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New report reveals that HS2 Ltd got its nature figures wrong

UK Government must require re-evaluation of nature loss and compensation say The Wildlife Trusts

A new evidence report, ‘HS2 double jeopardy: how the UK’s largest infrastructure project undervalued nature and overvalued its compensation measures’ reveals fundamental flaws in the way HS2 Ltd has assessed the value of nature along the construction path of HS2.

It 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.

For example, 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 new analysis finds that HS2 Ltd has hugely undervalued wild places being destroyed along the route – while simultaneously overvaluing the impact of its nature compensation measures.

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 reveals:

  • Across Phase 1 of HS2 (2021 scheme): at least 7.9 times more biodiversity loss than that calculated by HS2 Ltd
  • Across Phase 2a of HS2: at least 3.6 times more biodiversity loss than that 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 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 well established tree-lined 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 –its '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 figures 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. 
blue tit

Bob Coyle

In summary, a comparison of No Net Loss calculations is as follows:

  • For Phase 1 (2021 scheme), our assessment indicates a minimum net loss of 4,367 NNL units (17.36% loss of the pre-construction biodiversity value in NNL Units). This compares to a net loss of 555 NNL units (2.60% loss of the pre-construction biodiversity value in NNL units), as calculated by HS2 Ltd.
  • For Phase 2a, our assessment indicates a minimum net loss of 4,891 NNL units (42.80% loss of the pre-construction biodiversity value in NNL Units). This compares to a net loss of 1,342 NNL units (17.01% loss of the pre-construction biodiversity value in NNL units), as calculated by HS2 Ltd.

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, they 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.”

Craig Bennett

Craig Bennett (c) Trai Anfield

Craig Bennett, chief executive of The Wildlife Trusts 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 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 to our findings while there is still time to change the scheme to limit the adverse impacts and enhance biodiversity – by achieving a minimum 10% biodiversity net gain for replaceable habitats for each phase.
  4. HS2 Ltd should pause all construction immediately and halt the passage of the Phase 2b Hybrid Bill while these new findings are assessed by the Government.

See ‘HS2 double jeopardy: how the UK’s largest infrastructure project undervalued nature and overvalued its compensation measures’ here. The report is based on an investigation by the Evidence and Planning team at Cheshire Wildlife Trust.

Today The Wildlife Trusts have published an open letter to Secretary of State for Transport, Rt Hon Mark Harper, and Secretary of State for the Environment, Rt Hon Thérèse Coffey MP, urging them to work together to address the new evidence about biodiversity loss calculation errors by HS2 Ltd and asking for an immediate pause on construction.  

Editor’s notes

*No Net Loss: To deliver No Net Loss (NNL), the HS2 high speed rail scheme would have to balance damage to biodiversity caused by its construction with at least equivalent gains.  (Any damage to irreplaceable ancient woodland is not part of No Net Loss calculations and compensated for separately.)

 

Biodiversity Net Gain (BNG): means the natural environment should be left in a measurably better state than it was beforehand. HS2’s BNG commitments are voluntary, and not legislated. 10% BNG will eventually be mandatory for development which goes through the usual Local Authority planning route (housing and commercial development). It is not yet a legal requirement, although BNG is in the Environment Act there is a transition period before it takes effect and becomes a legal requirement. For Nationally Significant Infrastructure Projects (NSIPS) it is likely to become a legal requirement in 2025.

 

Analysis of No Net Loss, HS2 phases 1 and 2a:

To replicate HS2 Ltd's approach as closely as possible, Cheshire Wildlife Trust recalculated the impacts to biodiversity caused by the construction of Phases 1 and 2a of the scheme using HS2 Ltd’s own NNL biodiversity units. HS2 Ltd’s own No Net Loss biodiversity units measure the value of different habitats according to their size and how nature-rich they are. For the post-construction assessment (i.e., assessment of nature once the scheme is built) the only amendments were to correct obvious mistakes made by HS2 Ltd.

Using HS2 Ltd’s own data where available and additional information to show the type and quality of each habitat, Cheshire Wildlife Trust interrogated HS2 Ltd’s mapping and assessment of existing nature along the route and found a catalogue of errors. For example, within HS2 Ltd’s pre-construction footprint, many habitats such as field trees, ponds, watercourses and hedgerows are misrepresented, undervalued or in some cases not accounted for at all. This means that HS2 Ltd needs to provide far more nature compensation than it thinks is necessary, due to its serious underestimation on the impacts to nature. 

Much of HS2 Ltd’s data is hard to access. This, combined with HS2 Ltd’s own inadequate methodology means Cheshire Wildlife Trust’s figures in this report are almost certainly an underestimate and are indicative of the scale of the issues, rather than definitive. They are a warning of the likely errors and inaccuracies built into HS2 Ltd's current approach. Comparing the assessments carried out by HS2 Ltd with those carried out by Cheshire Wildlife Trust, it is clear that HS2 Ltd’s figures result in some glaringly inaccurate values for the loss of biodiversity resulting from both Phase 1 and Phase 2a.

 

Flawed HS2 Ltd figures and mapping include:

Significant mapping errors and poor digitisation. Numerous field trees, ponds, other waterbodies and watercourses (ditches and drains) are unaccounted for in the baseline mapping and are therefore excluded from the assessments.

Watercourses: As a result of HS2 Ltd’s flawed No Net Loss metric, there’s no differentiation between rivers, or streams. Any damage caused during the construction of the scheme is essentially unaccounted for and HS2 Ltd is only accounting for the overall loss in length, rather than the nature value of a specific river or stream.

Woodland: HS2 Ltd’s No Net Loss metric overvalues the woodland that the company will create to compensate for the loss of existing species-rich woods by at least half and overvalues grassland it plans to create to compensate for the loss of existing species-rich grassland by at least a third, compared to the current industry standard.

Hedgerows: Many hedgerows have been significantly undervalued in baseline calculations, and overvalued in the post-construction assessments, particularly compared to the current industry standard.

 

HS2 Ltd’s metric:

HS2 Ltd has developed its own distinct, and modified ‘accounting tool’ for nature, based on a 2012 Defra pilot metric. HS2 Ltd has been very clear that it is not using these calculations to inform the provision or the appropriateness of compensatory habitat. The like for like or better rule of the current up-to-date government metric is not being applied. The result is that, for example, many complex and well-developed semi-natural woodland ecosystems will be replaced with simplistic homogenous habitats of little value to wildlife.

In 2016 Natural England reported ‘In light of the wide-ranging issues that using the HS2 NNL metric as an accounting tool has presented, it is recommended that for Phase 2 of the scheme a metric is applied for biodiversity offsetting purposes, i.e., a tool to inform compensation provision. It is considered that this would be beneficial for the natural environment, for reporting purposes and for HS2 Ltd.’

The HS2 NNL calculations demonstrate that HS2 Ltd have not taken on board these particular recommendations from Natural England and the NNL metric is still not being used to inform the type of compensation required. See Review of the High Speed 2 No Net Loss in Biodiversity Metric.

 

HS2 and The Wildlife Trusts

The Wildlife Trusts support the need for better and more sustainable public transport, but nature, which is a vital ally in the fight against the climate crisis, must not pay the price. 

For more than a decade The Wildlife Trusts have highlighted the impacts on nature of the HS2 route, the scheme’s design and the UK Government’s approach to its delivery. In 2014, The Wildlife Trusts set out a ‘Greener Vision’ offering ideas for large-scale nature restoration along the proposed route.

In January 2020, The Wildlife Trusts’ report: What’s the Damage? Why HS2 will cost nature too much highlighted the impacts for wildlife and wild places, increased habitat fragmentation and the possibility of local area extinction of endangered species. It was supported by National Trust, RSPB and Woodland Trust.

HS2 claims it is “the UK’s flagship transport levelling up project ‘Levelling up’ needs to ensure nature, with all the wellbeing benefits it brings to communities living close to the route, does not lose out.

In 2022 Cheshire Wildlife Trust, as the leading local environmental NGO in the area impacted by HS2 Phase 2b, submitted its petition to the High Speed Rail (Crewe-Manchester) Bill. Amongst other objections this cited “a reprehensible lack of transparency regarding how HS2 Ltd has assessed the likely impacts to the natural environment”.

Open Letter to Government: wildlifetrusts.org - link will be available from February 8th

The Wildlife Trusts 

The Wildlife Trusts are making the world wilder and helping to ensure that nature is part of everyone’s lives. We are a grassroots movement of 46 charities with more than 900,000 members and 38,000 volunteers. No matter where you are in Britain, there is a Wildlife Trust inspiring people and saving, protecting and standing up for the natural world. With the support of our members, we care for and restore special places for nature on land and run marine conservation projects and collect vital data on the state of our seas. Every Wildlife Trust works within its local community to inspire people to create a wilder future – from advising thousands of landowners on how to manage their land to benefit wildlife, to connecting hundreds of thousands of school children with nature every year. 

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