High Speed Rail: Investing in Britain s Future. Consultation on the route from the West Midlands to Manchester, Leeds and beyond

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1 High Speed Rail: Investing in Britain s Future. Consultation on the route from the West Midlands to Manchester, Leeds and beyond Response from The Wildlife Trusts January 2014 Contact: Paul Wilkinson, Head of Living The Wildlife Trusts The Kiln, Waterside, Mather Road, Newark, NG24 1WT Registered Charity No

2 Freepost RTEL-YAZX-HAZT Phase Two Route Consultation PO Box 1152 HARROW HA1 9LH Sent by to: 31 January 2014 Response by The Wildlife Trusts to High Speed Rail: Investing in Britain s Future. Consultation on the route from the West Midlands to Manchester, Leeds and beyond. Background, context and contents 1. There are 47 Wildlife Trusts across the whole of the UK, the Isle of Man and Alderney. We are working for an environment rich in wildlife for everyone. With more than 800,000 members, we are the largest UK voluntary organisation dedicated to conserving the full range of the UK s habitats and species whether they be in the countryside, in cities or at sea. More than 150,000 of our members belong to our junior branch, Wildlife Watch. We manage 2,300 nature reserves covering more than 90,000 hectares; we stand up for wildlife; we inspire people about the natural world and we foster sustainable living. The Wildlife Trusts have a collective vision to create A Living and secure Living Seas for the whole UK. 2. The Wildlife Trusts welcome the opportunity to comment on the public consultation on the preferred route for Phase 2 of the proposed new high speed rail (HSR) network (High Speed Two HS2) from the West Midlands to Manchester and Leeds and beyond as set out in the documents released by DfT/HS2 Ltd on 17 July 2013 (and various corrections released on 13 September 2013). 3. We would ask you please to take account of the following key points when considering this response to the Consultation on the HS2 Phase 2 route from the West Midlands to Manchester and Leeds: The Wildlife Trusts have an agreed position on High Speed Rail 2 1. We recognise the need for an efficient and sustainable transport system and we support moves to a low carbon economy. We therefore take the view that HSR has the potential to be part of the nation s sustainable transport and communications system. In line with this position, The Wildlife Trusts have worked with major voluntary and community organisations (VCOs) to develop The Right Lines Charter 2 which sets out clear sustainability principles for HSR which we fully support and which are not met by any of the proposals for Phase 1 or Phase 2 of HS2. We have elected not to use the on-line format to respond to the consultation. The structure and specific questions do not adequately accommodate our need to express a range of views on the particular issues which concern us. 1 The Wildlife Trusts Position Statement on High Speed Rail 2 (HS2), October This document is available at 2 The Right Lines Charter sets out key principles for doing High Speed Rail well in the UK. TWT was one of the original ten signatory VCOs which prepared and launched this Charter in April The current proposals by DfT/HS2 Ltd for a high speed rail strategy and specific route developments from London to the West Midlands (Phase One) and from the West Midlands north to Manchester and Leeds (and beyond) still fail to meet these principles. The Charter is available at

3 This response from The Wildlife Trusts must be read in conjunction with the responses submitted to the High Speed Rail Consultation by the individual Wildlife Trusts whose areas are directly affected by the preferred route for HS2 Phase 2. The Wildlife Trusts fully support the submissions from: o Cheshire Wildlife Trust o Derbyshire Wildlife Trust o Nottinghamshire Wildlife Trust o Staffordshire Wildlife Trust o The Wildlife Trust for Lancashire, Manchester & North Merseyside o The Wildlife Trust for Sheffield and Rotherham o Warwickshire Wildlife Trust o Yorkshire Wildlife Trust. Our response is set out as follows: o This introductory section. o A summary of key issues and recommendations. o A table listing significant areas for the enhancement of nature which we predict will be detrimentally affected by the proposed scheme (Annex 1) We would be pleased to provide further information to support statements made in this response if required. Key issues and recommendations 4 The Wildlife Trusts believe that the evidence we have accumulated, including evidence gathered by the individual Wildlife Trusts directly affected by the HS2 Phase 2 preferred route proposal, demonstrates that the approach adopted by DfT/HS2 Ltd: will result in an unacceptable level of loss of and damage to existing wildlife assets by constructing the preferred route ; Key issues are o the failure to undertake a route-wide Strategic Environmental Assessment, including proper consideration of all reasonable alternatives (both route options and alternatives to a new high speed track) has removed the opportunity for public consultation to test the options to determine their impacts on the environment; o the failure of the Appraisal of Sustainability (AoS) of HS2 Phase 2 to examine all the available information on the wildlife assets along the preferred route (for example, the AoS excludes consideration of Local Wildlife Sites) such that predicted impacts are not properly identified and consequently any assessment of the overall effects of the proposed development on wildlife is deficient; compromises existing initiatives and future options to safeguard our natural heritage The impacts of the barrier which HS2 Phase 2 will create to wildlife have not been fully assessed. This relates both to the risks to species and to the range of landscape scale actions being developed and implemented by Wildlife Trusts and other organisations in order to restore degraded ecosystems, to support sustainable habitats and viable wildlife populations. scale initiatives such as The Wildlife Trusts Living schemes contribute to the restoration of ecological networks which are promoted in the Government s 2011 White Paper on the natural environment The Natural Choice: Securing the Value of Nature. Reversing the fragmentation of habitats is of fundamental importance to creating viable ecological networks; HS2 Phase 2 will result in further fragmentation of habitats.

4 5 We therefore recommend that: a) there remains an urgent need for Government to prepare a comprehensive strategic review of the country s transport and communications needs for the 21st century, including all forms of transport (covering air, land, inland waterways and marine; rail and road as well as walking and cycling) and embracing the full range of functions (for business, personal travel to work and for leisure, freight movement and distribution of goods and services through broadband, etc.). The core objectives in this review should be planning to optimise the move to low carbon life-styles; integration of transport and communications objectives with objectives to safeguard and to enhance our cultural and natural heritage and the well-being of our society. b) there must be adequate provision in terms of process and financial resources to ensure that any impacts on wildlife are properly and fully mitigated or compensated. The process should include a more robust and comprehensive assessment of the impacts on wildlife, including the assets that exist outside protected and designated areas and the implications for restoring ecological networks. In determining appropriate actions and measures for wildlife, the process should incorporate the standard planning hierarchy approach of first adjusting plans in order to avoid impacts on wildlife; where this is not feasible, implementing measures which will mitigate impacts. Finally, as a last resort, any residual damage to wildlife must be fully compensated. The process to put in place these measures should be open, inclusive and transparent. The Wildlife Trusts would expect to be engaged in this process (in contrast to the lack of consultation during the development of HS2 Phase 1) and in planning appropriate measures. It will be vitally important that adequate financial resources to implement and to monitor the effectiveness of relevant actions are made available and guaranteed. c) we believe it is vital that sufficient time must be allowed to prepare the Environmental Statement (ES) for HS2 Phase 2. Our experience of the Phase 1 ES is that the document was prepared under such a constrained timetable that it inevitably has major gaps in the ecological baseline and the proposals to mitigate and compensate for negative impacts on the natural environment, including on wildlife assets, are not sufficiently well developed to ensure a no net loss to biodiversity objective can be met. Ideally, The Wildlife Trusts would like the government s ambition for this major exemplary infrastructure project to be one of net gain for the natural environment. 6 We are convinced that by taking the revised approach we advocate above, the Government should be on the right track to achieve the objective expressed in The Natural Choice: Securing the Value of Nature to be the first generation to leave the natural environment of England in a better state than it inherited. 3 Integrating transport and communications infrastructure developments with wider needs for a healthy natural environment is vitally important for a sustainable future. 3 CM 8082 The Natural Choice: Securing the Value of Nature (2011) TSO, London; para 2.

5 Annex 1 Important areas where actions are under way to enhance and restore wildlife assets and which are at risk of detrimental impacts by HS2 Phase 2 Preferred Route. Scheme name X Y National grid ref Lead Partner Trust area(s) Local Authority(ies) Grid ref of centre-point Great Manchester Wetlands Lancashire WT Lancashire WT, Cheshire WT Bollin Valley Cheshire WT, Lancashire WT Wigan, Warrington, Trafford, Salford, Bolton, (St Helens, West Lancashire) Cheshire East, Warrington, Trafford, Manchester Saltscape Cheshire West and Chester LA Cheshire WT Cheshire West and Chester Dane Valley Cheshire WT Cheshire WT Cheshire West and Chester, Cheshire East Meres and Mosses NIA Shropshire WT Cheshire WT, Shropshire WT Tame Valley Anker Valley and Cambrian Ridge SP2096 SP2999 Shropshire, Wrexham, Cheshire West and Chester, Cheshire East, Newcastle-under-Lyme Warwickshire WT Warwickshire WT North Warwickshire Borough Council, Warwickshire County Council, Birmingham City Council, Tamworth Borough Council, Staffordshire County Council Local landowner Warwickshire WT North Warwickshire, Staffordshire Rivers Staffordshire WT Staffordshire WT All Las in Staffs are covered by part of this LLP. Tamworth Borough Council, Lichfield District Council, Newcastle-under-lyme District Council, Stafford Borough Council only are impacted by HS2. Staffordshire Mosses and Meres Arden Soar and Wreake Valley Staffordshire WT Staffordshire WT Newcastle-under-lyme District Council, Stafford Borough Council, Stoke City Council, and South Staffordshire Council, although only first 2 affected by HS2 SP2173 SK4928 approx Warwickshire WT Warwickshire WT Project in development LRWT Leicestershire WT North West Leicestershire District Council

6 Erewash Valley Notts/Derbyshire WT Nottinghamshire WT Broxtowe/Erewash Notts Magnesian Limestone Nottinghamshire WT Nottinghamshire WT Ashfield Ridge Wildlife in the City/ Nottingham City Nottinghamshire WT, Nottingham City Council Nottinghamshire WT Nottingham City Erewash Valley Living SK Derbyshire WT Derbyshire WT Erewash Borough Council, Broxtowe Council Trent Valley Living SK Derbyshire WT Derbyshire WT Erewash Borough Council, South Derbyshire Rother and Does Lea SK Derbyshire WT Derbyshire WT Bolsover District Council, North East Derbyshire District Council Living Don: Rotherham Rivers SK Living Don Partnership, Sheffield WT, Rotherham MBC, EA, Yorkshire WT Living Don: Blackburn Valley SK Living Don Partnership, Sheffield WT, Rotherham MBC, EA, Yorkshire WT Elmet Magnesian Limestone Living Lower Aire Valley Living Sheffield WT, Yorkshire WT (area of joint working) Sheffield WT, Yorkshire WT (area of joint working) Rotherham MB Yorkshire WT Yorkshire WT Selby, Leeds Sheffield CC, Rotherham MBC Yorkshire WT Yorkshire WT Leeds (also Wakefield, Selby, East Riding of Yorkshire) Lower Calder Valley Living Yorkshire WT Yorkshire WT Wakefield (also Leeds, Calderdale and Kirklees) SW Wakefield Living Yorkshire WT Yorkshire WT Wakefield (also small parts of Barnsley and Kirklees) Dearne Valley Living NE, EA and RSPB Yorkshire WT Barnsley (also Rotherham and Doncaster) Dearne Valley NIA RSPB (Dearne Valley Green Heart Partnership) Yorkshire WT Barnsley (also Rotherham, Doncaster and Wakefield)