Not necessarily a good thing, part 3

(… continued from Not necessarily a good thing, part 2, posted on 15 Jul 2016).

Another important criticism made by the Woodland Trust when it gave evidence to the Commons HS2 Select Committee in support of its petition concerned the way that HS2 Ltd had performed its “no net loss calculation”. The Trust’s witness, its Senior Conservation Adviser Richard Barnes, cited in particular that “the current metric used by HS2 Limited assumes that the loss of irreplaceable habitat and ancient woodland can be offset”. According to Mr Barnes, “that doesn’t reflect government policy nor what Defra or Natural England have suggested”. He also alleged that HS2 Ltd had, in contravention of national planning policy guidance, awarded a “lower evaluation” in the calculation to plantations of ancient woodland sites than to semi-natural ancient woodland and that, to add to all this, HS2 Ltd had simply got its sums wrong (see footnote 1).

Mr Barnes told the Committee that, in contrast to what HS2 Ltd had done, the “impacts on the irreplaceable habitat should be considered separately” when making a no net less calculation, and that “the scale of compensation proposed should use a bespoke metric that reflects the likelihood of success”. It was not appropriate to lump irreplaceable habits in with those that could be reasonably recreated. As Mr Barnes put it, “you’d look for them having a caveat that what they’re doing for no net loss doesn’t take into account the actual residual loss of ancient woodland” (see footnote 2). To do other than this results, in words displayed by Mr Barnes on one of his evidence slides, in “a fundamentally flawed approach”.

Readers who have put up with me for some time will know that so-called habitat translocation is a particular bête noire of mine (see footnote 3), and I was pleased to hear that Mr Barnes is not, it appears, its biggest fan either. In the first place, he described the term “habitat translocation” as “inaccurate really”, in that it does not reflect “the partial nature of what is being moved”; he noted that Natural England refers to it as “a salvage operation”. He added, “it’s not done like an archaeological dig with a trowel and a brush”: showing an image of a mechanical digger at work, he likened the technique as “very much an engineering operation” and described it as “done with a digger and dumper trucks and then spread again with diggers” (see footnote 4).

He stressed that habitat translocation “has to be done very carefully and you have to stick to the process prescribed in the best practice if you are going to do that”, and also expressed strong reservations about whether the right timing to carry out the operations involved would be observed in practice. He referred to “a narrow window of opportunity”, which is “different for the ancient woodland soil than it is [for] coppice stools”, where the latter are also being moved. This dictated that, for the process to be carried out correctly, “the translocation timing should dictate the engineering programme”. Mr Barnes reflected that the Trust’s “experience is that that doesn’t happen: the engineering operation happens and the translocation is done at the time that is convenient for the engineering operation, not vice-a-versa”. He added ruefully “there’s plenty of examples of that, unfortunately” (see footnote 5).

Now, don’t get me wrong, I can see that, if you’re going to trash a piece of ancient woodland, then there is nothing wrong with spreading the soil that you remove in another location that could do with some additional biodiversity. The problem is, as Committee Member Mike Hendrick MP astutely spotted, that habitat translocation is “being sold as if it’s like for like”, or as Mr Barnes put it, “plopping it somewhere else in the same state”. But, according to Mr Barnes, there is “no proof that it does actually produce the benefits that are indicated or suggested” – so it’s, in all probability, a dangerous delusion (see footnote 6).

Mr Barnes summed up all that he had told the Select Committee about the Promoter’s approach towards ancient woodland as having “fallen woefully short of adopting best practice”. He said that, in view of HS2 being a major project, the Trust was “particularly concerned that HS2 mustn’t create a precedent”. He made a plea direct to the Committee (see footnote 7):

“We would like the Committee to state that it accepts that this is the case because it’s vital to ensure that HS2 does not set a precedent and is not held up as an example of best practice, especially for the next phases of HS2.”

At least one Member of the Select Committee, Mark Hendrick MP, appeared to get the message that, perhaps, HS2 Ltd’s environmental credentials should be subjected to some outside scrutiny. On the afternoon of the same day as the Woodland Trust had made its morning appearance in Committee Room 5, he remarked to Matt Jackson, Head of Conservation Policy and Strategy Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust (see footnote 8):

“Again, if HS2 are judging, or marking their own homework, as far these metrics and biodiversity is concerned, that’s not necessarily a good thing, is it?”

Despite this Member’s apparent unease, and a direct recommendation in a letter from the House of Commons Environmental Affairs Committee that the Select Committee should “comment and report to the House [of Commons] on any issue relating to the environmental impact of HS2”, the Select Committee avoids commenting directly in its Final Report on the issues raised by the Woodland Trust by:

  • directing the Promoter to identify an independent third party arbiter to review the different net loss metrics and publish its findings (paragraph 303 of the Final Report); and
  • suggesting that “colleagues in the Lords may wish to consider … issues arising from the only recently published no net loss calculations (paragraph 304 of the Final Report).


  1. The Woodland Trust’s hearing made be viewed from 11:45hrs in the video and is reported from paragraph 306 in the transcript of the morning session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016. The quotations are taken from paragraph 335 of the transcript. “Ancient semi-natural woodland” is mainly made up of trees and shrubs native to the site, usually arising from natural regeneration, whereas “plantations on ancient woodland sites” are areas of ancient woodland where the former native tree cover has been felled and replaced by planted trees, usually of species not native to the site. Both types of woodland are afforded equal protection under the National Planning Policy Framework.
  2. See paragraph 335 of the transcript of the morning session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016.
  3. See, for example, my blog The answer lies in the soil (posted 8 Mar 2012).
  4. See paragraph 349 of the transcript of the morning session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016. For a discussion of the impacts that such treatment might have on soil biodiversity see paragraphs 350 to 363 in that same transcript.
  5. See paragraph 373 of the transcript of the morning session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016.
  6. See paragraphs 364 and 365 of the transcript of the morning session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016.
  7. See paragraph 375 of the transcript of the morning session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016.
  8. See paragraph 190 of the transcript of the afternoon session of the Commons HS2 Select Committee held on Tuesday 3rdFebruary 2016 – ignore the date on the title sheet of the transcript, which is incorrect.

Important Note: The record of the proceedings of the Commons HS2 Select Committee from which the quotes reproduced in this blog have been taken are uncorrected transcripts of evidence, which are not yet an approved formal record. Neither witnesses nor Members have had the opportunity to correct the record in such instances, and it may therefore be subject to changes being made in the light of any such corrections being requested.




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