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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 along the route – while at the same time overestimating the benefits of the planned nature compensation measures. This will leave nature in a much worse state than HS2 Ltd claim.

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 has 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. This is calculated using an accounting tool metric which is untested, out of date and fundamentally flawed.

By contrast, new rules for wildlife coming into force in November this year require all new developments over a certain size to provide 10 per cent gain for biodiversity, using a much more accurate metric, developed and consulted upon over several years.

The Wildlife Trusts report covers Phase 1 and Phase 2a of the route. Phase 2a spans from Fradley, just north of Lichfield, past Stafford and Stone, and then north near Madeley towards Crewe. This stretch will cause 3.6 times more nature loss than that accounted for by HS2 Ltd.

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 that calculated by HS2 Ltd
• Across Phase 2a of HS2: at least 3.6 times more biodiversity loss than that calculated by HS2 Ltd.

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 mature, species-rich hedgerows with huge trees, which provide berries, shelter and nesting places for wildlife, have been given a lower nature value than the brand new hedgerows that HS2 Ltd is going to plant.

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.

• Phase 1 calculations show that there will be at least 17 per cent less nature present after construction than there was before building started. HS2 Ltd’s figures say there will only be a 2.6 per cent nature loss. 

• For Phase 2a, we found that there will be at least 42 per cent less nature present after construction than there was before building started. HS2 Ltd’s figures say there will only be a 17.01 per cent nature loss. 

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

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

Kate Dewey, Senior Planning Officer at Staffordshire Wildlife Trust, says:

“This new evidence is damning and reveals a host of inaccuracies in 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. Communities are in despair at losing the wild places that they love – woods, meadows and wetlands. Once lost we will never get these unique places back.

“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 per cent 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 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 per cent 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.

Read , ‘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.

Members of the public can sign this open letter to show support here.