HS2 Position Statement

HS2 Position Statement

(c) Hugh Clark

UPDATE 28th June 2023: We signed the Wildlife Trusts’ open letter to the Secretaries of State for the Environment and for Transport in February 2023. The letter calls for a recalculation of the biodiversity assessments for Phases 1 and 2a as well as a pause on the legislation for Phase 2b. This is because the Wildlife Trusts’ analysis suggested that the calculations were underestimating the value of existing habitats (such as field trees, ponds, watercourses and hedgerows) and overestimating the value of planned compensatory habitats. This is very concerning as not only could valuable roosting and foraging habitat be lost or degraded, any created habitat may be inadequate in mitigating or compensating for the damage done. We agree with the Wildlife Trusts’ asks and we hope to see a good outcome for bats and their habitats along the route.

POSITION STATEMENT: At the Bat Conservation Trust (BCT) we know that wildlife protection can be balanced alongside economic and social priorities, including major infrastructure and development projects. However, this is dependent on careful forward planning, highly professional standards and the application of best practice. As a government funded scheme HS2 has the opportunity to be an exemplar of how this can be achieved, not only of civil engineering but also of managing and successfully avoiding, mitigating and (as a last resort) compensating for any adverse impacts on the natural environment and providing enhancements that are secure in the long-term. There is a growing body of evidence that protecting natural landscapes benefits the health and well being of people as well as providing space for wildlife.

As Professor Sir Partha Dasgupta, who leads the Government’s independent review on the Economics of Biodiversity, recently stated “Our economies, livelihoods and wellbeing all rely on nature, from the food we eat, to controlling our climate, regulating disease and as a place of recreation. Without nature, there would be no life.”

Destruction of Ancient Woodland

BCT’s previous position statement and update on HS2 highlighted our concerns in relation to the impact of ancient woodland loss on bats. We continue to be concerned with the inadequacy of proposed compensation (translocation of ancient woodland soils and new planting) due to very slow maturation rates and the need for habitat continuity for species reliant on ancient woodland features, including some of our rarest bat species.

Following completion and publication of the Oakeree Review on 11 February 2020 the Prime Minister gave the go ahead for HS2 to proceed.

The Oakeree Review acknowledged that ‘planting new woodland is not a direct replacement for removing areas of ancient woodland’ (para 6.17) and Conclusion 8 of the report states: Conclusion 8: The Review recognised the impact of HS2 on woodland, landscape, biodiversity and more broadly on built and natural environments. Given the duration of the HS2 project, such impacts, along with any accompanying mitigation and compensatory measures, need to be kept under review. The report also acknowledges that adverse impacts arising from the permanent removal of ancient woodland are not fully captured in the report and in the benefit-cost ratio (para 11.13).

The Woodland Trust has raised concerns and campaigned extensively regarding the loss of ancient woodland on the HS2 route. They report that Phase One of HS2 will directly affect 32 ancient woodlands and indirectly affect 29 others.

Whilst BCT is not against major infrastructure development in principle we remain concerned about the extent of ancient woodland losses on the HS2 route and the impact of this on bats and other species.

Removal of Ancient Woodland in Warwickshire in April/May 2020

HS2 Ltd. issued a formal ‘notice to proceed’ with construction on 15 April 2020. Felling of ancient woodland in Warwickshire started soon after.

The Woodland Trust has raised some key points regarding these works:

  • The removal of ancient woodland in Warwickshire in April and May 2020 will have had a devastating impact on wildlife (including nesting birds and breeding badgers) and limit the efficacy of proposed compensation measures such as translocation of ancient woodland soils due to inappropriate timing.
  • This work is against all professional advice and should have been carried out in the autumn, as per commitments made by HS2 Ltd. during the Hybrid Bill process.

Reports we have been receiving about potential disturbance and damage to bat roosts in trees during the maternity season in Warwickshire woodlands (Kenilworth Sites) due to HS2 Phase One construction is a cause for concern for BCT. We are seeking further clarification around the licence and around practice on the ground during felling as we have some specific concerns. See HS2 Phase One Construction Cause for Concern.

UPDATE 25th March 2021: HS2 has informed us that they have used a new, alternative method to survey some of the woodlands on the HS2 route and that this informed the licensing decisions taken (such as allowing works during the early part of the maternity season in some of the Warwickshire woodlands). We have not had the opportunity to assess this previously untested approach but it is approved by Natural England. BCT is organising the UK Bat Steering Group this year on the topic of tree/woodland surveys and mitigation, which will include discussion about this approach. The Woodland Bat Technical Advisory Group, made up of experts in the field of tree-roosting bats and surveys/mitigation, will be invited to the meeting. We hope that this will bring further clarity to the issues around surveying and mitigating for bats in trees and woodlands.

Next: BCT’s Position Statement on the Proposed Norwich Distributor Road Western Link