HIGH SPEED TWO: PHASE ONE ENVIRONMENTAL STATEMENT CONSULTATION

Transcription

1 FREEPOST RTEC-AJUT-GGHH HS2 Phase One Bill Environmental Statement PO Box London WC1A 9HS 26 th February 2014 HIGH SPEED TWO: PHASE ONE ENVIRONMENTAL STATEMENT CONSULTATION Dear Sirs Warwickshire Wildlife Trust is the leading local Nature Conservation charity in Warwickshire, Coventry and Solihull. We represent over 23,000 members and own or manage over 59 nature reserves covering around 800ha across the sub-region. The Trust aims are to protect and enhance wildlife and wild places and to encourage a greater appreciation of all aspects of the Natural Environment. The Trust welcomes the opportunity to comment on the Environmental Statement (ES) consultation for phase 1 of the High Speed 2 scheme. The consultation route crosses the sub-region of Warwickshire, Coventry and Solihull from southeast to northwest, passing through the districts of Stratford-on-Avon, Warwick, Solihull and North Warwickshire. There are seven Community Forum Areas (CFAs) along this stretch of the route which are as follows: 16, 17, 18, 19, 20, 23 and 24. All seven of these CFAs are within Warwickshire Wildlife Trust s remit area and it is these areas to which this response relates. The Trust has previously set out our position on the principles of High Speed Rail and the preferred route in the 2011 consultation and have input into the development of the scheme through consultations on the Scope and Methodology and on the draft ES in We have also participated in bilateral discussions with HS2 Ltd, have attended Community Forum meetings and are a member of independent Ecology Technical Group (ETG) which was set up to promote the best possible standards for biodiversity within the design of HS2. This response sets out the Trust s position on the ES for phase 1 of HS2. It is our view that: 1) The Environmental Statement does not provide a robust account of the ecological impacts of the scheme in Warwickshire, Coventry and Solihull 2) The Environmental Statement fails to achieve its stated objective of securing no net loss of biodiversity along the route And because of this, the Trust remains deeply concerned about significant residual and lasting impacts that HS2 could have on biodiversity within Warwickshire, Coventry and Solihull. This response below and associated appendices detail the reasoning and evidence behind our conclusions. Yours sincerely Richard Wheat Planning and Biodiversity Officer Warwickshire Wildlife Trust

2 Note: As this response relates to seven community forum areas, and as the crossovers between the ES volumes make it difficult for consultees to separate comments to individual volumes, we have not used the structure of the ES consultation response form to detail our comments. Our comments principally relate to the ES as a whole and we believe these points could not be structured into the rigid way in which the ES response form has been created. If however, it is necessary to relate this response to the questions on the response form for the purpose of analysis, we ask that section 1 is considered as a response to Question 3 and that section 2 is considered as a response to Question 4. A response form is enclosed in appendix 1 with the details as requested. However we strongly recommend that the response as it is intended below is taken in its current form. Section 1 The Environmental Statement does not provide a robust account of the ecological impacts of the scheme in Warwickshire, Coventry and Solihull The ES does not provide a robust ecological baseline for the purposes of the impact assessment Survey Methodology 1.1. The survey methodologies applied during the baseline surveys do not appear to be consistent with the agreed approach set out in the SMR Addendum Report: Ecological Field Survey Methods and Standards 1. The Volume 5 Ecology Data Reports 2 shows evidence of sub-optimal survey timings, poor site selection and patchy completion of survey work throughout CFAs in Warwickshire, Coventry and Solihull. Survey methodologies have already been adapted from existing best practice and are much reduced to facilitate the scale of this scheme; therefore the failure to uphold even agreed minimum survey standards serves to undermine the credibility of ecological baseline in the ES Appendix 2 outlines where we believe the survey methodology undertaken is inconsistent with the approach set out in the SMR Addendum Report. This list is by no means exhaustive and is so far based solely on evaluation of the survey reports for bats, reptiles and birds. Survey Effort 1.3. Survey effort has also fallen short of the minimum standards set out in the SMR addendum report; Ecological Field Survey Methods and Standards. The Volume 5 Ecology Data Reports indicate that survey effort has been inconsistent across Community Forum Areas (CFAs), is often comprised of below minimum survey visits and has been hampered by poor survey coverage in Warwickshire, Coventry and Solihull. It is apparent that land access and the available turnaround time for completion of the EIA are the main limiting factors influencing with the extent of survey effort undertaken. The shortfall in survey effort again brings into question the value and credibility of the baseline data in the ES. 1 HS2 Phase One Environmental Statement Vol 5 - Scope and Methodology Report Addendum Ecological Technical Report: Ecological Field Survey Methods and Standards - document reference CT /2, ES HS2 Phase One Environmental Statement Vol 5 - Ecology Data Reports and Map Books - CFAs 16-22, and

3 1.4. Appendix 3 outlines where we believe survey effort has fallen significantly short of the minimum standards set out in the SMR Addendum Report. This list is by no means exhaustive and is so far based solely on evaluation of the survey reports for bats, reptiles and birds. Baseline Evaluation 1.5. The quality of the baseline has wider implications for the ES. For example, the confidence in valuations and precautionary assessments, which depend on robust ecological data, will be compromised by gaps and inconsistencies in the baseline. This is already apparent in the ES Volume 2 reports which have often resulted in subjective, conditional or uncertain evaluations of species, habitats or features where there is a lack of evidence or robust data supporting the evaluation assigned Moreover, gaps or inconsistencies in the baseline at the ES stage would also provide a poor context in which to monitor ecological change throughout the course of the development. This could in turn create uncertainty about the thresholds for which remedial action will be required to resolve outstanding ecological issues or could result in misleading assumptions about the long-term ecological impacts of the scheme overall. The ES does not take full account of environmental trends in the future baseline Potential Local Wildlife Sites 1.7. Paragraph of the SMR addendum; Ecological Assessment Method clearly states that the impact assessment considers the baseline conditions that would exist with and without the proposed scheme. This projection however has not been applied in relation to the ongoing assessment of potential Local Wildlife Sites by local authorities along the route in Warwickshire, Coventry and Solihull Potential Local Wildlife Sites (plws) are sites deemed to support features of county importance for nature conservation but which have not yet been subject to the Warwickshire Local Wildlife Site Criteria Assessment 3. All Local Authorities in Warwickshire, Coventry and Solihull are part of the Local Wildlife Site Partnership and each year a proportion of plws within their respective districts are allocated for survey and assessment against the LWS criteria. In 2013, the number of plws surveyed across Warwickshire, Coventry and Solihull were as follows: Table.1 Number of plws surveyed per year through Warwickshire, Coventry and Solihull between 2010 and Year No. of plws surveyed in Warwickshire, Coventry and Solihull This trend is likely to continue through to the beginning of the construction phases in 2017 and beyond and so it is reasonable to assume that a proportion of the 33 plws within the route across the sub-region will have been surveyed and potentially allocated as county 3 LWS criteria assessment as detailed in The Green Book: Guidance for the Selection of Local Wildlife Sites in Warwickshire, Coventry and Solihull, Available from Wildlife Sites Project, Habitat Biodiversity Audit, Warwickshire County Council, PO Box 43, Warwick, CV34 4SX 3

4 important Local Wildlife Sites by this time. Using the precautionary worst case principle outlined in section 2.8 of the SMR Addendum: Ecology Tech Note, all plws should be formally noted and given a precautionary value of up to county importance rather than the site solely being assessed on its individual habitats and species components Appendix 4 lists all the potential Local Wildlife Sites that are likely to be significantly impacted by the route but are not explicitly assessed (as a site) in the ES. Habitat and Species Trends Paragraph of the SMR Addendum: Ecological Assessment Method indicates that the ES has not taken account of available local data on existing habitat and species trends when determining the future ecological baseline in Warwickshire, Coventry and Solihull. Data on local trends, such as that provided within The State of Habitats in Warwickshire, Coventry and Solihull report 5, may provide important evidence in which to base assumptions about future trends and so should have been acknowledged to inform the ES Volume 2 reports Nor has the ES considered changes to the baseline brought about by positive action for nature conservation at the county or local levels. Examples include the recent adoption of the Warwickshire, Coventry and Solihull Sub-Regional Green Infrastructure Strategy by all local authorities in the Sub-region and existing initiatives such as Warwickshire Wildlife Trust s Princethorpe Woodlands and the Tame Valley Wetlands Living Landscape Projects; all of which could influence baseline trends by 2017 and The ES has not consistently used the precautionary assessment consistently for all ecological receptors Appendix B of the SMR Addendum: Ecology Assessment Method 6 sets out the principles for using precautionary values and assumptions within the ecological impact assessment. These principles have not been applied consistently throughout the ES and have resulted in either features being undervalued or omitted from the impact assessment, even where significant impacts on the features may occur. In these instances precautionary mitigation and compensation measures are also missing for these features within the ES Table.2 below outlines examples where we believe the precautionary assessment has not been applied in accordance with the principles outlined in the SMR Addendum so far. Table.2 Summary of inconsistencies between the application of the precautionary assessment and the principles of the ES Vol 5 SMR Report Addendum CFA Report Precautionary Approach 17 Table.9 describes the hazel dormouse potential as being of negligible importance. However South Cubbington woodland was not accessed for survey and this area is situated in close proximity to a known population of dormice and is cited within the ES to support the highest 4 Paragraph of the Scope and Methodology Report Addendum states that Habitats and species occurring within sites which have not been formally designated (e.g potential local wildlife sites) should as a general rule be evaluated as part of the habitats and species assessments. 5 Habitat Biodiversity Audit for Warwickshire, Coventry and Solihull (2013) The State of the Habitats of Warwickshire, Coventry and Solihull, available from Habitat Biodiversity Audit, Warwickshire County Council, PO Box 43, Warwick, CV34 4SX 6 HS2 Environmental Statement Vol 5 - Scope and Methodology Report Addendum :Ecological Technical Note - Ecology Assessment Method, - Appendix B Approach to Precautionary Assessment - document reference CT /2, ES

5 potential for the species. In contrast, CFA 23, where opportunities are sub-optimal in comparison, gives dormice potential a precautionary assessment of up to county importance. The species was not assessed in the impact assessment even though potential habitat could be subject to significant loss, fragmentation and disturbance. 20 Paragraph does not use the precautionary assessment to consider the impacts on the potential bat assemblage in Crackley Wood south which is valued of being up to regional importance. The para uses the CoCP to rule out impacts even though the likely extent of this is unknown at this stage due to lack of access. 20 Table.12 describes a potential bat assemblage within North Wood which has a precautionary value of up to regional importance. The significance of habitat loss, fragmentation disturbance on these assemblages has not been assessed within the ES. Compensation for bats in North wood is described in para but this does not take into account displacement of the roosts which could be significant at up to regional level. The ES does not provide sufficient information to give weight to the assumptions and conclusions of the impact assessment. Certainty The degree of confidence assigned to the assumptions and conclusions of the impact assessment is not detailed within the ES. The Institute of Ecology and Environment Management s (IEEM) guidelines 7 states that a categorical confidence level should be provided for predictions so that the likelihood of an impact occurring, or a mitigation/ compensation proposal being successful, as detailed, can be considered as part of the ES. This is reaffirmed in paragraph of the SMR Addendum; Ecological Assessment Method 8 ; however the use of categorical levels of confidence it cites (i.e certain/ near certain and probable) are omitted from the ES Volume 2 reports. Probability Without the aforementioned confidence levels in the ES, it is not possible to differentiate between predictions that are certain/ near certain (i.e probability above 95%) or those that are only probable (i.e probability below 95% but above 50%). The assumptions associated mitigation/ compensation in the ES could therefore mislead consultees and decision makers about the likely probability that a specific ecological impact can be satisfactorily addressed This issue is particularly pertinent where the extent, location or design of mitigation/ compensation is not sufficiently detailed in the report and is solely reliant on the principles of mitigation outlined in the SMR addendum. Whilst the SMR addendum: Ecological Principles of Mitigation 9 does set out broad mitigation and design principles, it is unable to guarantee that all factors for successful mitigation/ compensation (such as extent and location) can be achieved and delivered within the physical and financial constraints of the scheme. It is therefore misleading for the ES to imply a similar level of confidence to these measures, 7 Institute of Ecology and Environmental Management (IEEM), 2006, Guidelines for Ecological Impact Assessment in the United Kingdom (Online), available at EcIA_Guidelines-Terestrial_Freshwater_Coastal.pdf [accessed on ] 8 HS2 Environmental Statement Vol 5 - Scope and Methodology Report Addendum: Ecological Technical Note - Ecology Assessment Method - document reference CT /2, ES HS2 Environmental Statement Vol 5 - Scope and Methodology Report Addendum: Ecological Technical Note - Ecological Principles of Mitigation - document reference CT /2, ES

6 which depend on unknowns, than to those that have been specifically designed and allocated within the landscaping scheme to date Appendix 5 summarises examples where, due to the lack of detailed information provided, we believe the likelihood of successful mitigation/ compensation can only reasonably assumed as probable. Justification There is also limited reference of up-to-date, peer reviewed scientific literature, and in some case field survey, to justify assumptions and conclusions in the ES. This relates both to the impact assessment (i.e. confidence in the predictions about how High Speed Rail will affect ecological receptors) and the mitigation/ compensation measures proposed (i.e. confidence in the type, extent, predicted use and longevity of mitigation or new habitat creation). The absence of such justification, particularly where guidance on conventional mitigation and compensation is not directly relevant to a major infrastructure project such as HS2, raises further doubts about the levels of confidence that can be applied to certain conclusions in the ES Appendix 6 summarises examples where, due to the lack of justification provided, we believe the likelihood of successful mitigation/ compensation can only reasonably assumed as probable. Verification of local effects The register of local level effects 10, which describes impacts that are significant at the local level, includes a column to indicate whether or not a listed impact has been compensated for. However the document provides no information about how the impact has been compensated, which requires decision makers and consultees to speculate that the impact has been addressed through the measures in the ES Vol 2 reports. In many cases it is not possible to cross reference the local level effect with compensation measures provided so it is almost impossible to verify these conclusions Whilst the ES assumes that local level effects are not material considerations in the scheme, and so do not explicitly require compensation to be provided, the details of uncompensated effects will still be important to inform the cumulative impact assessment as detailed in para of the SMR Addendum: Ecology Assessment Method. Therefore it is necessary for the ES to clearly state how local level impacts have been compensated so that consultees and decision-makers can verify the extent or significance of cumulative impacts at the route wide level. Without this information, it is not possible to determine whether or not the HS2 scheme is in line with the projects stated objectives of achieving no net loss of biodiversity. The ES is poorly structured, omits important ecological information and assessment and demonstrates a lack of inconsistency within and between documents. Terminology The ES volume 2 reports interchangeably use the terms mitigation, compensation and enhancement in the ecological impact assessment, contrary to paragraph of the SMR Addendum: Ecological Assessment Method. Whilst this is widespread throughout the ES, it is perhaps most notable in the continual use of subheading other mitigation measures which is used prior to the description of compensation measures for each CFA. 10 HS2 Environmental Statement Volume 5: Ecology - CFAs 16 to 22 register of local level effects: Ladbroke to Handsacre (Ref: volume 5 appendix EC , ES ) and CFAs 23 to 26 register of local level effects: Balsall Common to Curzon Street (Ref: volume 5 appendix EC , ES ) 6

7 1.24. The confusion surrounding the use of terms is compounded by the structure of the ES which introduces mitigation and avoidance prior to and during the impact assessment and throughout the description of compensation measures. This makes it difficult for consultees and decision makers to adequately determine if and how the mitigation hierarchy 11 has been applied correctly in the ES. Structure The structure of the ES also makes it difficult to cross reference between the baseline, the impact assessment and the mitigation/ compensation measures detailed. The Trust outlined this issue in our response to the draft ES stating that the use of tables to summarise impacts, avoidance/ mitigation, compensation and residual effects for each receptor should be provided to aid interpretation of the findings and minimise the risk of any shortfalls in information The failure to adopt this approach in the final ES, together with the submission of a separate document to list local effects (document references EC and EC ), makes it difficult for decision makers and consultees to cross check the conclusions of the report. However, where we have undertaken this task, it has revealed that a number of impacts on important ecological features, and subsequent mitigation/ compensation measures to address significant effects, have been lost within the ES reports or the register of local level effects. These omissions undermine the credibility of the ES and may result in the full impacts on biodiversity within the CFA s of Warwickshire, Coventry and Solihull being significantly underestimated Appendix 7 outlines where we believe significant ecological impacts have been omitted from the impacts assessment or local level effects document Appendix 8 outlines where in the ES we believe mitigation and compensation has been omitted for identified and potential significant effects. Inconsistencies Detailed review of the ES Vol 2 reports and their associated map books has revealed that almost all CFA areas within Warwickshire, Coventry and Solihull show inconsistencies between the compensation areas described and those annotated on the map. It is accepted that, as detailed in paragraph of the SMR Addendum: Ecological Assessment Method, landscape planting may be reported as compensation where it is considered to have a beneficial effect. However, where compensation is specific for an individual species or habitat, and where a target ecological condition is cited, these areas should be clearly highlighted using the relevant ecological habitat creation polygon on the associated map book This has not been the case for the CFAs in Warwickshire, Coventry and Solihull where areas specifically allocated for biodiversity have been annotated as landscaping mitigation, where annotated areas of habitat creation have not been described in the report or where a different habitat creation polygon has been used to the habitat described in the report. Appendix 9 summarises the inconsistencies that we have observed so far between the Vol 2 reports and associated map books for CFAs in Warwickshire, Coventry and Solihull. 11 Mitigation hierarchy following Paragraph 118 (1) of the National Planning Policy Framework which states that if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused 7

8 Other anomalies In addition to the above, there are also other anomalies within the report that hinder accurate interpretation of the impact assessment and the approach to mitigation/ compensation. A summary of anomalies which we have observed is provided in appendix 10. Section 2 The ES does not fulfil HS2 s stated objectives of achieving no net loss of biodiversity. Local Wildlife Sites Local Wildlife Sites (LWS) are core areas 12 for nature conservation, which underpin local ecological networks and make a significant contribution towards national and local biodiversity targets and objectives. These sites are integral to the Government s strategic objectives for establishing more, bigger, better and joined areas for wildlife 13 and for fulfilling its international commitments to halt the loss of biodiversity by LWS are afforded some protection through paragraph 113 of the National Planning Policy Framework 15 (NPPF) as well as within the many local development plans for the areas affected by the route. The impact of the HS2 scheme on LWS in Warwickshire, Coventry and Solihull is significant. Volume 3 of the ES: Route Wide Effects 16 indicates that in Warwickshire 18 LWS will be adversely affected which amounts to 4% of the entire sub-regional LWS network. Of these 18 LWS, 15 are deemed to be lost entirely or subject to significant and permanent degradation 17. In addition to this there is a further 23 potential Local Wildlife Sites (plws) directly affected by the scheme (as listed in appendix 4) which could be of Local Wildlife Site quality but were not included in the impact assessment. The status of LWS appears to have had little weight in the HS2 scheme. Initial review by Warwickshire Wildlife Trust indicated that in 2011, the number of LWS vulnerable to adverse impacts from HS2 in the sub-region was 17. Notwithstanding further review and notification of several plws within route since this time, the number of LWS has largely remained the same; demonstrating no clear commitment to avoiding or mitigating these sites through design changes in the first instance. What is apparent in the ES however is that the LWS impacted along the route are not only vulnerable to the route itself, but also to ancillary works such as construction areas, transformer stations, car parks, landscaping and road diversions. This indicates that there were, and still are, opportunities to amend the proposals 12 Core Areas of high nature conservation value as defined in Biodiversity 2020: A Strategy for England s Wildlife and Ecosystem Services, (Online) Available at [Accessed 29/01/2014] 13 The Natural Choice: Securing the Value of Nature, (Online) Available at [Accessed on 29/01/2014] 14 As agreed in the Nagoya Protocol, Japan summarised on page 60of The Natural Choice: Securing the Value of Nature 15 Paragraph 113 of the NPPF Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution they make to wider ecological networks. 16 HS2 Environmental Statement Volume 3: Route Wide Effects (Online) Available at [Accessed 23/01/2014] 17 Data based on analysis of HS2 Environmental Statement Volume 2: Community Forum Area Reports (CFAs 16-20, 23 and 24. (Online) available at [Accessed Jan 2014] 8

9 to avoid or reduce impacts on LWS without significantly altering the route design; contrary to the statement in para of the ES Volume 3 report. Paragraph states that compensation measures are provided where a significant effect is expected on a LWS. However, this compensation, where it has been provided, will only ever replace the component habitats of the LWS which have been lost to the scheme whereas the remaining effects of fragmentation, disturbance, edge effects and hydrological changes are, in many cases, likely to persist. The assumption in para that compensation will reduce the effects on LWS to a level where they are unlikely to be significant is therefore unfounded. The ES has detailed very few measures to address the indirect impacts on the retained areas of LWS. These unmitigated indirect impacts, together with any habitat lost to the proposed scheme, are therefore likely to result in the de-notification of the majority of LWS along the route in Warwickshire, Coventry and Solihull. As para correctly states, this loss of designated status cannot be compensated for. Even in the long-term the suggested designation of the newly created habitats is not guaranteed, as this will depend on location and juxtaposition of the habitats, the species that colonise the site and the long-term management; not just the target habitat be created as inferred. The loss of the 18 LWS identified in table.6 of the ES Volume 3 report is therefore a residual effect that should be clearly stated as part of the HS2 scheme. Ancient Woodland The HS2 scheme will have a significant effect on ancient woodlands in Warwickshire, Coventry and Solihull. Analysis of the ES Volume 2 reports reveals that 6 ancient woodlands will be affected in the sub-region resulting in the loss of around 8.1 ha 18 of ancient woodland habitat overall. This means that of the 32ha of ancient woodland lost to the HS2 scheme, 25% will be lost in Warwickshire. In addition to this, further ancient woodland habitat in Warwickshire will be impacted indirectly through fragmentation, edge effects, disturbance and hydrological changes. These impacts are largely omitted or considered insignificant in the ES Volume 2 reports even though the design of the route, the location of the ancillary infrastructure and the proposed operational parameters of the scheme do not support these conclusions. The extent of additional ancient woodland habitat indirectly impacted by the scheme is therefore not known but in a county with less than 2% coverage of ancient woodland 19, any further loss or degradation of this irreplaceable resource will inevitably be significant. As ancient woodland is irreplaceable, it is not possible to compensate for the impacts on the habitat within the ES. The loss and degradation of more than 8ha of ancient woodland is therefore a significant residual effect that should be clearly stated as part of the scheme. The Trust considers the use of term beneficial effect in the ES to describe measures taken to address ancient woodland loss as misleading as there is clearly no benefit from these measures above and beyond what the damage which will have already occurred. The translocation of ancient woodland soils and coppice stools can only therefore been seen as a suboptimal 20 attempt to salvage what has been lost. 18 Analysis taken from HS2 Phase 1 Environmental Statement Volume 2: CFA Reports CFAs 16-20, 23 and 24 document reference (ES ES , ES and ES ) 19 Ancient woodland data taken from Habitat Biodiversity Audit for Warwickshire, Coventry and Solihull (2013) The State of the Habitats of Warwickshire, Coventry and Solihull, available from Habitat Biodiversity Audit, Warwickshire County Council, PO Box 43, Warwick, CV34 4SX 20 Joint Nature Conservation Committee (JNCC), A Habitats Translocation Policy for Britain, July 2003, (Online) available at [Accessed Feb 2014] 9

10 Compensation can only feasibly be achieved for the replacement of woodland habitat overall, which is principally the approach detailed in the ES. Mindful of the value of high distinctiveness woodlands in the proposed Biodiversity Offsetting metrics, woodland creation to loss ratios in the ES should be highly favourable in order address the diminished relative value of new woodland creation and the significant temporal effects (min 50 years +) on woodland biodiversity. However observed ratios in the ES for Warwickshire CFAs vary widely, with some sites achieving woodland creation ratios of less 1:1. Whilst the final biodiversity offsetting metrics will determine if this creates a biodiversity loss overall, an actual reduction in high quality woodland habitat (not including lower quality woodland for landscape planting) in Warwickshire, Coventry and Solihull would clearly be a significant residual impact of the scheme. Ecological Landscape Para of the ES Volume 3 report states that the principle of Lawton s more, bigger, better and joined places for nature will be used as a guide to influence the areas of compensatory habitat creation. However, this principle does not seem to have been applied when reviewing and assessing the impacts of the scheme on the ecological landscape along the route. The scheme will have clear landscape scale effects through habitat loss or change, fragmentation and displacement of species populations, all of which could alter local ecological networks. And whilst new habitat creation may reduce, address or even enhance some networks, others could be lost degraded or fragmented in the long-term. The failure of the ES to balance these ecological effects on the landscape scale brings into question the assertion that the scheme contributes towards the creation of a more resilient and biodiversity-rich landscape. The omitted references to biodiversity opportunities areas, as identified by local biodiversity partnerships, and existing landscape scale biodiversity focussed projects, such as the Wildlife Trust s Living Landscapes projects, in the ES, is clear evidence of the lack of knowledge about the ecological landscape effects of the scheme. These projects and opportunities, which often have wider community, public and private sector support, are areas where targeted resources could have real and lasting effects. However, whilst these schemes were brought to the attention of HS2 Ltd during the bi-lateral meetings and other fora, the impacts of the scheme on these projects, or the framework these projects provide to inform compensation measures, have not been a consideration of the ES. In Warwickshire, the scheme crosses five areas which have been identified as either focussed areas for biodiversity enhancement or where biodiversity-led projects exist. This includes the Princethorpe Woodlands Living Landscape area (crossed as the route passes through South Cubbington Wood) and the Tame Valley Wetlands Landscape Partnership Scheme which is currently the subject of a 1.7 million bid to the Heritage Lottery Fund. Failure to account for these projects within the ES means that not only does the route fragment and degrade the ecological landscape of these areas, it may also compromise opportunities to improve it in the long-term if, as a result, project proposals and bids fail and, in the case of the latter, investment to the tune of over 2.5 million is lost. The effects on the ecological landscape are not solely confined to focussed biodiversity opportunity areas. Notwithstanding the wider loss and fragmentation of core sites (as outlined for LWS and ancient woodlands above) and other residual effects on habitats and species, the operational HS2 scheme is likely to have significant barrier effects on wildlife at a landscape scale, such as through physical barriers and noise and visual disturbance. And whilst these barrier effects have been acknowledged to a lesser extent within the ES through the appropriate valuation of hedgerow networks, watercourse corridors and bat foraging routes, the approach to compensating for these effects is limited both in quality and extent. 10

11 In Warwickshire, Coventry and Solihull, the landscape fragmentation effects of the HS2 scheme are significant. The ES Volume 2 reports reveal that seven watercourses will be culverted, up to 169.9km of hedgerow could be removed and three notable linear habitats along disused railway corridors will be severed. In addition, according to analysis of the bat survey work in the ES Volume 5 Ecology Map Books 21 around 124 key foraging routes for bats across the county will also be impacted. Compensation for these impacts are however minimal. There is limited reference to compensation for culverted watercourses, other than minor enhancements downstream, and the extent of hedgerow restoration or creation is not detailed in the ES for most CFAs in Warwickshire. Only CFA 24 identifies the likely extent of replacement hedgerow and this replacement accounts for only 10% of the hedgerow network lost or in other terms a 90% loss. The shortfall in compensation for landscape effects also extends to addressing species impacts, the most notable being that for bat species. Compensation for impacted bat foraging and commuting routes comes in the form of viaducts over river corridors, green over-bridges and underpasses for access roads, none of which appear to have been purposefully created or, in terms of the latter two, placed specifically to address the severance of key bat foraging and commuting routes. An analysis of the ES volume 2 maps and the Vol 5 ecology map books indicates that there is 37 retained or created crossing points of the HS2 scheme that could be used by bats in Warwickshire, Coventry and Solihull. Of these only around 39 of the 124 (i.e. 31%) key foraging routes coincide (i.e. is within close proximity) with a proposed crossing point. Furthermore the analysis revealed that, where crossing points do not coincide with key foraging areas, the distance range that a bat would have to travel to reach a crossing points is between <50m and 2.5km, which could impact on the condition and breeding success of local bat populations. A summary breakdown of this analysis by CFA is detailed in table 3 below. Table.3 Analysis summary of key bat foraging routes and crossing points within the HS2 scheme CFA No of key foraging/ commuting routes or areas in baseline data affected by HS2 route (Data from CFA Maps books (EC-06-Bat Activity) No. of new or retained crossing points proposed in CFA (Greenoverbridge, under pass or viaduct) No. of key foraging areas coinciding with new crossing points % of foraging routes not mitigated and range distance to nearest crossing % (75m- 1.7km) % ( m) % (125m 1.45km) % (<50m- 2.5Km % (<50-1.1km) % ( m) 21 Analysis taken and measured from HS2 Phase 1Environmental Statement Volume 5: Ecology Ecological Map Books document references ( , and )and HS2 Environmental Statement Vol 2 CFA Reports CFAs 16-20, 23 and

12 % (175-2km+) Overall, this loss of connectivity features, and the 69% loss of bat foraging/ commuting routes, illustrates that the scheme will result in a residual effect on the ecological landscape in Warwickshire, Coventry and Solihull which should be clearly stated in the ES. Biodiversity offsetting The ES commits to the principle of using biodiversity offsetting as a means to assessing the relative biodiversity losses and gains of the scheme and to determine if the HS2 Ltd s stated objective of securing no net loss of biodiversity is achieved overall. The absence of the Biodiversity Offsetting Assessment as part of the consultation documentation is therefore puzzling as without it, there is insufficient support or justification for many of the conclusions presented in the ES. It is unclear when decision makers and consultees will have the opportunity to scrutinise the results of the Biodiversity metrics; however the absence of the document from this consultation exercise further supports our remarks that the ES does not provide an adequate representation of the Environmental Impacts of the scheme. In the interim, we are aware that Warwickshire County Council has undertaken a review of the scheme using Habitat Biodiversity Audit data and the metrics from the Warwickshire, Coventry and Solihull Biodiversity Offsetting Pilot Scheme. The review reveals that, when taking account of construction, mitigation and compensation, the scheme would result in a significant loss of biodiversity equating to a shortfall of up to 1400ha of habitat in Warwickshire alone. Whilst the Trust withholds our formal comments on the final HS2 biodiversity offsetting assessment until it is made publicly available, this enormous shortfall in biodiversity compensation identified at this stage, which is also echoed throughout our response, is likely to be a significant residual effect on biodiversity in Warwickshire, Coventry and Solihull which will need to be clearly stated within the ES. Compiled by Warwickshire Wildlife Trust February