Conclusions
1. The 'mitigation
hierarchy' lies at the heart of the Government's approach to environmental
sustainability. At each successive step down the hierarchy, the
degree of environmental protection is diminished. The hierarchy
should be followed in developing HS2, but the Government has significant
work to do to demonstrate that this approach is being applied,
given the environmental damage current plans envisage to ancient
woodlands, SSSIs and local wildlife sites, and the possible significant
harm for particular species affected. (Paragraph 18)
2. The Government
has not been able to establish a full environmental baseline against
which the aim of 'no net biodiversity loss' can be assessed.
(Paragraph 22)
3. The HS2 biodiversity
offsetting metric includes some features which provide additional
protections to those envisaged in last year's Defra Offsetting
Green Paper, but unlike the Defra approach it also allows offsetting
to be assessed and scored for irreplaceable habitats such as ancient
woodlands. The HS2 metric for new habitats rightfully aims to
create habitats that would be regarded as achieving 'good' condition.
(Paragraph 35)
4. It is right that
the HS2 offsetting metric includes a discount factor for time,
but the rate proposed does not fully represent the extent of the
environmental harm from the potential delays. Some species may
become endangered by the hiatus. This is a difficult area to measure
because the discount factors usually applied in economic appraisal
to recognise the value of time are unlikely to capture the impact
of delays for the wildlife affected. (Paragraph 40)
5. There is a rationale
for providing biodiversity compensation along the HS2 route, to
facilitate the relocation of the wildlife affected and to provide
some compensatory well-being benefits to local people disrupted
by the railway and its damage to local landscapes. Nevertheless,
the requirement for biodiversity compensation to be provided directly
alongside the HS2 route may lead to missed opportunities for better
offsetting measures. (Paragraph 45)
6. The HS2 Environmental
Statement, and its associated documents and plans, provide a degree
of environmental protection by specifying minimum requirements
and standards. There is also a plan to appoint a Complaints Commissioner
for construction-related matters. But these measures alone are
not enough: HS2 Ltd can avoid adjustments if they are not considered
'reasonable' or 'practicable' (paragraph 69) and it has provided
no separate budget to meet the cost of environmental protections.
(Paragraph 51)
7. There is some debate
about whether HS2 will deliver a reduction in emissions by taking
travellers off the roads and planes. But at best, the savings
are likely to be relatively small. The carbon footprint of the
project hinges on emissions from its construction as well as from
the operation of the trains, and that raises issues about striking
a balance between minimising emissions and minimising disruption
to communities and habitats, for example by using cuttings and
tunnels which involve greater emissions in construction. Perhaps
a bigger issue is the potential effect of the decarbonisation
of the generation of the electricity used by the trains; a matter
that has been largely absent from the HS2 debate so far. (Paragraph
61)
8. In the absence of a formal [Strategic
Environment Assessment] process for HS2, it is incumbent on the
House to keep the scope of the continuing environmental assessment
process sufficiently broad, within the 'principles' of the Hybrid
Bill, to allow full consideration of the environmental impacts
of options still available within a project described in the Hybrid
Bill as "a high speed railway between London and the West
Midlands". The House will have to ensure that HS2 Ltd does
not rely on its 'practicable and reasonable' caveat to readily
dismiss essential environmental protections. (Paragraph 84)
9. It is important that if HS2 proceeds, the
House is able to demonstrate that it has at least fully followed
the purposes and processes to address environmental risks and
to prevent or mitigate them that would be expected of any other
development of this scale. (Paragraph 86)
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