HS2: is it worse than you think?

9th March 2023:

It has come to light that the UK government is set to announce that construction of certain sections of HS2 will be delayed in “an attempt to cut costs”. This includes sections from Manchester - Crewe as well as Birmingham – Crewe, major parts of the scheme, which should see ‘no net loss’ of biodiversity and a ‘net gain’ in biodiversity respectively.   

Nikki Williams, director of campaigning and communities at The Wildlife Trusts, says: 

“HS2 has been plagued by problems from the start, especially the devastating impact on nature and evidence of inaccuracies in calculating how wild places are affected, combined with serious doubts over the projects’ ability to effectively make up for that loss. 

“We have been calling for a pause so HS2 Ltd can revisit its figures and ensure it will provide sufficient compensation for nature loss along the route. 

New plans to delay because of spiralling costs provides an opportunity Government must take to ensure HS2 fulfils stated commitments around ‘No Net Loss' of biodiversity along Phase 1 and Phase 2A of the route, and ‘Biodiversity net gain' along Phase 2B.” 

Over 78,00 people have already signed our open letter demanding urgent action to ensure the errors HS2 Ltd has made that have been revealed in our report are urgently resolved.   

It’s critical that any delays to the scheme involve a rethink around the levels of loss, and impacts on nature. 

It is vital that the assessments around the impacts on nature by HS2 Ltd are accurate and up to date, as these are what informs the HS2 route construction and design. These calculations also inform the plans HS2 Ltd is making to achieve ‘net gain’ further up the route.

Our audit reveals major issues in the way the data has been collected and assessed. In addition, our own assessment of the actual loss is very different to that claimed by HS2 Ltd.

HS2 is the UK’s largest infrastructure project of any kind - and has repeatedly been upheld as ‘world beating’ by politicians.

Yet it is clear that there has been limited in-depth scrutiny of the HS2 Ltd nature data by the UK Government, or understanding of the ecological assessments done to date – which has led to this situation with the nature loss sums

It is critical that the UK Government take action now to remedy this, especially given the level of construction already taking place, and in the context of continued nature loss across the UK and the world.

Wildlife Trusts have campaigned to influence the design and route of HS2 since 2012.

• 14 Wildlife Trusts have been directly impacted by HS2 since the scheme began

• 11 Wildlife Trusts are in counties affected by current plans

• 4 Wildlife Trusts will have nature reserves compulsory purchased under current plans

The Wildlife Trusts have previously published two evidence reports, around costing out a truly ‘green corridor’ and presenting the risks to nature from HS2 plans (‘What’s The Damage’.)

In 2020 64,000+ people signed a petition asking the Prime Minister to “pause and rethink HS2” based on ‘What’s The Damage’, a The Wildlife Trusts evidence report setting out the risks to nature from HS2 including of local species extinctions.

We intend to hand in a physical copy of the letter, with the number of co-signatories and a copy of our report, direct to the Secretaries of State for the Department for Transport (DfT) and DEFRA, and to the Prime Minster at the same time.

High Speed Two (HS2) Limited (HS2 Ltd) is the company responsible for developing and promoting the UK’s new high speed rail network. It is funded by grant-in-aid from the UK Government. HS2 Ltd is an executive non-departmental public body, sponsored by the Department for Transport.

HS2 Ltd is responsible for HS2, and the Department for Transport (DfT) is responsible for HS2 Ltd. Defra is responsible for the government’s policies around nature’s recovery and biodiversity net gain. Our Open Letter is addressed to the Secretaries of State for transport and for the environment; we include Defra in this campaign along with DfT as it’s crucial the two departments recognise the interdependencies here – nature loss is something Defra is responsible for tackling and the DfT is responsible for ensuring national transport infrastructure is delivered to a high standard. Right now, what HS2 Ltd is doing will impact on both departments.

In addition, while some Wildlife Trusts work closely with HS2 Ltd locally and remain an active partner to try achieve the best result for nature along the route, we have regularly requested better communication, engagement and for more detailed plans and data so that we can better advise. These requests have largely been ignored in the past and we do not want to continue wasting precious charitable funds and time, during a nature loss crisis relying on HS2 Ltd for a genuine, helpful response.

The DfT is ultimately responsible for HS2, but as Defra is responsible for nature recovery targets and this audit shows serious discrepancies between official loss sums which will affect Defra’s ability to deliver its priorities, it is vital that DEFRA also understands the issues and ultimately can play its part in making sure these are resolved.

We didn’t intend to. Originally, we were looking at the data to try to understand the impacts of nature loss and the plans for net gain locally, in order to fully assess the local Wildlife Trust response, or the level of support that Wildlife Trusts could offer to help other landowners manage nature impacts.

When we started our search however, we found strange and unexpected errors which raised several questions that we have been unable to comprehensively answer. Looking further into the data, we saw habitats wrongly identified and various assumptions made in the official calculations that just didn’t make sense – like, all road verges along the route are 1 metre wide; like, the assumption that new hedgerows planted elsewhere will be worth, in 10 years’ time, more to wildlife than existing mature hedges due to be lost along on the route.

We have repeatedly raised the fact that details are lacking from HS2 Ltd’s plans; we have repeatedly requested all data and methodologies around nature impacts and asked for detailed plans for next gain.

We raised this most recently at Transport Select Committee (Nov 2022)

Prior to this, CEOs from Wildlife Trusts impacted and the CEO of The Wildlife Trusts movement met with HS2 Ltd and the then-HS2 Minister, and we wrote to HS2 Ltd in May 2021 following this meeting setting our request again. We also asked MPs to speak at a Westminster Hall debate in Sept 2021 to highlight the limitations in the details provided and the data available.

We have sent our report to HS2 Ecology Review Group (of which we are a member) and invited peer review. The Group includes representatives from HS2 Ltd, local authorities, statutory bodies and environmental organisations. 

and charities, including The Wildlife Trusts. The group was set up to review the outputs of monitoring for habitat creation sites and make recommendations for remedial action where appropriate. We have also sent the report to Natural England.

Responding to the report, a HS2 Ltd spokesman said:

HS2 Ltd: “We don’t recognise the figures from the report nor do we believe them to be reliable. The Wildlife Trusts have undertaken limited desk research and have not accessed huge areas of land for undertaking ecological survey, in contrast to the ecologists who have compiled HS2’s data. Independent experts from Natural England have consulted on our methodology and it has been rigorously assessed by a team of professional ecologists, with the data shared with the independent Ecological Review Group. We’re committed to reviewing our assessment methodology on an ongoing basis and intend to align more closely with the Government’s biodiversity metric once it is published in the coming months.

The Wildlife Trusts: Dr Rachel Giles, Evidence and Planning manager Cheshire Wildlife Trust said:

“Our objective was to reveal the true impacts to biodiversity as a result of HS2.  We have carefully analysed all the available data including HS2 Ltd’s own survey data. We only amended HS2 Ltd’s survey data when it was very clear mistakes had been made, or to improve the accuracy.

“For example, HS2 Ltd applied a standard buffer on arable field margins, whereas we mapped actual arable margins.

“We looked at every single land parcel and all the available data, including HS2 Ltd’s own survey data, and made a professional judgement on habitat distinctiveness. We have included habitats which HS2 Ltd missed, for example failing to include individual field trees or failing to include all the ponds.

“HS2 Ltd has published its No Net Loss figures years before it published the supporting data sets, - so there wasn’t the opportunity for timely review or independent scrutiny.  Because of this delay, it has taken four years for the extent of the issues to be finally recognised.”

HS2 Ltd said “Independent experts from Natural England have consulted on our methodology and it has been rigorously assessed by a team of professional ecologists, with the data shared with the independent Ecological Review Group.

The Wildlife Trusts: Dr Rachel Giles, Evidence and Planning manager Cheshire Wildlife Trust said :

“In 2016 Natural England raised serious concerns about HS2 Ltd using its own accounting tool, and made recommendations that it should update its methods, but HS2 Ltd has yet to fully address this. 

Natural England examined HS2 Ltd’s metric and concluded:

‘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 No Net Loss calculations demonstrate that HS2 Ltd has not taken on board these particular recommendations from Natural England and the No Net Loss 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. Natural England, 2016, Review of the High Speed 2 No Net Loss in Biodiversity Metric.

Rachel Giles sits on the independent Ecology Review Group to which HS2 Ltd released its figures without all the supporting data. The group was not given the opportunity to contribute to the development of the No Net Loss metric despite some members of the group raising serious concerns.

HS2 Ltd said “We’re committed to reviewing our assessment methodology on an ongoing basis and intend to align more closely with the Government’s biodiversity metric once it is published in the coming months.

The Wildlife Trusts: Dr Rachel Giles, Evidence and Planning manager Cheshire Wildlife Trust said:

“It’s good to hear that HS2 Ltd is considering a change to their approach. Our door is open to HS2 Ltd to try and solve these issues. Aligning more closely with the Government’ biodiversity metric is a positive step, but HS2 Ltd has to be open about any changes it makes to the Government’s metric, and these must be transparent, and evidence based. We would welcome HS2 Ltd aligning with a metric such as one directly comparable to the government’s current Biodiversity Metric 3.1. because this is a way of measuring nature that also ensures appropriate biodiversity compensation is provided.

“However, importantly in the light of its flawed figures. HS2 Ltd needs to reassess biodiversity along the whole route which will mean they need to provide more, additional and appropriate nature compensation than they’re currently offering.”

HS2 Ltd said “As well as delivering the country’s largest environmental programme, planting seven million trees and creating over 33 square kilometre of new habitats on Phase One alone, we continue to minimise loss through design refinements, such as our recent 30% reduction of the impact on ancient woodlands on Phase One.”

The Wildlife Trusts: Dr Rachel Giles, Evidence and Planning manager Cheshire Wildlife Trust said:

“HS2 Ltd is a huge construction project, not an environmental programme, and will leave a huge scar across our countryside. At the moment it is not meeting its own No Net Loss nature targets. It needs to leave nature in a better state than when it started work, by creating additional good quality spaces for the natural world. This is hugely important in this time of nature and climate crises. We are one of the most nature depleted countries in the world and so it is important that HS2 signs up to biodiversity gain across the whole route of high-speed rail.”

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