Public concern over the damage to wildlife caused by lineside vegetation clearances led to a DfT-commissioned report in 2018. one year after it was published, Stewart Thorpe asks: what has changed?
If you cast your mind back to the spring of 2018, Network Rail found itself in the midst of a media storm. A story, based on a leaked internal memo, had been published by The Guardian disclosing an “£800 million scheme to remove all ‘leaf fall’ trees”. Although the article was later amended to correctly state the programme had been a proposal and not official policy, it thrust Network Rail’s practises into the spotlight.
Around the same time, a petition calling for Network Rail to stop felling trees was launched and backed by tens of thousands of signatures while countless other stories on the same topic were emerging in the media. However, within a day of The Guardian’s article being published online the situation had reached boiling point – all non-safety critical tree felling was suspended and a review of the organisation’s approach to vegetation management was commissioned.
John Varley OBE, honoured for services to agriculture and the environment in 2016, was appointed to chair the review and tasked with considering how Network Rail could maintain a better balance between cutting back flora and conserving biodiversity. Over four months during the summer, 8,000 survey responses were collected, 100 key documents reviewed and 40 interviews conducted to gather the necessary evidence to make an assessment. The review team even took the time to observe lineside vegetation teams in action.
Reading the review, it is clear John appreciated both sides of the debate. He alluded to the £300 million annual cost of ‘leaves on the line’ and that the number of vegetation-related incidents has increased from 11,500 in 2009/10 to 19,000 in 2017/18. But John also understood that Network Rail, as one of the country’s largest landowners, has the opportunity to become one of the most environmentally responsible transport organisations in the world because of the substantial biodiversity and natural capital across its estate.
Nevertheless, while he found the importance of the environment was recognised by Network Rail’s leadership team and in official policy, this was not the case across the organisation. One of the cornerstones of his findings was that approaches to vegetation management were “reactive and inconsistent,” with little thought given to their environmental impact. Safety and operational performance were instead the main focus of activity.
A lack of ringfenced funding, a narrow interpretation of compliance caused by a “significant backlog” and a culture that did not view vegetation as an asset – caused, in part, by an “overriding” concern for safety – were identified as reasons for this. This ongoing backlog also means there will be high levels of vegetation management activity for at least the next five years.
John stated that lineside vegetation should have the same importance attached to it as track and signalling, which have asset management programmes, and said: “…by not managing its vegetation as an asset, and in the context of wider policy, Network Rail risks increasing its whole-life costs and destroying valuable natural capital.”
The Varley Review’s findings weren’t all doom and gloom. Pockets of best practice were identified, including the Thameslink Programme which, in 2014, became the first Network Rail project to set and achieve a net positive target for biodiversity. John also noted there has been a shift in policy. For example, Infrastructure Projects has committed to a net positive effect on biodiversity for projects valued more than £20 million in CP6. In addition, a new vegetation management standard, introduced in April, specifies environmental requirements that weren’t previously included.
Writing to John upon the completion of the review in November 2018, rail minister Andrew Jones accepted his six recommendations for Network Rail and said: “As your report makes clear, what is now required is a change in governance, organisation and culture within Network Rail, to ensure that these activities are better aligned towards achieving national biodiversity goals.”
So, what’s changed?
John’s assignment came to an end in July this year when he produced a final report on Network Rail’s progress.
“Network Rail have, in my view, picked up the baton and I have been genuinely impressed by how far they have progressed and the momentum that has been established towards delivering the Review recommendations,” he wrote in his concluding comments.
“However, it is far from the end of the process for Network Rail and the Department for Transport. While I have been extremely encouraged by the progress so far, and in such a short period of time, much remains to be done if all the recommendations in my Review are to be implemented.”
Below, Network Rail’s progress against the Varley Review’s six key recommendations is explored in detail.
The government must set out a clear policy position for Network Rail in terms of delivering for the environment
After the review found there was no specific requirement for Network Rail to support government ambitions to “leave the environment in a better state than we found it” (Our 25 Year Plan to Improve the Environment, 2018) – in contrast to Highways England – it suggested the Department for Transport (DfT) should establish a clear strategy, and it has.
‘Enhancing Biodiversity and Wildlife on the Lineside’ was published in July with the headline challenge for Network Rail to achieve no net loss in biodiversity by 2024 and biodiversity net gain on each route by 2040. Regulator the ORR has been given a remit to monitor Network Rail’s ongoing environmental performance as well.
Appropriate governance must be put in place at organisation, route and project level
Since the Varley Review, Network Rail has begun working with the Department for Environment, Food and Rural Affairs, the DfT and Natural England to establish new metrics that its vegetation management work can be measured against by the ORR. These will be instated from 2020.
Network Rail is also working on changing its vegetation management standard by early 2020 so that vegetation is recognised as an asset. In the meanwhile, it has also clarified compliance on the current standard.
While Network Rail has also committed to putting all board members through sustainability leadership training, John was left disappointed by a failure to introduce a non-executive board champion for natural capital. Nevertheless, Network Rail has set up a committee on environmental sustainability, chaired by a non-executive director, which provides advice to the board. This was part of a move to make environmental issues a priority for all board members, not just one, according to Network Rail.
Network Rail should publish an ambitious vision for the lineside estate
John was impressed by the amount of work and support behind its ‘Lineside Estate Vision’, which is being developed and due for publication by the end of 2019. Commitments on renewable energy, biodiversity improvement and pollution are all being made in the vision. Network Rail has also promised to publish annual reports on levels of biodiversity in its routes.
Network Rail must value and manage its lineside estate as an asset
Resources have been set aside to develop a database of habitats and biodiversity across the network, to sit alongside other asset information. Network Rail is also moving ahead with a cut and maintain/replace strategy, which is more economical than a previously commonplace “cut and forget” approach.
Furthermore, although Network Rail doesn’t currently monitor the number of trees felled at a national level – instead it measures work by square metres – it is looking to change this approach, with a particular focus on how this data would be captured and assured.
The review also highlighted that gaps in levels of ecological expertise were resulting in poor environmental practices (the Anglia Route was an exception as it created a training course for vegetation management inspectors). Network Rail is now conducting a skills gap analysis and has a proposed budget for upskilling in CP6.
Network Rail must improve its communication with affected communities
Respondents to the Varley Review’s online survey were overwhelmingly negative when it came to providing feedback on Network Rail’s communications around vegetation management. Greater openness and transparency is needed, they said, and improvements are in the pipeline.
Learning from best practice, new leaflets and letter templates have been created to improve understanding of work. Research is also being undertaken to better understand what stakeholders want to know, amongst other changes.
Network Rail should lead a cultural change for valuing nature and the environment
Safety and performance are already valued highly in the organisation, but John stressed that environmental considerations must sit alongside those two.
Building on the success of its safety culture change programme, Network Rail has proposed an environment culture change campaign for year two of CP6 to overcome the often negative view of vegetation. Believing this change will only happen over time, John was disappointed at only a year’s funding being allocated.
“This is of an order of magnitude smaller than the very successful safety campaign that has preceded it,” he said.
In response, a Network Rail spokesperson said that “discussions have taken place so that lessons can be learned from the safety work that has shown many benefits across the rail industry”.
A green challenge
Prior to the Varley Review, there were competing perceptions in some circles that either safety or the environment had to be prioritised. These views will still persist but as John demonstrated, the argument isn’t as clear cut as that.
Over the last 18 months, wider societal changes have also changed the landscape. There is now a Draft Environment Bill that promises to fundamentally alter approaches to the environment, with a soon-to-be-created green governance body – the Office for Environmental Protection – to hold the government to account.
Legislation is in place to reach net-zero carbon emissions by 2050. Environment secretary Michael Gove has appointed a tree champion to stop unnecessary felling of trees and boost planting rates and public concern about the environment and climate change is seemingly at an all-time high. As John puts it: “The imperative for action has increased manyfold”.
Network Rail has already proven it can manage one of the safest railways in Europe, now the challenge has been set to make it one of the greenest too.