Written evidence from the Woodland Trust
The Woodland Trust welcomes the opportunity to respond
to this consultation. The Trust is the UK's leading woodland conservation
charity. We have three aims: to enable the creation of more native
woods and places rich in trees; to protect native woods, trees
and their wildlife for the future; to inspire everyone to enjoy
and value woods and trees. We manage over 1,000 sites and have
300,000 members and supporters.
Woodland Trust is concerned that the HSR project being proposed
by the Government fails to meet appropriate environmental standards
as the route will lead to the loss and damage of 48 ancient woodlands.
These sites represent an irreplaceable habitat that public policy
aims to protect through Planning Policy Statement 9: Biodiversity
and Geological Conservation.
of the environmental impacts of HSR have not been considered in
the Government's consultation document and there is a distinct
lack of information on the alternative routes.
the public debate over the future of the Public Forest Estate
the Government moved to address concerns about the loss of ancient
woodland by promising to ensure that the habitat would continue
to be protected in the National Planning Policy Framework (NPPF)
being drafted by the Department for Communities and Local Government.
In its current format HSR undermines this commitment.
What are the main arguments either for or against
1. Climate change represents the greatest threat
to our native woodland heritage. Consequently the Woodland Trust
supports the concept of a greener transport infrastructure. The
Trust believes that transport should be efficient, of benefit
to the majority of the public and not represent a threat to the
nation's most valuable wildlife habitats. In the case of HSR,
the proposed route casts serious doubt on the green credentials
of the overall scheme because of its impact on the environmental
heritage that green polices are designed to protect.
2. Moreover, the route for HSR detailed in the
consultation document fails to meet reasonable environmental standards
as the proposals will directly impact on at least 21 ancient woods.
Even PPS 9 recognises that ancient woodland is an irreplaceable
habitat - it is considered the UK's equivalent to the rainforesttherefore
compensatory tree planting will fail to ameliorate its loss. As
a result the Government should re-consider the planned route if
it is genuine in its desire to create a green transport network
worthy of the name.
How does HSR fit with the Government's transport
3. No comment.
4. The business case outlined in the consultation
document fails to evaluate the full impact the loss of ancient
woodland will have on the natural environment and the wider damage
the route may inflict on the countryside. At a time of heightened
awareness of the benefits arising from the natural environment
and the forthcoming publication of the first natural environment
white paper for twenty-years this is a significant omission.
5. Development located near to woodland has been
proven to cause severe damage to tree roots, increase surface
water run-off and cause soil erosion and compaction.1
At the minute HSR has not evaluated its impact on irreplaceable
habitats and therefore both the direct and indirect impacts to
woodland should be evaluated as part of the consultation process.
This evaluation should include the impacts of HSR in regard to
the following points: fragmentation, noise pollution, soil compaction
and vibration emanating from the rail tracks.
The strategic route
6. The Trust believes that the route should avoid
damaging vital environmental assets such as ancient woodland.
As the route proposed by the Department for Transport fails to
do this it is difficult for the Trust to support HSR in its current
7. It is noteworthy that the route appears to
have been selected on the grounds of cost and speed alone. The
methodology adopted by the Government assumes that all environmental
impacts can be mitigated. However, in the case of ancient woodland
this is simply untrue. By only avoiding designated sites, the
consultation also misrepresents the environmental impacts of HSR
(paragraph 4.21 of the consultation). This approach has shortcoming
as it assumes that all important habitats are designated whereas
85% of the country's ancient woodland are without any national
or international designation. This format also overlooks the cumulative
impacts on non-statutory sites and the wider biodiversity of the
8. It would also have been preferable if the
consultation document had published a variety of options with
all the environmental impacts assessed, including information
on any loss or damage to ancient woodland. By doing so respondents
would have been able to offer a fulsome commentary on each option
rather than having to estimate the multitude of possible impacts.
Economic rebalancing and equity
9. No comment.
10. Regrettably the environmental impacts of
HSR are not correctly accounted for at this present time. GIS
analysis undertaken by the Trust shows that 21 ancient woods will
be directly affected due the construction of the track and a further
27 woods could be damaged as they lie within 200 metres of the
proposed route. From this data the Trust has calculated that 135.57
hectares of ancient woodland (48 woodlands in total) will be directly
affected by HSR. Notably there has been no environmental information
published on the conservation value of ancient woodland; indeed
it is not clear whether any ecological studies have been carried
out at all. Similarly, little has been said about the mitigation
proposed other than vague statements about "tree planting"
and "green tunnels". This offers none of the vital informationsuch
as the location of the track and timescales for completing the
project needed to provide an informed assessment.
11. Losing ancient woodland contradicts the Coalition's
aspiration to be the "greenest government ever". Ancient
woodland has developed naturally with the long continuity of these
woods ensuring that they became a valuable natural habitat for
wildlife. The UK Biodiversity Action Plan highlights broadleaved
woodland because it supports almost twice as many species of conservation
concern compared against any other habitat. For instance, ancient
woodland has more than twice as many species as chalk grassland
and almost three times as many as lowland heathland. Ancient woods
support an impressive 232 species as outlined in the UK Biodiversity
Action Plan.2 As a result of development pressures,
agricultural intensification and the planting of conifers, the
UK has only 50% of the ancient woodland it had in the 1930s and
today only 2.4% of the UK's land cover comprises of this unique
12. Despite the suggestion that translocation
might be a viable option, the proposed planting of up to 2 million
trees does not diminish the reality that ancient woodland cannot
be recreated. The circumstances that allowed ancient woods to
form were unique (for example the centuries of undisturbed soils
and tree cover), and such conditions are no longer available.
13. Moreover, independent scientific research
does not support translocation. A study for WWF3 identified
that it is not possible to attribute outright success in any case
of translocation due to the inadequate recording of results and
the number of reported failures. They concluded that the genuine
costs are simply unknown. Meanwhile researchers at Wye College4
concluded that as a technique for re-locating displaced habitats,
translocation of soil from woodland is especially problematic
owing to the sensitivity of vegetation and the loss of tree canopy
cover. Ancient woodland contains many thousands of species of
plants, animals and fungi; and any success in ensuring the survival
of one or two charismatic species should not be seen as representing
translocation of a complete habitat. The stability of an ecosystem
is related to its diversity,5 and a serious reduction
of that diversity is likely to lead to the ecosystem in its previous
14. One of the strongest features of the debate
over the Public Forest Estate earlier this year was the importance
of addressing the need to afford ancient woodland special protection.
Over 160, 000 people have signed the Woodland Trust's petition
calling for the issue of ancient woodland protection to be addressed
in its own right. Given the Government's responsiveness to this
public concern as evidenced by the Ministerial assurance that
ancient woodland will be protected in the new National Planning
Policy Framework (NPPF),6 the Trust believes it is
unfortunate to have a situation where one arm of Government is
pledging protection of ancient woodland in recognition of its
value whilst anotherthe Department of Transportopenly
admits in HS2 London to West Midlands. Appraisal of Sustainability
that "in total, up to 19 ancient woods could be subject to
land take."7 In our view the route for HSR should
be altered so as to ensure that there is no further loss of ancient
woodland; a conclusion which is supported by more than 4000 members
of the public who have now expressed their concern about the loss
of this precious habitat as a result of HSR.
1 Corney, P M Smithers, R J Kirby, J S, Peterken,
G F Le Duc, M G and Marrs, RH. Impacts of nearby development
on the ecology of ancient woodland (2008) at: http://www.woodlandtrust.org.uk/SiteCollectionDocuments/pdf/policy-and-campaigns/woodwatch/impacts-development-on-ecology-ancient-woodland.pdf
2 For further information about the value of ancient
woodland please refer too the following report: Woodland Trust,
Woodland Biodiversity: Expanding our Horizons (2000) at http://www.woodlandtrust.org.uk/SiteCollectionDocuments/pdf/policy-and-campaigns/woodwatch/impacts-development-on-ecology-ancient-woodland.pdf
3 Gault C on behalf of WWF, A moving story - species
and community translation in the UK - a review of policy, principle,
planning and practice (1997).
4 Hietalahiti M K & Buckley GP. The effects
of soil translocation on an ancient woodland flora. Aspects of
Applied Biology (2000).
5 Shear McCann, K. The diversity - stability debate,
Nature, May 2000 (2000).
6 House of Lords, Lord Taylor of Holbeach, 28 Feb
2010. When concluding a committee session of the Public Bodies
Bill Lord Taylor assured the House that "protection for ancient
woodland in the existing planning guidance will be carried over
into the national policy framework."
7 Department for Transport (2011), HS2 London
to West Midlands Appraisal of Sustainability, p91.