Environmental Audit CommitteeWritten evidence submitted by Buglife

1. Executive Summary

1.1 Buglife—The Invertebrate Conservation Trust is working in partnership on St Helena to develop invertebrate conservation. Through this work we have been made aware of a number of failings during the construction of the new airport. These are having a large, adverse impact on the island’s ecology.

1.2 St Helena is ecologically significant. On Island 400 invertebrate species are found nowhere else on earth—surpassing the number of endemic species found in the UK and all other Overseas Territories put together.

1.3 Plans for an airport have been confirmed and construction is underway. The airport is located within Prosperous Bay Plain in the east of the island, the flattest area on St Helena. Prosperous Bay Plain contains a unique desert ecosystem in its Central Basin and surrounding ridges and valleys, comprising grits and dust with sheltered rock outcrops.

1.4 Prosperous Bay Plain is the main evolutionary centre on St Helena for animals adapted to arid habitats. In the context of St Helena’s biodiversity, it is an area with an extraordinary concentration of endemic invertebrates—a globally significant “biodiversity hotspot”. It is clear that if located in the mainland UK, Prosperous Bay Plain would be within the very top tier of the country’s most important wildlife sites, and would be protected by a myriad of different national and international designations.

1.5 As part of planning process for the airport an Environmental Impact Assessment was carried out. This predicted a large adverse impact on the Island’s Central Basin and Prosperous Bay Plain and developed a draft Environmental Management Plan (EMP) and draft Landscape and Ecology Mitigation Plan (LEMP).

1.6 The primary objectives of the LEMP were to provide compensatory habitats and landscape treatment to reduce and offset the permanent impacts of the airport and its associated infrastructure. This includes direct loss of habitat and the direct and indirect impacts on the landscape of the island. The EMP makes it clear that the detailed landscape and ecological mitigation requirements would continue to be developed in parallel to the design to ensure that any changes to engineering works could be assessed and then avoided, mitigated or compensated.

1.7 The detailed design of the LEMP has not run in parallel and is starting 16 months after construction was initiated. As a result Buglife considers there has been the avoidable loss of or serious damage to a number of areas of high ecological value and sensitivity. This is due to requirements of the EMP not being met and/or not having detailed information to ensure areas of high importance are avoided or protected. This has been of particular impact when construction plans change.

1.8 No detailed surveys have been carried out to identify sensitive areas and guide construction as was planned. This is of particular issue when airport engineering plans change, as they seem to do frequently. Construction is then taking place before the impact has been assessed, without even thinking about how the loss or damage may be avoided, mitigated or compensated. This is having a serious impact on the population viability of rare species such as the endemic Mole spider.

1.9 There are on the ground examples indicating that airport construction is not being adequately mitigated and compensated. Avoidable loss of and damage to extremely sensitive, and globally significant, habitat has already been caused due to environmental protection being a low priority and a lack of forward planning. There has also been very little monitoring and enforcement by St Helena Government to ensure that environmental mitigation activities outlined in the LEMP are being adequately delivered. In the context of the UK’s responsibility to protect the biodiversity on Overseas Territories this unique biodiversity hotspot should be of the highest priority.

1.10 We strongly recommend that further information is sought from Department for International Development and the St Helena Government to clarify what steps are being taken to protect and also enhance biodiversity on St Helena. Permanent damage has already been caused and if action is not taken now species will become extinct.

2. Introduction

2.1 Buglife—The Invertebrate Conservation Trust is the only charity in Europe devoted to the conservation of all invertebrates, and is passionately committed to saving the small things that run the world. The charity was established in 2002 and has a strong conservation track record, saving sites that are home to endangered species; promoting the conservation of invertebrates to the public and land managers; undertaking research and surveys essential to planning effective action; and influencing policy and legislation so as to benefit endangered species.

2.2 Buglife strives to develop international invertebrate conservation by undertaking international projects. Invertebrates are not just in trouble on mainland UK, there are invertebrate conservation issues across the globe, and notably in other parts of the EU and on the UK Overseas Territories.

2.3 Funded by the Darwin Initiative, Buglife is working in partnership with the St Helena National Trust, St Helena Government and the Centre for Ecology and Hydrology (Edinburgh) to develop invertebrate conservation on St Helena and we therefore have an in depth understanding of the value of the St Helena wildlife.

2.4 St Helena’s flora and fauna evolved in extreme isolation, resulting in more than 400 invertebrate species found nowhere else on Earth. This total surpasses the number of endemics found in the UK and all its other Overseas Territories put together. For this reason, St Helena has been called the “Galapagos of the South Atlantic”.

2.5 Plans for the new airport on St Helena have been approved, funded and construction is underway. We do not seek to stop this. However, through its work on St Helena Buglife has recently become aware of the apparent failures in the delivery of the environmental mitigation and compensation strategy for the airport and significant changes to the development which have not had their potential environmental impacts assessed. In our view, this prevents the UK Government from fulfilling its responsibility to protect biodiversity in the UK Overseas Territories.

2.6 The purpose of this evidence is to raise awareness of the negative impact that the airport construction is having on the wildlife of St Helena which could be avoided. Going forward we hope to encourage better quality of work from an environmental management perspective that is more transparent and engages with conservation organisations on St Helena that have detailed knowledge and expertise of the island’s ecology.

3. Value of Prosperous Bay Plain

3.1 The airport is located within Prosperous Bay Plain in the east of the island, the flattest area on St Helena. Prosperous Bay Plain contains a unique desert ecosystem in its Central Basin and surrounding ridges and valleys, comprising grits and dust with sheltered rock outcrops.

3.2 Prosperous Bay Plain is the main evolutionary centre on St Helena for animals adapted to arid habitats. In the context of St Helena’s biodiversity, it is an area with an extraordinary concentration of endemic invertebrates—a globally significant “biodiversity hotspot”. As invertebrates are the principal group of endemic animals on St Helena, there being no native amphibians, reptiles or mammals and just a single, endemic land bird still extant, Prosperous Bay Plain is of major importance to St Helena’s natural heritage.

3.3 The dusty, level floor of the Central Basin, a low lying depression within Prosperous Bay Plain, is a unique habitat on St Helena. It is a miniature mature desert ecosystem, similar in character to deserts in continental Africa.

3.4 A total of 35–40 animal species and six genera that have been recorded on Prosperous Bay Plain occur nowhere else in the world. As recently as 2003, 10 species new to science were discovered there, indicating that the fauna is poorly understood and there are probably other un-described species present. In addition, 51 species endemic to St Helena have been recorded from the area of Prosperous Bay Plain, though they are not restricted to it.

3.5 The invertebrates found only in the area of Prosperous Bay Plain are represented by a wide range of invertebrate groups, not just many similar species in a single group; there are centipedes, spiders, pseudoscorpions, mites, beetles, wasps, moths and flies:

The pseudoscorpion Sphallowithius excelsus is like a miniature scorpion but without the stinging tail. It lives in the dusty areas of the Central Basin.

Wolf spiders are a really special component of the Prosperous Bay Plain fauna, several species make burrows in the soft dust, eg the Prowling wolf spider Hogna nefasta is the dominant invertebrate predator, while the Lurking wolf spider occurs towards the eastern end of the Central Basin, the area most at risk from the development, and is considered to be endangered and at serious risk (only eight specimens have been found to date). It has not yet been given a scientific name and has been temporarily assigned to Trochosippa sp.

A further un-described and rare species of restricted range, recently christened the “Mole spider”, is also endemic to Prosperous Bay Plain. It is possibly the only large spider in the world to live rather like a mole, exclusively in subterranean tunnels which it digs itself.

Endemic weevils are very species rich on Prosperous Bay Plain, with Xestophasis xerophilus being found only there and associated with the native Samphire plant.

The tachinid fly Atlantomyia nitida is probably a parasite of the endemic grasshoppers but appears to be very rare.

3.6 It is clear that if located in the mainland UK, Prosperous Bay Plain would be within the very top tier of the country’s most important wildlife sites, and would be protected by a myriad of different national and international designations. Permission to develop such a site in the UK would be very unlikely to be granted.

4. Impact of Airport Construction

4.1 The airport development is predicted to take around 163 hectares of the Prosperous Bay Plain. In addition to this 8.11 hectares of the Central Basin will be lost to the airport development area.

4.2 The St Helena Airport Environmental Statement (2008) concluded that the desert habitats of Prosperous Bay Plain were of Very High Value for their ecological interest and of International Importance. A Large Adverse impact was predicted for the desert ecosystems of PBP and its Central Basin.

4.3 To mitigate and compensate the acknowledged Large Adverse environmental impact of the airport, a draft Environmental Management Plan (EMP) and draft Landscape and Ecology Mitigation Plan (LEMP) were produced. The documents were part of the St Helena Airport Environmental Statement published in 2007 and which subsequently supported the application for development permission in 2008.

4.4 Within these documents the St Helena Government (SHG) and Department for International Development (DfID) state that they will to seek the highest possible standards of environmental management during construction and operation of the [airport] works.1 It also states that the Environmental Management Plan will remain in draft form to the start of construction2 and that changes, both significant and minor, will be incorporated into the Environmental Management Plan as it develops.

4.5 The primary objectives of the LEMP were to provide compensatory habitats and landscape treatment to reduce and offset the impacts of the airport and its associated infrastructure. This includes permanent direct loss of habitat and the direct and indirect impacts on the landscape resource of the islands. The EMP makes it clear that the detailed landscape and ecological mitigation requirements would continue to be developed in parallel to the design to ensure that any changes to engineering works could be assessed and avoided, mitigated or compensated.

4.6 The draft LEMP set out the range of activities considered necessary to establish the means to provide compensatory habitat and landscape treatment. Principle activities included: pre-construction site preparation, plant production management, germplasm collection, plant production, landscape and ecology mitigation planting, alien plant control & maintenance and long term management.

4.7 The LEMP first initiated in September 2008 was scaled back significantly and then halted, understandably, following the pause and then cessation of negotiations for air access. This work was limited to a one-year programme, which collected a very small amount of seed to start building up plant stocks for compensatory habitat. No direct mitigation for the permanent or temporary loss of habitat was undertaken.

4.8 In June 2010 the Rt Honourable Andrew Mitchell MP, then International Development Secretary, confirmed the UK Government’s willingness to fund an airport for St Helena subject to conditions. In 2011 there were engineering modifications and an Environmental Statement Addendum was produced reviewing past work and addressing some of the engineering revisions.

4.9 In a written Ministerial Statement to Parliament on 3 November 2011 it was confirmed that the conditions had been met and the design, build and operate contract awarded to Basil Read (Pty) Ltd.

4.10 In March 2012 DfID initiated the search to appoint a supplier to provide ecology mitigation services to the Government of St Helena to deliver LEMP (www.government-online.net/ecology-mitigation-st-helena/).

4.11 A year later in March 2013 the Airport Project board that governs the Airport Project gave approval for the LEMP of £870,000 to be managed by the St Helena Government Air Access Office (AA). It is not clear how this sum is to be allocated, if it is enough to mitigate and compensate a major development with a large adverse impact or what will happen if further compensation work is needed once the fund has been allocated.

4.12 The St Helena Airport update issue no 28 (26 March 2013) stated that detailed design and planning for the LEMP has begun. As of May 2013 airport construction works have been underway over 16 months.

4.13 Due to the detailed design of the LEMP starting 16 months after construction was initiated Buglife considers there has been the avoidable loss of or serious damage to a number of areas of high ecological value and sensitivity. This is due to requirements of the EMP not being met and/or not having detailed information to ensure areas of high importance are avoided or protected. This has been of particular impact when construction plans change. For example:

(i)Advanced pre-construction works that formed part of the mitigation requirements of the project are not underway and this will impact on ecologically sensitive habitats and species as well as the quality of environmental management of the development. For example, ecologically sensitive areas of habitats and species, including and most importantly, the unique Central Basin area of Prosperous Bay Plain has not been adequately protected by physical barriers or signage to prevent damage or additional disturbance (by works or access) during construction. Fencing of the Central Basin was identified as a key method of limiting the damage to this area prior to the construction.

(ii)The baseline surveys carried out as part of the original EIA do not provide an accurate baseline data set to work from. It was intended that more detailed surveys would be carried out prior to construction to inform development. As a result it is not possible to accurately assess the impact of construction or to guide construction works and mitigation plans to avoid unnecessary environmental damage.

e are aware that in some areas detailed habitat and invertebrate surveys have been carried out, but the report and its findings are not in public domain despite a number of requests for the information over the last nine months. Even more alarming is that one of the areas identified as of high value was destroyed shortly after it was pointed out. This demonstrates the lack of transparency in the construction process.

Surveys appear to be either not undertaken at all or commissioned late in the construction process, which imposes limited options for avoidance, reduction, mitigation or compensation of impacts.

(iii)The endemic Mole spider has been previously recorded in the Central Basin but no surveys of the size or health of the population have been conducted that we are aware of. It is also known on one site near the Airport Contractor’s construction camp at Bradley’s and on the southern ridge of the Central Basin.3

On the southern ridge, the one population was expected to be directly impacted by the construction and one to be lost entirely to the runway. Airport engineering plans have changed and the construction footprint has now resulted in the additional loss of the majority of habitat across the southern ridge. This could impinge on the viability of the population, particularly as no attempt has been made to mitigate this loss. It may have been possible to translocate the population had further assessment of the impacts been carried out in advance. Remaining areas of habitat may be at risk of additional disturbance and damage as there are no physical protective measures in place.

The population at Bradley’s Camp is now likely to be destroyed to create a triangulation station for the airport. It is not clear why this area of habitat has been selected when there are similar habitats unoccupied by the spiders, including the area temporarily being used to house septic tanks, all around this area. Unfortunately, the story of the mole spider is likely to be indicative of how other less charismatic species, concentrated around the Airport Development Area, are being affected by the development.

(iv)The recently constructed access road from Rupert’s Bay has resulted in the creation of a spoil slip slope covering the original vegetation that is highly prone to erosion. The vegetation lost contained Samphire which was important for a number of species only recorded in that particular area. If there had been further refinement of the EMP this interest would have been identified and its loss may have been avoided.

(v)Part of the mitigation strategy was to restore areas under temporary use and create compensatory habitat for permanent habitat loss using native species. Without detailed baseline surveys it is not possible to accurately assess the quantity and types of compensatory habitat required. As the surface of the majority of the construction area has now been scraped, this task has been rendered impossible.

(vi)Some areas of compensatory habitat may need to be stocked with native species from areas to be lost to development. These would be propagated primarily through seed collection and then cultivated. The delay in the start of the LEMP means that important plant areas have already been destroyed, severely compromising this aspect of compensation.

(vii)In this arid and sensitive environment dust levels arising from the development are unavoidable but controlling them is an important and required component of the mitigation measures. We are concerned about dust levels and the need to protect ecologically sensitive habitats adjacent to the development. The impacts of dust on the habitats and species are not fully understood and need to be monitored in order to allow action if levels rise too high. Heavy coatings of dust are likely to have a serious effect, particularly on annual plants and sensitive lichen species, which form major food sources for the invertebrates of the Plain. The Environmental Statement indicates that barriers will be used as needed but none are evident at this point in time.

4.14 These examples indicate that the airport construction is not being adequately mitigated and compensated. Avoidable loss of and damage to extremely sensitive, and globally significant, habitat has already been caused due to environmental protection being a low priority and a lack of forward planning. There has also been very little monitoring and enforcement by St Helena Government to ensure that environmental mitigation activities outlined in the LEMP are being adequately delivered. In the context of the UK’s responsibility to protect the biodiversity on Overseas Territories this unique biodiversity hotspot should be of the highest priority.

5. Recommendations for Committee

5.1 As mentioned above, going forward we would like to see a more transparent way of working secured. Buglife and the on island conservation organisations are able to give specialist ecological advice on the wildlife of St Helena. As the construction is moving at such pace action needs to be taken quickly to ensure that further habitat is not destroyed or damaged needlessly.

5.2 Buglife recommends that further information is sought from DfID to establish the on Island situation and ensure that environmental protection is high on the St Helena Government agenda. This needs to be demonstrated on the ground through sensitive construction. We suggest the following information is obtained from DfID to help understand the situation:

What is the timetable for the revised LEMP and what impact on St Helena’s biodiversity will there be by not having this in place from the start of construction?

Will the revised LEMP review the level of mitigation and compensation required to offset the additional environmental impact? What will the procedure be if mitigation and compensation exceeds the budget set by DfID?

When engineering and design plans have changed is construction being realised after environmental assessment has been carried out? If so, when will the survey and impact assessment information be in the public domain? The current absence of detail is contributing to the lack of transparency around the project.

What monitoring and auditing is being carried out to ensure that mitigation measures are in place and working?

What process is used to weigh up the costs of impact on the environment (eg potential extinction of a very rare endemic species) relative to the financial savings gained by a particular change to the construction design?

To what extent has DfID devolved environmental management and oversight of the airport construction project to the St Helena Government? We have concerns that environmental protection is being and will continue to be compromised as St Helena Government is also required to deliver the airport to time and to budget. This is a clear conflict of interest.

13 May 2013