The area threatened by the offline routes for the A27 Arundel Bypass is of extraordinary and exceptional ecological and landscape value, say Natural England in their 24 October 2019 response to Highways England's Further Consultation. It’s a long and detailed report, as befits the scale of the issue. For a flavour of it, check out these significant quotes:
From p. 1: The location of this scheme which is both directly within, and within the setting of, the South Downs National Park is of national importance for wildlife and landscape. It contains a suite of priority and irreplaceable habitats which support an outstanding assemblage of species including rare and notable species. The area has been identified as of national/international importance for bats which indicates the quality and permeability of this exceptional landscape. The loss of and deterioration of these habitats presented by the options is of considerable concern to Natural England. We therefore welcome Highways England’s decision to reconsider less damaging online options in this new public consultation.
Natural England considers that online routes offer the greatest opportunity for addressing the environmental impacts and to reduce the currently forecasted impacts of this complex scheme. The reduced costs of online options present an opportunity for an exemplar approach, befitting this special landscape and its cultural heritage.
… the impacts on wildlife and landscape are considerably greater with offline schemes. This is because offline schemes include both habitat loss and the permanent severance of remaining habitats affecting the resilience and functionality of this extraordinary ecosystem, and diminishing its ability to adapt to the effects of climate change.
…We have advised that in order to ensure a robust assessment of the impacts of severance the critical factor is to assess each option in an integrated way at a landscape scale. We have provided Highways England with a joint letter from Natural England, the South Downs National Park, Environment Agency and the Forestry commission (appended to this letter) presenting our united concerns, of which severance is an overarching theme.
It is with concern therefore that we advise that the impact of severance has not yet been adequately assessed in the brochure or accompanying supporting evidence. Without a clear and balanced assessment which highlights this major impact, a judgement of the true scale of environmental impact presented by offline options cannot be made.
…This letter highlights our considerable concerns regarding landscape and the impacts that the options have for biodiversity via loss and severance of habitats. We will reiterate our advice that this area is extraordinary, necessitating a bespoke approach to assessment across the suite of priority and irreplaceable habitats and the associated array of species that this nationally important environment contains.
Natural England’s consultation response notes that the information presented in the Highways England Environmental Assessment Report (EAR) is misleading and incomplete.
Page 7: The EAR Includes an assessment of individual habitats and their importance (which we wish to provide comments on); but an integrated appraisal of the functionality of the area and how each option would affect it has not been included. The assessment of severance appears only as a description and in tabulated form and not for all habitats or species. This present’s unclear and misleading information regarding this issue which we have advised is of critical importance for this scheme. Without this information, presented in an integrated cumulative way at the appropriate landscape level, we advise that the true impact of the Arundel Bypass cannot be assessed and therefore cannot be relied upon to provide a reliable assessment of alternatives for the Preferred Option. To highlight this when judging environmental impact the online options appear to be more damaging than offline schemes. We advise that this is because the integrated approach addressing functionality has not been included.
And they conclude on page 12:
Natural England advises that at present the supporting information pertaining to biodiversity and Landscape is unclear and incomplete and does not provide a full and accurate appraisal of the considerable environmental impacts of the Arundel Bypass. Again we welcome that less damaging online options are included for consultation but we are concerned that the assessment does reflect their less damaging impact and potential for mitigation, in particular with regard to severance. We advise that a clear cumulative and integrated assessment is currently lacking and therefore a robust appraisal of the options is not possible from the information provided.
Our overarching advice remains that in order for Highways England to deliver a viable road scheme that fulfils the policy and legal protection afforded to Landscape and Biodiversity and the requirements of the mitigation hierarchy, you must demonstrably minimise impacts. In order to do this a landscape-scale integrated assessment is required to accurately assess impacts and provide the level of confidence and quality that will be required regarding mitigation of impact in this highly complex, nationally important environment.