- Read the HS2 Phase 2B working draft Environmental Statement published on 11th October 2018 – this sets out the impacts of building the planned section of the route in our area and how HS2 plan to avoid, manage and mitigate them.
- Tell your local MP what you think, write to them with your concerns. You can find details for your MP and submit an email to them via writetothem.com. Let us know if you do and what response you received.
- If you have any concerns or questions about the proposals or consultations, do contact us via 0114 2634335 or email@example.com. Again, we would love you to tell us your views.
- Join us – we rely on the income from our members to help us campaign on issues like this.
- Make a donation to our Campaigning for Wildlife Fund and help support our vital work on this and other issues for wildlife.
Mitigation and compensation:
A consultation was opened in July 2017 – closing 29th September 2017 – on the scope and methodology for the Environmental Impact Assessment. We responded to this.
Should the proposed route 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 as clearly set out in paragraph 9 of the National Planning Policy Framework “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…”.
Having considered the latest proposals, together with the supporting documentation, we have identified the following improvements that we wish the Government and HS2 Ltd to make:
- To carefully analyse the impacts and effects of the route on biodiversity. So far discussions about the environmental case for HS2 have not properly considered this aspect.
- To undertake a comparative assessment of baseline ecological data to inform the HS2 route selection and so avoid key habitats wherever possible;
- To undertake and make available as part of the consultation a comprehensive Environmental Impact Assessment (EIA) of the route. Until this has happened it is not possible to understand the full impact of the route on biodiversity, including the cumulative impact of habitat loss and fragmentation. This has not been made available so far and would be expected to have been provided prior to consultation by any other developer.
- To include Local Wildlife Sites in the Sustainability Statement and Appendices impact analysis.
- To commit to ensure that sufficient funds are made available to mitigate or compensate the adverse effects of the route on biodiversity and for long-term management/maintenance.
- To commit to a mitigation package that results in a ‘net gain for nature’ as stated in the Government’s own National Planning Policy Framework. A position of ‘no net loss’ is not sufficient (we are disappointed by the Government’s response to this – see above).
One way of achieving this would be for the Government to actively commit to the implementation of the Wildlife Trusts’ A Greener Vision for HS2. This vision is based on the Wildlife Trusts own research shows that investment in green infrastructure, habitat restoration and creation as part of HS2 is both affordable (within the scale of the overall budget for the project) and cost-effective.
To demonstrate this the Wildlife Trusts affected by Phase 1 and 2 of HS2 have identified and mapped habitat creation opportunities along the route. These areas were subsequently refined to identify the areas where the opportunity for nature restoration is greatest and most cost-effective to devise a strategic corridor (or stepping stones) of habitat that would reconnect fragmented habitats and strengthen local ecological networks.
It shows how a ribbon of natural areas, wild havens, green bridges and cycle ways could be created along the corridor of the HS2 route. Initial costings suggest that environmental restoration on this scale could be achieved with less than 1% of HS2’s overall budget of £42bn and a Cost Benefit Analysis undertaken by researchers at Newcastle University show that the benefits of restoring nature and providing access will outweigh the costs.
In 2014, the Environmental Audit Committee produced a report on HS2. The report contained a number of recommendations that we supported but unfortunately the government rejected most of these. For example:
- a) EAC Report on Biodiversity Loss “On HS2, the Government should aim higher than simply striving for no net biodiversity loss” and “The Government has not been able to establish a full environmental baseline against which the aim of ‘no net biodiversity loss’ can be assessed. HS2 Ltd must carry out outstanding environmental surveys as soon as possible”. (Para 12, page 8 and Para 22, page 12. Para 86, page 38)
Disappointingly, the Government has rejected the Committee’s call for a more ambitious objective than ‘no net loss’ stating that their current approach is ‘appropriate’.
- b) The EAC report recommends that HS2 has a separate ring-fenced environmental budget to ensure that nature restoration along the line can be maintained and enhanced over time. This was rejected by the Government
- c) The EAC report states that not all of the route has been surveyed for protected species, and where surveys have not taken place, HS2 Ltd has relied on informed guesswork.
The Government says they “will continue to liaise closely with Natural England and local wildlife trusts as appropriate as part of the process of improving our evidence base as the project develops.”