase 1 will be a net loss of biodiversity.  Despite the stated intent of HS2 Ltd that the development should result in ‘no net loss to biodiversity’, and based on the incomplete evidence presented in the Environmental Statement, it is clear that the result of constructing the railway will damage and destroy more wildlife habitat and populations of wild species than will be replaced.  For example:

• In Warwickshire, Coventry and Solihull it has been estimated that four per cent of all the Local Wildlife Sites will be adversely affected as a result of HS2 including many that will be lost entirely or subject to significant and permanent degradation. 

• In Birmingham, the route and construction will destroy up to 80% of The Wildlife Trust for Birmingham and the Black Country’s Park Hall Nature Reserve.  This is a significant loss to the local community, to the Wildlife Trust, for the habitats and species and for Birmingham’s ecological networks.  The floodplain grassland on the site is being lost due to re-routing of the River Tame and utility infrastructure diversions.  The current floodplain will be dug out for flood alleviation, also leading to reductions in the area of neutral grassland and consequent quality, very limited mitigation for the loss of 17 ponds and ditch habitat, no confirmation of marshy grassland or swamp habitat mitigation and no mitigation for hedgerow loss. 

• In London, the London Wildlife Trust has estimated that approximately 150ha of wildlife habitat will be lost or damaged by HS2 in London.  In terms of mitigation, HS2 Ltd has offered to create just 97ha of new or enhanced habitat.  This leaves a net loss of 53ha (roughly equivalent to St James’ Park and Green Park combined).

• The CFA7 report lists approximately 25.9ha of woodland habitat to be lost from within the area.  However, another part of the Environmental Statement states that approximately 30ha is due to be lost.  A total of 19.5ha of woodland is to be created for this loss.  So, irrespective of whether 25.9ha or 30ha is to be lost, there is still inadequate compensation. 

• In the Colne Valley, an impact on 19ha of semi-natural broadleaved woodland, scrub, wetland and grassland is linked to 3ha of compensatory habitat – a net loss of 16ha for one localised loss.  The cumulative effect of further examples along the route could be enormous

24. The Wildlife Trusts are also concerned that appropriate consideration has not been given to the importance of the presence of habitats and species along the full route.  For example, the Environmental Statement acknowledges that some species may be uncommon in London but this is countered by statements that they are widespread elsewhere and therefore not worthy of consideration. 

25. Throughout the Environmental Statement, the terms ‘mitigation’, ‘compensation’ and ‘enhancement’ are used interchangeably.  In addition, there are examples where mitigation and compensation proposals have been combined and overlapped.  There are also inconsistencies between the compensation areas described and those annotated on the map.  This means it is not possible to establish whether all impacts have been fully and appropriately taken into account and mitigated or compensated adequately.  For example, almost half of the Fox Covert Local Wildlife Site (in Northamptonshire) will be lost but it is not clear from the map books where the compensatory woodland planting will occur.  There are also instances where mitigation and compensation are double-counted. 

26. Whilst we believe that the amount of mitigation and compensation proposed is insufficient, we have also identified instances where the proposals are inappropriately located.  For example, woodland creation has been proposed on wetland on the Broadwater Lake Nature Reserve where Herts and Middlesex Wildlife Trust resources and conservation funding has previously been spent on removing scrub and trees to improve the wetland habitat interest and enhance the visitor experience.  Shallow reedbed margins provide vital wetland habitat for birds and it is the nationally important populations of these birds that mean the reserve is designated as part of the Mid Colne Valley SSSI.  In another example, at Lower Thorpe (Northamptonshire), the proposed mitigation includes wet grassland on an area that is existing open water.

27. In addition, there are instances where habitat ‘creation’ is proposed but, at that location, the habitat already exists.  It is unacceptable to claim a gain, or even compensation for loss, of biodiversity in these circumstances.  This should more correctly be defined as enhancement. 

28. Ideally, HS2 Ltd should aim to provide net gain for biodiversity especially given the scale and timeframe of construction and operation and the uncertainty of some of the overall impacts such as cumulative effects. 

29. The scale (construction, geography) of HS2 provides an opportunity to be innovative in terms of restoring the natural environment as part of a major infrastructure project.  HS2 should be aiming to provide compensation through taking a landscape-scale approach focusing around areas of existing biodiversity value and following the principles of landscape-scale conservation advocated in both Making Space of Nature[8] and the Natural Environment White Paper[9].  Instead, HS2 will slice through areas where The Wildlife Trusts’ and partners are working to restore the natural environment and create ecological networks jeopardising opportunities for future restoration and enhancement.  Habitat fragmentation is a significant driver of wildlife decline.  HS2 threatens to exacerbate the issue through the loss of ecological connectivity. 

30. There are some proposals to create linear habitat areas alongside the route but further consideration should be given as to how these can reduce fragmentation and re-instate ecological connectivity.  In many instances, there are features along the route corridor that have the potential to be linked to the wider natural environment.  However, HS2 Ltd appears to have restricted focus to just the route rather than within a buffer zone or the route’s footprint. 

31. The Wildlife Trusts would like to see a much more ambitious and integrated strategy for mitigation and compensation along the route that considers not only the direct impacts but how mitigation and compensation can be used to improve the wider landscape by buffering and linking existing habitat to protect, restore and enhance ecological networks.  HS2 to aim to provide compensatory habitat at a landscape scale, focusing around areas of existing biodiversity value. 

32. The Wildlife Trusts own research shows that significant investment in green infrastructure, habitat restoration and creation as part of HS2 is both affordable and cost-effective.  We believe that major infrastructure projects, like HS2, should be used to create Living Landscapes, rather than destroy their potential. 

33. At a series of workshops, staff from the various individual Wildlife Trusts identified areas where there are opportunities, through habitat creation, to increase the size, or improve the quality, of existing habitat patches and establish continuous corridors between them.  Subsequent work has identified the most necessary and cost-effective of these to deliver a reasonable and practical vision for HS2.  This shows how large development can be used to aid the restoration of the natural environment and how it can be a catalyst for further habitat restoration. 

34. The Wildlife Trusts commissioned environmental economists at Newcastle University to carry out a scoping assessment of the approach taking into account the fixed and marginal costs and benefits.  The Cost-Benefit Assessment shows that, relative to the scale of HS2, the enhancement of ecological connectivity is both affordable and delivers a significant return on investment. 

35. In light of the deficient ecological baseline, we could in principle welcome the commitment to long-term monitoring of the direct and indirect effects of the scheme on biodiversity and the efficacy of any mitigation and habitat creation measures over the lifespan of the project.  However, in the absence of any detail of the proposed monitoring regime, we cannot determine how effective this might be. We are thus obliged to reserve judgment until more details on this have been published.  Without an effective monitoring framework there is inadequate assurance that appropriate monitoring standards will be applied. 

How and where biodiversity offsetting will operate

36. The Environmental Statement commits to the principle of using biodiversity offsetting as a means to assessing the relative biodiversity losses and gains of the scheme and to determine if the HS2 Ltd’s stated objective of securing no net loss of biodiversity is achieved overall.

37. Reference is made in the Environmental Statement to the use of a modified biodiversity offsetting metric and that relevant parties will be provided with additional documentation to show the conclusions of the calculation.  However, despite the individual Wildlife Trusts being directly affected by the route and therefore relevant parties, HS2 Ltd has still not provided information on their approach to the use of biodiversity offsetting.  Without HS2’s report on the offsetting process used to assess the adequate level of compensation provided, or supporting GIS layers, being available during the Environmental Statement consultation phase, it is impossible to assess if compensation for the loss of habitats along the route is adequate and there is insufficient support or justification for many of the conclusions presented. 

38. Warwickshire County Council has undertaken a review of the scheme using Habitat Biodiversity Audit data and the metrics from the Warwickshire, Coventry and Solihull Biodiversity Offsetting Pilot Scheme.  The results reveal that, when taking account of construction, mitigation and compensation, the scheme would result in a significant loss of biodiversity equating to a shortfall of up to 1,400ha of habitat in Warwickshire alone. 

39. Analysis of the information that is available, and provided within the Environmental Statement, suggests that HS2 Phase 1 will result in substantial losses of biodiversity assets and an overall net loss of biodiversity.  The Environmental Statement provides an inadequate assessment of impacts and provides insufficient mitigation and compensation for even those impacts which are identified. 

Annex 1

Important areas where actions are under way to enhance and restore wildlife assets and which are at risk of detrimental impacts by HS2 Phase 1. 

10 March 2014

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