High Speed Rail - Transport Committee Contents

Written evidence from the Woodland Trust (HSR 69)

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.


—  The 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.

—  Many 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.

—  During 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 HSR?

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 rainforest—therefore 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 policy objectives?

3.  No comment.

Business case

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 format.

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 area.

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.

Environmental impact

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 information—such 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 habitat.

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 form collapsing.

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 another—the Department of Transport—openly 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.

May 2011


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.

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Prepared 8 November 2011