It’s less than 3 weeks since I gave evidence to the Environmental Audit Committee (EAC), yet the Committee has done an excellent job to produce an authoritative report ahead of the Second Reading of the High Speed Two (HS2) Hybrid Bill. The Committee asked pertinent and searching questions to tease out vital evidence from the panels they invited to give evidence, and I’m delighted to say their report reflects their rigour during the committee sessions.
A key concern we highlighted with the Committee was that due to incomplete surveying of ancient woodland, the Environmental Statement gives only a partial picture of the true environmental impact of HS2, a concern which was backed up by the HS2 Ecology Technical Group (a coalition of ecological experts from the councils affected and NGOs) written evidence, and agreed by Natural England during their evidence session. We dispute the claim made in the Environmental Statement that 19 ancient woods will be directly effected in the construction of the scheme. Our in-depth analysis has demonstrated that 27 ancient woods are directly affected, with a further 21 ancient woods likely to suffer damage from noise, vibration, changes to lighting and dust. In addition, we have found a further 23 woods which will be impacted which we believe to be ancient but are not listed on the Ancient Woodland Inventory.
The Committee echoed concerns about the quality of the ES’s baseline data and have recommended that:
“HS2 Ltd must carry out outstanding environmental surveys as soon as possible. It should focus particularly on cataloguing all ancient woodland and protected animal species, and as much as possible of the 40% of the route yet to be examined by involving local wildlife groups where possible”.
In both our written and oral evidence we highlighted the need for Government to strictly follow the mitigation hierarchy, the Committee strongly supported this and noted that:
“Damage to ancient woodland, an irreplaceable resource, also raises the questions of proper application of the environmental ‘mitigation hierarchy’: compensation measures should only be implemented as a last resort, if adverse effects cannot be avoided or mitigated. The Committee calls upon Parliament to ensure that the mitigation hierarchy will be followed fully”.
We also outlined a core concern that mitigation and compensation are consistently used incorrectly within the ES with regard to ancient woodland, which is irreplaceable and, as such, any attempt to compensate will only ever be just that – no amount of new planting will ever fully replace what has been lost. Addressing this, the Committee have recommended:
“The HS2 Environmental Statement must be revised to distinguish clearly between ‘mitigation’ and ‘compensation’ measures in respect of biodiversity, and to explain the factors determining in which cases these should be applied. If biodiversity loss is genuinely unavoidable and also cannot be mitigated, compensation measures should be applied to the fullest extent possible.”
The Committee supported our concerns that any future drive to cut the overall budget for HS2 will have a disproportional impact on environmental outcomes, as these will be seen as non-essential. They have recommended that:
“There needs to be a separate ring-fenced budget for these safeguards and for compensation, separate from the rest of the HS2 budget, to prevent the environment being squeezed if HS2 costs grow”.
We highlighted our concerns about a lack of long term strategy to monitor and maintain planted sites. The Committee took this on board and recommended that:
“Government should establish a process to monitor all aspects of the environmental protections needed for HS2 for the 60 years following the start of construction and operation of the railway, including biodiversity mitigations, compensations and offsets. This process must be managed by an independent body, which should be tasked with monitoring and publicly reporting progress against the ‘no net biodiversity loss’ objective”.
The Committee also shared our concerns about HS2 Limited’s proposals to include Ancient Woodland within the scope of their offsetting proposals. The Committee recommend that:
“If the offsetting metric is used to determine compensation for ancient woodlands on the HS2 route, these habitats should receive the maximum score possible on all criteria (distinctiveness, condition and position within ecological networks) to recognise their irreplaceability and to maximise the extent of the offsetting provided. But ancient woodlands should be treated separately from the overall biodiversity ‘no net loss’ calculation”.
It seems appropriate to end with a quote from Joan Walley MP, Chair of the Environmental Audit Committee, which sums up perfectly the Committee’s core concerns:
“The Government needs to show real commitment to dealing with the impact that HS2 will have on our countryside and wildlife. Ancient woodlands and other hard to replace sites of natural value should not be subordinated to crude economic calculations of cost and benefit.”
You can read our press statement in full on our website. HS2 demonstrates that ancient woodland is not adequately protected and is not treated with sufficient respect in big national planning cases. Even if you are not directly affected by HS2, you can still give a voice to precious ancient woodland by taking action and joining us in telling David Cameron “enough is enough!” – ancient woodland must be given the protection it deserves.