9th January 2014
BCT Initial Response - HS2 Environmental StatementThe Bat Conservation Trust works to ensure that the needs of bats and other wildlife are considered alongside economic needs, such as major infrastructure projects. We believe that a balance between these two areas is possible, but that achieving this balance is dependent on high professional standards.
The HS2 proposal has the potential to significantly impact national populations of bats and the habitats they are associated with such as ancient woodland. In order for the HS2 project to meet conservation objectives and comply with legal requirements the proposals within the Environmental Statement must satisfactorily mitigate for any adverse impacts.
Dr Carol Williams, Director of Conservation, BCT: 'We are concerned at the inadequate standard of surveying that supports this Environmental Statement. Also of concern is the interpretation of the survey findings into flawed proposals to negate impacts. This is particularly evident when considering the losses of ancient woodland.'
BCT have reviewed the Environmental Statement (ES) and will be compiling a more detailed submission to the consultation in due course.
Part of the drafting of the final response will involve the input of local knowledge from groups with more site specific understanding of the implications of these proposals.
The following points outline our initial concerns:
1. Ecological impacts, in particular impacts to rare bat populations of national importance, should be given due regard The Non Technical Summary outlines the ecological impacts for each Community Forum Area. Only the impacts that are deemed most significant are detailed within the document. Bats do not get a specific mention in any of the Community Forum Area summaries.
BCT is concerned by this as the associated reports state that nationally important populations of Bechstein's bats will be significantly impacted by the development. Failure to identify this within the report suggests that these impacts are not being given due regard within the development process.
2. The difference between mitigation and compensation should be addressed especially when referring to irreplaceable habitat BCT is concerned that irreplaceable ancient woodland will be lost and that the ES states that compensatory planting will mitigate for the loss and in some instances enhance the area. This is misleading in a number of ways. Fundamentally it fails to acknowledge the difference between compensation and mitigation, which is a recurring theme within the ES. Most importantly, it falsely suggests that a complex habitat such as ancient woodland can be simply recreated. Such compensation is not appropriate for irreplaceable habitats. Additionally, it is not appropriate for the species associated with ancient woodland as they cannot be compensated for in this way when such large timescales are required to achieve any sort of mature woodland.
3. Decisions should always be based on sufficient robust survey data If the projected impacts on the bat populations are to be negated successfully, the design process must work in parallel with the ecological considerations highlighted by the baseline surveys. It is therefore essential that sufficient survey data is collected and reviewed. In some instances it is clear that affected areas have not been surveyed at all or in other instances that insufficient survey effort and at times inappropriate survey techniques have been employed. On such a major project, with equally major potential ramifications for bats and other wildlife it is vital that high professional standards are maintained.
4. The construction phase should be subject to the same rigour particularly in relation to lighting The impact of lighting on bats is likely to be most acute in the construction phase. Consideration of the impact of lighting on bats needs to be fully acknowledged within the ES, alongside appropriate proposals that will mitigate for any significant impacts, both for the construction phase and in the longer term
5. Mitigation for bat crossings should be started as early as possible to allow habitat to establish Measures should be put in place wherever possible to retain habitats with slow maturation such as broadleaved woodland. This applies to important features such as hedgerows, woodland and tree lines used by bats as commuting routes. Replacing or diverting these routes will take careful execution, the success of which is largely dependent on the use of established habitats. The design and location should be based on robust survey data.
6. Provisions should be made to ensure mitigation is maintained for the long term The on-going management and monitoring of habitat is an essential part of successful mitigation. This should be enabled by the provision of support through dedicated funding and resources to whomever the land is entrusted, particularly if ownership is passed to a third party such as a nature conservation body. Likewise, dedicated resources should be identified that will enable the future management of compensatory habitat and monitor the long-term impacts of the scheme.
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