Enter Prince Charming, stage right, part 2

(… continued from Enter Prince Charming, stage right, part 1, posted on 7 May 2014).

It would be hard to see the report HS2 and the environment, recently published by the House of Commons Environmental Audit Committee (EAC), as a ringing endorsement of the HS2 Phase 1 Environmental Statement; it is so obviously quite the opposite. The EAC criticises the ES on the grounds that:

  • The aim of achieving no net biodiversity loss, which the compensation measures in the ES seek to attain, is too low an objective, and a net biodiversity gain should be the aspiration (paragraph 12).
  • The ES fails to demonstrate that the “mitigation hierarchy” principle has been followed, with there being obvious confusion between “mitigation” and “compensation” measures (paragraph 18).
  • The ES fails to present “a clear baseline of the state of habitats and biodiversity before the project commences”, chiefly due to only 60% of the route having been surveyed (paragraph 20).
  • The EAC expresses reservations about the offsetting metric that has been developed for the ES, particularly as “Defra are still finalising the standard metric for offsetting”, and feels that there is a danger of the value of offset land being over-expressed in the calculations, whilst habitat being lost is undervalued (paragraph 35).
  • The EAC is of the view that any proposals to offset the loss of ancient woodland should be treated separately and not, as appears to have been the case in the ES, included in the overall “no net biodiversity loss” calculation (paragraph 36).
  • The “discount factor for time”, i.e. the time taken for new habitat to reach “target condition”, that has been employed in the ES “does not fully represent the extent of the environmental harm from the potential delays” in reaching this condition (conclusion 4).

The EAC’s criticisms imply that revisions will be required to the ES, which is something that follows anyway from the changes in Camden suggested by Sir David Higgins. However, we can expect the amendments required to address the EAC’s complaints will be more extensive, having route-wide implications. The EAC report makes two specific recommendations in this respect (paragraph 22 and paragraph 19, respectively):

  • “HS2 Ltd must carry out outstanding environmental surveys as soon as possible. It should focus particularly on cataloguing all ancient woodland and protected animal species, and as much as possible of the 40% of the route yet to be examined by involving local wildlife groups where possible.”
  • “The HS2 Environmental Statement must be revised to distinguish clearly between ‘mitigation’ and ‘compensation’ measures in respect of biodiversity, and to explain the factors determining in which cases these should be applied.”

According to the EAC report (paragraph 21) HS2 Ltd told the Committee that “further surveys would be carried out”. The DfT explained that, if any new survey data identified a “new significant environmental effect” not already reported in the ES, then supplementary environmental information would have to be deposited in Parliament. I’m sure that the consultation-fatigued will be delighted to learn that any such supplementary information would be, according to the DfT, “subject to the minimum of 42 days’ public consultation”, and that the submissions made to that consultation would be “summarised by a technical assessor appointed by Parliament”, a process that we have just seen with the ES as a whole.

That the survey work underlying the environmental impact assessment is woefully incomplete is not entirely the fault of HS2 Ltd. As things stand at the moment, HS2 Ltd can only access private land to undertake survey work with the permission of the owner of that land. That a significant number of landowners have withheld the necessary permission is, in some cases, due to resentment about the impacts that HS2 would have leading to a degree of bloody-mindedness. However, from my own discussions with landowners, I feel bound to say that HS2 Ltd contributed to this problem in no small way by the crassness with which they, or more specifically the agents that were employed, handled the relationships with those that they were seeking to persuade to grant access. It would appear that many were not tempted even by the cash on offer should they sign on the dotted line.

In my next posting I will look further at this problem of accessing land to carry out environmental surveys.


One response to this post.

  1. Posted by chriseaglen on May 20, 2014 at 1:11 pm

    Oh what a pantomime. Time to get ready for the next round of petitions. People have learnt environment is a weasel word which cannot embrace its scope. Hopefully we all realise how the defending NGOs turn collaborators not defenders. Hmg failed in governance and behaved out of the bounds as sustainabully and complied with austerity. Vote for this group on Thursday and fools are led by hypocrits in the eu and uk.


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