HS2 Phase 2 consultation response

Our response to the government's HS2 Phase 2 consultation

 

iv) Do you agree or disagree with the governments proposed route between W. midlands and Leeds as described in chapter 8? This includes the proposed route alignment, the location of tunnels, ventilation shafts, cuttings, viaducts + depots as well as how the high speed line will connect to the ECMC.


We disagree with the current route and details of this route as it would cause significant, in some cases, irreparable damage to designated wildlife sites.

We have analysed the route with a 50m buffer either side and identified the following sites that would be directly affected in Sheffield and Rotherham:

Twelve local wildlife sites (totalling 345 hectares), including three ancient woodlands (totalling 46 hectares): Smithy Wood, Hesley Wood and Woodland at Hesley Tip. Other sites affected include: Holbrook Marsh, Woodhouse Washlands and Treeton Dyke. See map 1 and Table 1 in appendix for details (to come soon). Many other wildlife sites may also be affected in South Yorkshire during track construction.
In our view, this is unacceptable. We are particularly concerned about the proposed loss of ancient woodlands for the following reasons:

Ancient woodland is defined as an area that has been wooded continuously since at least 1600 AD. It supports more threatened species than any other habitat in the UK, however, only around 550,000ha remains. It is a functionally irreplaceable resource for biodiversity that is also an important part of our cultural heritage.
As well as providing a wildlife and recreational resource for local people, woodlands can be part of a sustainable economy. Jobs and revenue streams are created through direct woodland management posts, timber management and the supply of sustainable biomass fuel. The woodland itself also provides natural ‘services’ for people, for example CO2 and rainwater absorption.

The following extracts are taken from the Government’s own ‘Standing Advice on Ancient Woodland’ (Natural England)
The value of ancient woodlands
Ancient woodlands are of prime ecological and landscape importance, providing a vital part of a rich and diverse countryside. In particular, ancient woodlands:

• Are exceptionally rich in wildlife, and support many rare and threatened species.
• May contain surviving descendants and features from the original natural forests.
• Act as reservoirs from which wildlife can spread into new woodlands.
• Are an integral part of England‘s historic landscapes.
• Contain a wealth of features of historical and archaeological importance little altered by modern cultivation or disturbance.
• Contribute to people‘s sense of place and imagination.
• Are important elements in the biological and visual functioning of a landscape.


‘Keeper‘s of Time,' issued by Defra/The Forestry Commission, is a statement of policy for England‘s ancient and native woodland which re-emphasises their value and includes six policy statements for ancient woodland:

• The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland.
• Ancient and native woodland and trees should make an increasing contribution to our quality of life.
• Ancient and native woodland should be exemplars of sustainable development, and provide opportunities for enterprise and employment.
• The ecological condition of ancient and native woodland should be improved and maintained.
• Rare, threatened or Priority species associated with ancient and native woodland should be conserved and enhanced.
• The cultural heritage associated with ancient woodland and veteran trees should be protected and conserved.


The National Planning Policy Framework (NPPF) and ancient woodland

NPPF states that the planning system should contribute to and enhance the natural local environment, including by protecting and enhancing valued landscapes, minimising impacts on biodiversity, and providing net gains in biodiversity

Paragraph 118, states that “planning permission should be refused for developments which result in the loss or deterioration of irreplaceable habitats, including ancient woodland, and the loss of aged or veteran trees in areas outside ancient woodland, unless the need for the development outweighs the loss of the woodland habitat.” “Policy G3 goes beyond this by setting out a framework for ensuring development does not have an unacceptable impact on trees and woodlands in general. Specifically, the second part of the policy prohibits development that would damage existing mature or ancient woodland, veteran trees or ancient or species-rich hedgerows.”


We would like:

  • For HS2 to be reconsidered as the wider environmental impacts of the proposals, particularly with respect to carbon emissions, the wider landscape and habitat fragmentation have not yet been properly assessed; and no compelling environmental case for the proposals has yet been made;
  • If HS2 is to be built we would like to see the most sensitive sites avoided, either through route alterations or cut & cover/bore tunnels/green bridges/viaducts – this would include all areas designated for their value to wildlife, including Local Wildlife Sites, which in Sheffield and Rotherham include irreplaceable ancient woodland habitat.
  • A robust package of mitigation and compensation for any final agreed route based on a ‘net gain for nature’. (see Q vii)

v) do you agree or disagree with the government’s proposals for
b) A S. Yorks station to be located at Sheffield Meadowhall as described in chapter 8 (sections 8.5.1-8.5.8)?

A route through Sheffield City Centre, if the route we have found is correct, in theory would result in a slightly lower cumulative impact on the area of protected wildlife sites, although a greater number and different set of sites would be impacted. This suggests that a Sheffield City Centre route would be more favourable to us from an ecological impact point of view, however, without HS2 conducting a proper ecological assessment of these potential impacts, it is difficult for us to have a more informed opinion at this stage.

Impact within 120m corridor only

Meadowhall route (13 LWS)

Sheffield city centre (17 LWS)
LWS 56.36 ha 56.81 ha
Ancient woodland 12.81 ha 8.56 ha


 

 

 
 
 
 
 
 
vii) Please let us know your comments on the Appraisal of Sustainability (as reported in the sustainability statement) of the governments proposed phase 2 route, including the alternatives to the route as described in chapter 9.


Our comments on the Appraisal of Sustainability for phase 2 are:

1. Overall our opinion is that the Government needs to ensure that if HS2 is to go ahead, that it must not be achieved at the expense of the natural environment. The current proposals and Sustainability Statement and Appendices do not reassure us that this will be the case.
We have the following specific comments to make on the ‘Sustainability Statement: Appendix E4 – Biodiversity’

2. Our view is the methodology is inconsistent. The consultants were asked to ”Provide detail on the possible effects on sites of regional importance1 Local Nature Reserves (LNR), Ancient Woodland, UK Habitats of Principal Importance (HPI), and publicly accessible information on Wildlife Trust Reserves;” but why not include Local Wildlife Sites (and Local Geological Sites) in this list? The importance of Local Wildlife Sites has been recognised in numerous Government documents including in Defra Local Site Guidance and The ‘Making Space for Nature’ report . ‘Natural Environment White Paper’ , and the National Planning Policy Framework.

We note that para 2.3.2. says “There are also a number of non-statutory, locally listed designations, information on which is held by a number of sources, notably the Wildlife Trusts and local data sources. The occurrence of particular species is not known at this stage, other than where they are mentioned within citations for protected sites. Surveys of protected species and consideration of locally designated sites will be addressed in due course as part of the EIA”

In our view, this is too late in the process for Local Wildlife Sites to be considered. It is not clear whether there will be a consultation on the EIA before it is submitted as part of the Hybrid Bill, to give interested parties such as ourselves, time to comment. The timescale seems very short to enable this to be a thorough process – especially when ecological surveys seasons have to be taken into account.
 

3. “4.3 Sites of Regional Importance 4.3.1. The proposed route directly affects a number of sites as follows: Nine Ancient Woodland sites, with notable impacts to New Farm Wood and Watnall Coppice (both within HSL13) and Smithy Wood, Hesley Wood and Wombwell Wood (all within HSL16 Blackburn to Cold Hiendley). Impacts on these woodlands would be a moderate adverse effect.“

We completely disagree with the view that the impacts on these woodlands would be only a moderate adverse effect as the route would cut through ancient woodland which is irreplaceable. How can this be a moderate effect? As the habitat is irreplaceable, we see no justification for this statement. And the report itself is contradictory, as para 4.4.1. says “Southern Magnesian Limestone NA (HSL13) and Coalfield NA (HSL16) are where most of the adverse impacts are located with particular focus around Chapletown, Worsborough (HSL16) and Hucknall (HSL13). The cumulative loss of Ancient Woodland and large areas of HPI woodland would be of regional importance and a major adverse impact.” We agree with this assessment of it being a “major adverse impact of regional importance and would like this impact to be avoided through a route alteration or modification (see Q iv).

4. 2.4.1. We welcome the mention of Living Landscape Strategies in this paragraph as we see these as being key to achieving the vision for creating robust ecological networks for the future. This is not only a vision of the Wildlife Trusts, but also of the ‘Natural Environment White Paper’, the National Planning Policy Framework, ‘Making Space for Nature’ and the ‘England Biodiversity Strategy'. However, it is not clear how the information in para 2.4.1 is actually being obtained (The Wildlife Trust for Sheffield and Rotherham have not been asked for our Living Landscape Strategy/maps) or analysed/considered as part of the process?

5. Should the proposals go ahead, then steps must be taken to mitigate and compensate for environmental damage and losses following the principles of requiring a ‘net gain’ for biodiversity. We therefore cautiously welcome para 2.4.2. “At the EIA stage a package of mitigation and enhancement measures will be considered (in consultation with Natural England (NE) and other wildlife organisations) to address the impacts on habitats and species. These measures would seek to address both the direct impacts on designated sites, and to reflect the wider strategic ecological priorities of affected areas (be these NAs, or the updated NCAs, LLS or similar). Profiles for these areas contain a series of ecological objectives or opportunities to, for example, reinforce fragmented woodlands, re-establish hedgerows, or restore, create and manage grazing marsh. These objectives will help to shape both mitigation strategies and to support, where appropriate, any wider programmes of enhancement or compensation (such as LLS or Community Forests). They may also be coupled with initiatives on ecosystem services, which could be introduced in the future.”

However, as the EIA has not been carried out yet and the proposed methodology is not public, we cannot say whether we are happy with the mitigation and enhancement measures. We (with the other Wildlife Trusts) would like to be consultees for this stage. We are very concerned about the use by ministers of the phrase ‘no net loss of biodiversity’. This is based on outdated policy. Current policy, including the National Planning Policy Framework. Paragraph 9 of the NPPF is clear: “pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment…including…moving from a net loss of biodiversity to achieving net gains for nature…”.

Therefore we would expect to see an unambiguous objective of a ‘net gain for nature’ with metrics, tests, strategies and monitoring clearly set out to achieve this to guarantee success. This would help contribute to the targets in the England Biodiversity Strategy and help the UK meet its international biodiversity obligations.



Appendix

Table 1 Local Wildlife Sites potentially impacted by HS2 - available for download at bottom of page 

Map of potential HS2 Railway impacts in Sheffield and Rotherham  - Available for download at bottom of page



Notes

Working with other Wildlife Trusts
Nationally, the 47 Wildlife Trust are working together to encourage HS2 Ltd to make decisions based on the best available environmental evidence. Our initial analysis shows that more than 200 important wildlife sites lie within a one kilometre corridor along the route and could suffer as a result. We are now working on a more detailed analysis of the likely impact of the scheme. We are also encouraging the government to form an ‘Environment Forum’ where views and concerns can be shared.

The need
The government has shifted its argument from the need for faster travel, to one of capacity. However, a recent report by the Tax Payers Alliance highlights the used of old and flawed data in the passenger demand forecasts. The report also highlighted Network Rail’s own figures showing that the West Coast Main Line is the least crowded long distance route to London, suggesting building the proposed HS2 route will not alleviate the routes most requiring additional capacity. The 51m group of Local Authorities who are against HS2 have suggested alternatives to improving capacity.
The Tax Payers Alliance report also highlights figures from the TPA and DfT showing that many cities and towns will have a reduced service on existing routes to London. For example, trains from Sheffield City Centre will be reduced from 2 to 1 per hour and will be slower.
Current fastest journey times between Sheffield and London are being cut by seven minutes to two hours from December 9th as trains operate at 125 mph on parts of the route for the first time as a result of £70m improvements. David Horne, Managing Director of Network Rail also said electrification, which will bring even faster journey was “around the corner”. With these faster train times, is HS2 justified?

The economic case
The projected project cost has increased from £32 billion (2010) to £50 billion in 2013 (£42.5 billion for infrastructure and £7.5 billion for rolling stock). A recent report by the Institute of Economic Affairs estimate costs could be as high as £80 billion if costs for mitigation (including ‘buying off opposition’) and additional linking infrastructure projects required are included. Several reputable reports (e.g. from the new economics forum ) argue HS2 is not the best way to spend £50 billion on improving transport in the UK.
Public Accounts Committee (a group of MPs) said in September that the DofT was failing to present a ‘convincing strategic case’ and instead the case was based on ‘fragile numbers, out-of-date data and assumptions which do not reflect real life”. The committee said there was no evidence the line would help the growth of regional cities and instead would draw even more business to London.
 

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Table 1 Local Wildlife Sites potentially impacted by HS2.jpg239.68 KB
Map: potential wildlife impacts of HS2_swt.jpg3.6 MB