Sign our open letter

Today, a new evidence report reveals fundamental flaws in the way HS2 Ltd has assessed the value of nature along the construction path of HS2 in Warwickshire and beyond.

‘HS2 double jeopardy: how the UK’s largest infrastructure project undervalued nature and overvalued its compensation measures’ finds that HS2 Ltd has hugely undervalued natural habitats and the wildlife that is being destroyed by the construction along the route – while simultaneously overvaluing the impact of its nature compensation measures.

Phase 1, which covers 140 miles of track between London and the West Midlands, will cause at least 7.9 times more nature loss than accounted for by HS2 Ltd. The report finds that HS2 Ltd used its own modified ‘accounting tool’ to assess nature loss on the route, despite a 2016 recommendation from Natural England to introduce a specific metric for nature compensation. As a result, existing habitats such as woodlands, watercourses and hedgerows were frequently recorded as lower quality than up-to-date data would suggest.

The report concludes that figures released by HS2 Ltd in 2017, 2019 and in 2021 are ‘wholly unreliable’ and do not reflect the full extent of nature loss along the route. This period of construction included controversial works at South Cubbington and Crackley woods in Warwickshire. 

Phase 1 will cut a swathe across Warwickshire, and work has already had devastating effects on wildlife in the south of the county. The track and associated lineside fencing will severely damage connectivity across the landscape, meaning that wildlife including bats, deer, and many other mammals will have fewer natural corridors for movement and foraging. The lack of provision of green bridges for crossing points over the line will exacerbate this loss of connectivity.

Bats and birds depend upon connected woodlands and hedgerows for food, shelter and nesting sites. HS2 Ltd have not fully assessed the estimated impacts of the track on specific species, nor addressed these. Warwickshire Wildlife Trust is extremely concerned that losses of important wildlife habitats, such as woodlands, grasslands and hedgerows, will go unchallenged due to the undervaluing of nature uncovered in the report.

Ed Green, chief executive of Warwickshire Wildlife Trust says:
'This new evidence is damning and reveals a host of inaccuracies that are built into HS2 Ltd's current approach. Our report exposes the absurdity of allowing HS2 Ltd to self-regulate without proper transparency and independent oversight. The company needs to be held to account by the Government for its failings.

'HS2 Ltd must correct its mapping and errors in its figures and make all its new data publicly available. This vast infrastructure project is taking a wrecking-ball to wildlife and communities are in despair at losing the wild places – the woods, meadows and wetlands that they love - they will never get these back. So HS2 Ltd must repair nature in a way that’s commensurate with the magnitude of the damage being caused.

'The scale of errors means HS2 Ltd needs to provide far more nature compensation than it’s currently offering because it has seriously underestimated the impacts to biodiversity. We want to see a minimum of 10% biodiversity net gain along every phase of the route. This is surely the absolute bare minimum that HS2 Ltd should be offering after all the destruction and heartbreak it has caused.'

The evidence report is a review of the No Net Loss* data for HS2 Phases 1 and 2a and was commissioned by The Wildlife Trusts. It finds:
•    Across Phase 1 of HS2 (2021 scheme): at least 7.9 times more biodiversity loss than calculated by HS2 Ltd
•    Across Phase 2a of HS2: at least 3.6 times more biodiversity loss than calculated by HS2 Ltd 

HS2 Ltd promised that nature would not lose out when much-loved natural areas and important habitats were destroyed to make way for construction of the high-speed rail line. It made a commitment to No Net Loss of biodiversity for replaceable habitats along Phase 1 and 2a of the route, and a net gain for biodiversity along Phase 2b. 

Compensating for nature losses relies on accurate baseline assessments of the value of wildlife habitats along the route – for example, by looking to see how species-rich the grasslands are or how diverse woodlands are in terms of the mix of native tree species and complexity of woodland structure, the quality of the understorey and woodland floor plants.

The report found watercourses, ponds and trees which have been missed out of the data, and problems with the way nature is being valued. For example, many tree-lined, well established and species-rich hedgerows, which provide berries, shelter and nesting places for wildlife, have been given a lower nature value than the new hedgerows that HS2 Ltd is going to plant.
  
The new report which is published today finds that HS2 Ltd's No Net Loss metric – their 'accounting tool' for assessing impacts on nature – is untested, out of date and fundamentally flawed. Taking a conservative approach to the data, the report highlights alarming errors in HS2 Ltd’s calculations and mapping, indicative of a large-scale problem, which calls into question the adequacy of all HS2 Ltd’s nature restoration and compensation plans.

•    Our Phase 1 calculations show that there will be at least 17% less nature present after construction than there was before building started. HS2 Ltd’s figures say there will only be a 2.6 % nature loss.  
•    For Phase 2a, we found that there will be at least 42% less nature present after construction than there was before building started. HS2 Ltd’s figures say there will only be a 17.01% nature loss. 

As things stand, HS2 Ltd will not compensate sufficiently for the damage likely to be caused by Phases 1 and 2a of the scheme. If HS2 Ltd continues to use the same metric, it will not come close to delivering a Net Gain for Biodiversity for Phase 2b. 

Dr Rachel Giles, Evidence and Planning Manager at Cheshire Wildlife Trust and author of the report, says: 
'We’ve been shocked by the errors and discrepancies that our audit revealed. HS2 Ltd must stop using a deeply flawed method to calculate the value of nature affected by the construction of the route. It is astonishing that a flagship infrastructure project is able to use a metric which is untested and not fit for purpose. 

'HS2 Ltd should urgently recalculate the total loss to nature, by re-evaluating existing biodiversity along the entire route whilst there is still time to change the scheme’s design and delivery.' 

The Wildlife Trusts’ recommendations:
1.    HS2 Ltd should re-map existing habitats along Phases 1 and 2a, correcting mapping errors, applying the correct nature values to habitats, and ensuring no habitats are excluded. 

2.    HS2 Ltd should recalculate the total impacts to nature, by using an up to date and proven methodology, such as one directly comparable to the government’s current Biodiversity Metric 3.1. If changes to the methodology are made these should be transparent and evidence-based. It is critical that HS2 Ltd ensures all data is made publicly available at the point the figures are released to facilitate transparency and enable independent scrutiny.

3.    The Government should respond swiftly to our findings, while there is still time to change the scheme’s design and delivery to limit the adverse impacts and enhance biodiversity in a way that is commensurate with the scale of the damage – by achieving a minimum 10% biodiversity net gain for replaceable habitats for each phase of the scheme.

4.    HS2 Ltd should immediately pause all construction and enabling works and halt the passage of the Phase 2b Hybrid Bill whilst these new findings are assessed by the Government.