Compensation culture, part 7

(… continued from Compensation culture, part 6, posted on 8 Mar 2017).

As I reported in my blog One myth busted (posted 16 Nov 2016), the results of the biodiversity offset calculation for Phase 1 of HS2 demonstrate that there would be a reduction of approximately 3 per cent in biodiversity units caused by the project. HS2 Ltd see this as representing “good progress … towards the goal of no-net loss” (see footnote 1).

But employing this single figure to measure the environmental credentials of the project is, I suggest, far too simplistic.

In the first place there is the stricture in Biodiversity 2020 that “losses should be offset by gains in other important species and habitats, not by replacing the rare and threatened with the commonplace, but by ensuring the natural environment remains diverse and continues to provide essential services” (see footnote 2). This requirement is reflected in the guidance notes that were issued by the Department for Environment Food and Rural Affairs (Defra) for developers taking part in the biodiversity offsetting pilots. These notes set rules for “matching” lost and offset habitat types that call for the loss of high distinctiveness habitat to be offset by high distinctiveness habitat, and “usually [of] the same habitat type”, and for medium and low distinctiveness habitat loss to be offset by medium or high (see footnote 3).

On the basis of the summary of the offset calculations that I reported in part 6, HS2 Phase 1 is falling far short of these requirements if either the woodland and woodland/scrub habitats or the “other habitats” are considered, alone. HS2 Ltd might be able to argue that the shortcomings in offsetting these habitat types that the analysis has revealed are balanced by the appreciable gains and trade-ups that have been demonstrated for grassland, since Biodiversity 2020 allows that “pragmatically unavoidable losses in one type [of habitat] could be balanced by gains in others” (see footnote 1). However, as far as I can see, no such justification has been attempted by HS2 Ltd: plainly, a justification is needed why it has not been possible to do better for woodland and the other habitat types and that the grassland improvements truly compensate for this failing.

The position with hedgerows appears to be even worse. The Defra guidelines for developers emphasise the importance role that hedgerows play in our countryside; their contribution to biodiversity “by area” being “far greater than even the most biodiversity rich habitats” (see footnote 4). The guidelines stipulate that “loss will need to be offset with like for like habitat” and that only “planting new hedges” is an appropriate offset. Defra also requires offset calculations for hedgerows to be “measured in metres, rather than biodiversity units” (see footnote 5). Defra also stipulates that the condition of the lost hedgerow should be taken into account when determining the appropriate linear run of offset hedgerow to be created: if the condition of the lost hedge is poor then the offset should be at least the same length as the one lost; in the case of a hedgerow in moderate condition, then at least twice its length of offset is required; and, if the lost hedgerow was in good condition the offset should be at least three times its length (see footnote 6).

HS2 Phase 1 clearly fails to come anywhere near meeting the Defra guidelines for hedgerows. The HS2 Ltd offset calculation reveals that 444km will be lost and replaced by 397km: so, not even a one-for-one offset is being offered. If the assumption that I referred to in part 6 that a proportion of boundary hedgerows will not be reinstated is made, then the length of offset hedgerow expected should prudently be reduced by ten per cent to 358km, so the expected replacement ratio, by length, falls to 0.8 (see footnote 7).

I suggest that the above observations indicate that HS2 Ltd needs to do some serious rethinking about its policy towards offsetting, and should be looking at providing additional offsetting away from the bill limits. Notwithstanding, a total rethink of the policy is required anyway, in the light of the Promoter’s agreement, announced to the Lords HS2 Phase 1 Select Committee and reported in my blog Cutting out the old wood, part 1 (posted 10 Dec 2016), that ancient woodland and, I think, other irreplaceable habitat should be removed from the no net loss calculation and, instead there should be, according to Natural England (see footnote 8):

“Separate non-metric reporting for irreplaceable habitats and protected areas should include an explanation of how and where compensation is being provided and the considerations given to site-by-site compensation design, and should set that compensation in the context of legislation and national planning policy.”

It is to be hoped that setting the proposed compensation “in the context of legislation and national planning policy” will encompass an explanation of why the loss cannot be avoided or mitigated.

What Natural England hasn’t explained is the impact that the removal of irreplaceable habitat from biodiversity offset calculation will have upon the HS2 Ltd No net loss in biodiversity calculation document. This document can no longer claim to have the aim to demonstrate the achievement of “no net loss in biodiversity at a route-wide level” since some of the habitat loses and offset gains will no longer be included (see footnote 9). HS2 Ltd will no longer be able to claim that no net loss has been achieved, and the document will have no relevance.

(To be concluded …)


  1. See paragraph 4.1.2 in the report HS2 London-West Midlands No net loss biodiversity calculation, HS2 Ltd/Department for Transport, December 2015. The calculation reflects the design and mitigation including changes up to and including Additional Provision 4 and does not reflect the agreement to remove irreplaceable habitats from the analysis.
  2. See paragraph 3.10 of the publication Biodiversity 2020: A strategy for England’s wildlife and ecosystem services, Defra, August 2011.
  3. See Table 4 in the publication Biodiversity Offsetting Pilots: Guidance for developers, Department for Environment, Food and Rural Affairs (Defra), March 2012.
  4. See paragraph 35 in Biodiversity Offsetting Pilots: Guidance for developers.
  5. See paragraph 36 in Biodiversity Offsetting Pilots: Guidance for developers.
  6. See paragraph 37 and Table 5 in Biodiversity Offsetting Pilots: Guidance for developers.
  7. See paragraphs 37 and Table 5 in Biodiversity Offsetting Pilots: Guidance for developers.
  8. See paragraph 3.21 in the report Review of the High Speed 2 No Net Loss in Biodiversity Metric, Natural England, November 2016.
  9. See paragraph 1.2.1 in HS2 London-West Midlands No net loss biodiversity calculation.

One response to this post.

  1. Hi the other irreplaceable habit type that needs urgent consideration is wetlands. In Hillingdon HS2 is set to destroy the Colne Valley wetlands. This includes moving drinking water extraction points, destroying riparian zone trees (protected under the WFD) and polluting water bodies, lakes, rivers and the Grand union Canal. Who is monitoring this. Oh yes HS2!!!!!
    Come and show your support for our wild life and join us along the 2km of GUC in Denham Country Park that is now HS2 destruction zone. More info on; Colne Valley Face book


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