Some years ago I was walking through a pine forest, feeling enlivened by the refreshing scent of the needles, when something that looked like a snake suddenly slithered across the sandy path just a metre from my toes. I stopped in astonishment. Looking more closely I realised from its grey-brown colouring and dense patterning that it must be a slow worm. Not in fact a worm nor a snake – it is rather a legless lizard. Taking no notice of me at all, it idly disappeared into the undergrowth.
This wasn’t my only encounter with uncommon wildlife on that July afternoon. Further along the sandy ride I was excited to witness several grayling butterflies warming themselves in a patch of sunlight by gently opening and closing their wings and revealing their distinctive eyespots. What a privilege!
Yet, during the consultations for the new nuclear power station known as Sizewell C, it became clear from the documents put forward by Electricité de France (EDF), owner of this pine forest, that the company considered the plantation to be of low biodiversity value. They failed to take into account the fact that the rides between the trees supported several species so rare that they are protected by law.
Some, such as the grayling butterflies, are now endangered and on the Red List, having lost 72% of their abundance between 1976 and 2019, largely due to destruction of habitat. When I learned that this woodland, known as Goose Hill and much loved by ramblers and bird-watchers, was to be entirely flattened and covered in concrete for a construction site, I was heartbroken.
Net gain for nature?
Looking into it in further detail I came across Biodiversity Net Gain (BNG), which specifies that developers must provide a minimum of 10% net gain for nature in addition to compensating for any damage caused. Using the Statutory Biodiversity Metric devised by the Department for Environment, Food and Rural Affairs (Defra), the biodiversity value of the land prior to development is calculated in units according to size, type of habitat, its current condition, ecological distinctiveness and location. The proposed replacement and enhancement habitats are then also calculated and must show the necessary improvement. Ideally these should be in the same area, but if this is not possible then they can be elsewhere. As a last resort, builders can simply buy habitat units from conservation organisations or even obtain biodiversity credits from the government. In the first instance, however, they must avoid harm – but do they?
A conversation with a Suffolk ecologist revealed his profound disapproval of use of this metric, considering the method to be ‘damaging’. He feels that it gives builders a licence to destroy the environment, including protected sites and species, so long as they offer something more elsewhere. However, some non-governmental organisations (NGOs) have accepted BNG on the basis that something for nature is better than nothing.
How honest are developers?
Many builders simply regard nature as an expensive inconvenience. It is therefore all too tempting to manipulate the BNG calculations in their favour. By keeping the biodiversity value of the present land, before development, as low as possible and exaggerating the worth of their proposed new habitats, greater uplift is achieved and the required 10% for nature more easily gained.
As part of the Development Consent Order (DCO) for Sizewell C, EDF claimed a staggering 19% net gain for nature via use of the metric but were reluctant to reveal details of their calculations. As a result, Friends of the Earth Suffolk Coastal brought in an expert from Bioscan who demonstrated that baseline figures were consistently too low. The above story concerning the pine plantation is a prime example. Here the rides have been conveniently forgotten, as are the uncommon birds such as crossbill and the spectacular hobby that used to feed and nest here.
While EDF have promised that Suffolk Sandlings will eventually replace the forest, that won’t be for at last 20 years with no guarantee of success. Meanwhile there is an extended biodiversity deficit. When Bioscan recalculated the figures only 6.7% net gain was achieved. How then did EDF arrive at 19%?
The RSPB Minsmere and Suffolk Wildlife Trust were so troubled by the company’s persistent exaggerated environmental claims that they put out a joint statement: “Sizewell C must do better to be clear about the compensation they are required to deliver by law, versus what is truly ‘additional’ for nature.”
Can habitats be created?
Compensation for a destroyed habitat sometimes means ‘creating’ a new one, but this is fraught with problems and success is never assured. Climate change, with increasing drought and/or flooding, is making this more difficult or even impossible. Newly planted trees, for example, are simply dying either for lack of water or because they are drowned. The high-speed rail developers, HS2, admitted that they had allowed tens of thousands of compensatory saplings in the Colne Valley to die during a heatwave because it was too expensive to water them.
Sadly, experience has shownthat builders often do not set aside the funds necessary for the monitoring and aftercare of the new habitat for the required 30 years.
A shocking example
It is generally accepted that some habitats can never be replaced, such as ancient woodlands that have taken hundreds of years to evolve. Rather than BNG, special rules apply. Yet even these habitats are regularly damaged or destroyed, with so-called “compensation” provided that is totally inadequate.
The mitigation offered by HS2 for the destruction of Broadwells Wood in Warwickshire, namely relocation of some of the topsoil to a newly planted site, is frankly absurd. There is no scientific evidence whatsoever, despite all the small creatures and fungi contained within the soil, that this will magically recreate an ancient woodland.
In addition, due to delays to the schedule, the work was illegally carried out in spring, killing nestlings, bats and small mammals, some supposedly protected. What else is this but a scandalous betrayal of trust?
This anti-nature government
For those of us who care deeply about the survival of our wildlife and their habitats, the government’s push to speed up development through the new Planning & Infrastructure Act, which excludes important protections for nature, is profoundly alarming. They even threaten to weaken the BNG rules.
One in six British wild species are already at risk of extinction, yet this Labour government, who recently promised to ‘save nature’, has now given us a builders’ charter. It’s not only developers who cannot be trusted, neither can this government.
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