HS2 Ltd have got their nature calculations wrong
Nature loss on the HS2 route - could it be even worse than we thought?
HS2 Ltd, the company responsible for the HS2 railway, had promised to make up for the damage the route would cause to nature.
Concerned by the huge risk to wildlife that the current route poses, we've spent almost a year looking into the official HS2 nature loss calculations. And the numbers don't add up. No-one has checked the detail. Until now.
During our audit we found seriously flawed and out-of-date methodologies and a long list of errors - including habitats wrongly identified or undervalued by the company, and new planting overvalued.
The evidence shows that far more nature will be lost along the route than anyone ever expected.
Why does this matter?
This data is being used to assess the habitat creation HS2 Ltd will be doing to try and make up for the damage caused on the route (known as 'biodiversity net gain'). But the baseline is wrong, because of all the errors and miscalculations our report exposes - which means even more of our wildlife could be lost than has been claimed. Meaning not enough nature will be put back!
Our report:
- highlights major errors and concerns with the methodology and calculations HS2 Ltd has used to determine the scheme’s design, the environmental impact calculations and their proposed habitat mitigation
- sets out the changes we advise the UK Government to sanction, so the truth about the impacts on nature can be confirmed
- makes the case for an immediate pause on Phase 1 construction and on the current Phase 2 legislative process whilst the issues above are rectified.
You can help us #DefendNature today - sign on to our Open Letter and demand action.
It's not too late!
The UK Government must compel HS2 Ltd to re-map the route correctly, re-calculate the damage in full and re-assess what is then needed to achieve 'net gain'. The Department for Transport and DEFRA must work together so HS2 Ltd can fix its mistakes and find the truth.
Because of the gravity of this situation, all HS2 construction on Phase 1 must halt now - and the Phase 2b Hybrid Bill (which will give HS2 Ltd formal permission to work towards 'net gain') must stop progressing through Parliament.
Add your name to our open letter
Rt Hon Mark Harper MP and Rt Hon Thérèse Coffey MP
Dear Secretaries of State,
An urgent call to address new evidence of ecological assessment errors by HS2 Ltd
We write collectively to bring a new report to your attention which shows that the environmental cost of HS2 is far higher, and more serious, than HS2 Ltd has claimed.
We know you will both find this state of affairs unacceptable. However, we believe it is still possible to prevent more ecosystem damage, to limit the further destruction by HS2 of important habitats and to also ensure best use of taxpayers’ money.
Please work together using your respective powers to oblige HS2 Ltd to:
- 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.
- Re-calculate 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 ensure all data is made publicly available at the point the figures are released to facilitate transparency and enable independent scrutiny.
- Immediately pause all construction and enabling works and halt the passage of the Phase 2b Hybrid Bill while these latest audit findings are assessed by the Government.
- 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 i.e. by achieving a minimum 10% biodiversity net gain for replaceable habitats for each phase of the scheme.
An immediate pause on Phase 1 construction and on the advancement of the HS2 Phase 2a: High Speed Rail (West Midlands to Crewe) Act 2021, are both imperative.
These steps must be taken immediately if the UK Government is to deliver a world-leading national infrastructure project that supports nature’s recovery, as was promised. Inaction would also see the UK Government betray its own commitment to ‘leave the environment in a better state for the next generation’ as well as negate recent global commitments made at COP27 and at COP15 that are designed to achieve the Government’s aim of seeing 30% of our land and sea protected for nature by 2030.
We trust you will do the right thing.
Yours sincerely,
Frequently Asked Questions
Why does this matter?
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.
What’s your history with HS2 and HS2 Ltd?
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.
What will you do with the Open Letter?
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.
Why isn’t HS2 Ltd the target of the campaign?
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.
Why are you targeting DEFRA as well as DfT? This is a rail scheme.
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.
Why have you produced this report?
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.
Have you raised these issues with HS2 Ltd or the UK Government before now?
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.
How have you reviewed your findings?
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.
HS2 Ltd responds to our report
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.”