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Introduction Introduction The Woodland Trust (The Trust) is the UK's leading woodland conservation charity and aims to protect native woods, trees and their wildlife for the future. We do this by restoring and improving woodland biodiversity and increasing people's understanding and enjoyment of woodland. We own over 1,000 sites across the UK, covering over 20,000 hectares (50,000 acres) and we have 500,000 members and supporters. Ancient woodland is one of the country’s richest terrestrial wildlife habitats, home to 256 species of conservation concern as listed on the UK Biodiversity action plan. It has evolved over hundreds, if not thousands of years and cannot be recreated or compensated for. Furthermore, it also holds a unique, indescribable value for all those who visit or have an association with it. “Our ancient woodlands are quintessential features of England’s much-loved landscapes – irreplaceable, living historic monuments which inspire us and provide us with a sense of place and history in an increasingly frenetic world”. These are not The Trust’s words, but taken from the Government’s own Keepers of Time, written in 2005 as a statement of policy to better protect and value ancient woodland. Clearly there is a wider recognition of the importance of ancient woodland, and The Trust is determined that this should be applied throughout the construction and operation of High Speed 2. Although supportive in principle of the concept of high speed rail, The Trust has severe misgivings about the green credentials of a route that will destroy some of the UK’s finest irreplaceable natural habitats. It is important that there is proper consideration of its environmental impact and that the likely significant effects are accurately assessed, so that appropriate mitigation can be designed to be integral to the project and compensation measures are appropriately secured. The Trust is concerned that many of the mitigation and compensation measures proposed are not detailed enough and may only be implemented “if reasonably practicable”, with no definition given as to what this actually means. Furthermore, there is little or no information on how the nominated undertaker and contractor will be obliged to put mitigation and compensation measures in place as well as monitor and manage them for decades to come. Summary of Representations on the Environmental Statement The Woodland Trust (The Trust) has reviewed the Environmental Statement (ES) for the proposed route of Phase 1 of High Speed 2 (HS2). Our comments relate specifically to ancient woods on the ancient woodland inventory (AWI), and those woods that we consider should be on the AWI. Our main concerns are summarised below; 1. Ancient woodland is irreplaceable – whilst the ES asserts this in Volumes 1, 3 and 5, this key fact is absent from the Non-Technical Summary and Volume 2 and often, the analysis in these sections mistakenly implies or states that the proposed compensation planting will mitigate the loss of ancient woodland. This leads to conclusions which underplay the magnitude and significance of the environmental effects of the proposals. 2. Compensation versus mitigation - The ES continually confuses the terms compensation and mitigation. Any planting offered in relation to ancient woodland loss should be referred to as compensation because it is not possible to mitigate the loss of an irreplaceable habitat. 1 3. Success of mitigation measures – the assumption throughout the ES is that any mitigation measures proposed will be successful. There is no discussion of alternative mitigation measures or what contingency plans will be put in place if mitigation fails. 4. Effect of ancient woodland loss – Any loss of ancient woodland should clearly be recorded as a significant permanent residual effect in accordance with the Scope and Methodology Addendum (Volume 5). Unfortunately this is not always the case and loss is sometimes referred to as a moderate or even a low adverse effect. The Trust considers this to be misleading. 5. Significance of ancient woodland loss – parts of the ES accept that ancient woodland is of national significance. However, within the CFA reports ancient woodland is often referred to as only being of county/metropolitan significance and in some cases it is referred to as only having district/borough significance (e.g. CFA 9), which is potentially misleading. Any loss of ancient woodland is of national significance. 6. Cumulative effects – there is no discussion within the ES of the cumulative effects of removing over 32ha of irreplaceable ancient woodland along the route of Phase 1. 7. Number of ancient woodlands to be affected – The Trust considers that Phase 1 of the proposed scheme will directly affect 27 ancient woodlands and indirectly affected 21. The ES states that 19 ancient woodlands will be directly affected and does not give a number for those indirectly affected. The ES has not, therefore, assessed the likely significant effects of the development on the environment as required by the European Council Directive 85/337/EEG (as amended and codified in 2011 by Council Directive 2011/92/EU (“the EIA Directive) and the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (“the Regulations”). 8. Ancient and veteran trees – Every ancient tree provides history, biodiversity, aesthetic and landscape value because of its age, size or condition. Ancient trees are a rarity in themselves and the UK has a special responsibility as it is believed to contain the highest proportion of ancient trees in Northern Europe. However, these trees are barely mentioned by the ES even though there are significant numbers within the construction boundaries. The loss of the oldest wild pear tree (CFA 17) in the UK is referred to as being of district/borough significance only . Once again this has the effect that the ES has not fully assessed the likely significant effects of the development on the environment as required by the EIA Directive and the Regulations. 9. Mantle’s Wood – At present it is proposed to construct the northern tunnel portal in the middle of Mantle’s Wood ancient woodland, representing the single biggest loss of ancient woodland along Phase 1 (6.2ha). For the ES to accept on one hand that ancient woodland is irreplaceable, but then to construct a tunnel portal in the middle of one is completely unacceptable and shows a blatant disregard for the significance of this habitat. 2 10. Inconsistent figures – the area of individual woodlands (both ancient and secondary) to be lost to the scheme are reported inconsistently between reports and within reports. This has made it difficult to determine which figures are correct and what environmental information is to be taken into consideration. 11. Method for demonstrating no net loss in biodiversity - The ES states that the project aims to result in no net loss in biodiversity. However, it is not possible to achieve this target because irreplaceable habitat is being removed. The Trust is concerned that the ES proposes to use a modified form of the Defra methodology for biodiversity offsetting to significantly reduce the burden of achieving this objective. The Defra methodology is a draft which is still under consultation, and the changes proposed by HS2 are a major departure from this approach and are not based on any tried and tested methodology. Furthermore, the ES does not provide evidence of any calculations already made or any detail of how such metrics calculations will be used in practice. This makes it almost impossible to review the appropriateness of the proposed modified methodology. We consider it to be completely inappropriate to assign offsetting values to ancient woodland. The implication is that the loss of biodiversity that comes with the removal of ancient woodland can be mitigated for by planting and The Trust considers that this is misleading for both consultees and the decision makers. 12. Wider Effects – The ES identifies three ancient woodlands which may be potentially affected further if works move within the statutory limits of deviation. As any impact on ancient woodland would be significant because it is irreplaceable, The Trust would like confirmation that there are no other ancient woodlands that may be affected by works within the statutory limits of deviation. 13. Precautionary principle – although the ES states that a precautionary approach has been taken, this is not demonstrated within the ES. There are many examples of assumptions that the proposed scheme will not have a negative impact when there is no evidence to back this up. 14. Mapping – HS2 Ltd promised that a GIS overlay of the whole of Phase 1 would be available to accompany the ES. This was finally made available on 24 January 2014 (the original date for the consultation to close), 8 weeks after the consultation commenced. There are 100s of maps contained within the ES and using them to gain an understanding of the whole route has been very difficult. North is not in the same direction on all map sheets so it is difficult to visualise how each map connects to its neighbour. Furthermore, the maps are inadequately labelled and the CFA reports do not contain any map references when referring to landscape features so locating woodlands has been difficult. The poor quality of the mapping means that we have had to resort to using our own maps to understand the content of the ES. In addition, maps showing the statutory limits of deviation are not included within the ES although they are referred to and consultees would need to view them. The HS2 Ltd. helpline did not know where they were located and eventually The Trust found them in the HS2 Ltd. online shop. Again, the inadequacies in the mapping mean that it is hard to see how any decision on the Bill can be based on a robust consideration of the environmental information.
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