Following the publication of the HS2 Select Committee’s report the Woodland Trust welcomes the Committee’s clear direction to HS2 that it needs to identify an independent third party arbiter to review its flawed ‘net loss’ metrics and this issue may need to be considered by the House of Lords. This point was pushed strongly by the Trust at its Select Committee hearing on February 3rd. It’s also good to see the Committee agree that any tree planting proposals must be formalised and clearly stated rather than simply an aspiration.
HS2 should have made more strenuous efforts to avoid the loss of ancient woodland. The Trust is against any inclusion of ancient woodland in a ‘no net loss’ metric. Irreplaceable habitat should never be included in a ‘no net loss’ calculation because it is impossible to achieve no net loss of biodiversity if this category of habitat is lost. Loss of ancient woodland should be compensated for on a transparent case by case basis.
(Page 74, 301)Shows the Committee suggests that HS2 are making decisions on environmental effects that they should not be deciding on solely and there is a call for an independent advisor on this.
Committee Member Mark Hendrick MP was so concerned about the lack of clarity and poor justification for HS2 Ltd’s approach to their ‘metrics’ for justifying their response to loss of ancient woodland and damage to biodiversity that he said: “Again, if HS2 are judging, or marking their own homework, as far these metrics and biodiversity is concerned, that’s not necessarily a good thing, is it?”
The Trust is concerned however to see that many of the key errors highlighted during the Select Committee hearing regarding the flawed preparation for the Hybrid bill by HS2 Ltd are not be mistakenly considered as best practice and could lead to unsatisfactory precedents. It is important that these be addressed in the forthcoming parliamentary stages:
- Use of translocation being touted as better compensation than planting of trees on non-translocated soils, despite there being no hard evidence to support this. The perceived higher quality of woodland planted on translocated soils is being used a reason to reduce the area of compensation proposed, the Woodland Trust refute this.
- No mention of compensation planting ratios in relation to habitat loss (including AW) the Trust requested a ratio of 30:1 for ancient woodland. The Committee asked HS2 what the proposed ratio was, HS2 were unable to do this at the committee hearing. This is still absent.
- Developments being designed without fully identifying the environmental baseline. The identification of valuable habitats late in the planning process results in amendments to the scheme being seen as difficult and too expensive to incorporate at a post-design stage. Loss of habitat is then accepted as inevitable and unavoidable.
- No commitment to buffering of ancient woodlands affected by the proposed scheme. It is often wrongly assumed by developers that ancient woodland is only affected by direct removal of vegetation and/or soil. This is incorrect. A project the size of HS2 should recognise the impact of indirect effects and subsequently provide mitigation to reduce these effects.
- Treating Planted Ancient Woodland Sites (PAWS) as having lower value than ASNW. PAWS and ASNW are both forms of ancient woodland and therefore both irreplaceable. If PAWS is treated differently in the case of HS2 then it risks a new precedent being set where it will be treated differently by every other developer in the UK, this is against current best practice.
- HS2 has unnecessarily constrained the area available for compensation planting by only looking at areas that fall within the area of the HS2 proposed plans. The Trust demonstrated in its evidence that there are a variety of voluntary schemes (not via CPOs) available that would have enabled HS2 to identify land outside its current plans to deliver better results for habitat protection and biodiversity.
- Potential increase in AW loss at Pinnocks Wood due to route being moved from a SSSi, which is just moving the destruction from one extremely important habitat to another.
- There are several areas where the potential for moving the route may have a more detrimental effect on AW loss than is currently stated. For example, Hunts Green (page 42, para 147).
Austin Brady, Director of Conservation at the Woodland Trust said:
“Ancient woodland is an irreplaceable habitat and its loss should always be avoided. Although it’s good to see the Committee’s recognition of the need to reassess HS2 Ltd’s flawed ‘no net loss’ calculations, much of the remaining corner cutting by HS2 Ltd in relation to ancient woodland has been ignored. In doing this, the Committee has missed an important opportunity to ensure this project is the very best example of national infrastructure with the best interests of the whole country, including the environment at its heart. We want to see these shortcomings addressed during the forthcoming parliamentary stages.”