Bats and the Planning System
Here at Wildwood Ecology, we are very lucky to have a wide variety of clients, ranging from large firms to individual homeowners, allowing us to work on a range of projects and to provide ecological assistance to many different kinds of people. Although often our clients are happy to work with us, there is a distinct elephant in the room when we meet many of our clients for the first time: most of those who seek the services of an ecological consultant do so in order to meet the necessary requirements for planning approval or list building assessment.
First steps in planning
Often, when seeking planning permission or listed building consent (LBC) for a development on an existing building, you will be asked to seek a bat survey of the building prior to the consent being given. This leads many to believe that they only need to get a single survey done and then they’re good to go. Sadly, this is rarely the case.
When we first turn up to a job, the first survey we will undertake is known as a Preliminary Roost Assessment (PRA), this is essentially a scoping survey to determine the condition of the building, whether any bats are present and the building’s suitability for use by bats. The building’s suitability for bats is often what catches people out, as a building can have no bats in it and no evidence of use by bats (such as bat droppings), however it can still have suitability for use by bats.
Suitability for bats
The suitability of the building for use by bats is determined by looking at the possibility that bats can access the building (e.g. gaps in the roof, under the eaves, slipped tiles) as well as any suitable roosting features within the building (e.g. timber beams). Even a small number of these features can mean that the building has at least low suitability for use by bats.
As you can imagine, sometimes use by bats can be a bit of a self-fulfilling prophecy, if a building is old and needs redevelopment, it’s going to be much more likely to be full of holes than a new build. It is rare that buildings are considered negligible (no evidence of bats or features suitable for supporting bats) as bats find their way into the smallest of gaps, for example the crack beneath the guttering on this house.
Surveys to satisfy planning
What this means is that, in order to confirm use by bats, dusk or dawn bat surveys will be needed. These surveys can only be conducted in the active season for bats (May – August) and can require multiple surveys in order to confirm absence (up to 3 surveys for buildings with high suitability).
What this means for the client is that, what they initially thought was a single daytime inspection for bats has turned into multiple night time surveys by multiple surveyors! In my experience, when I come to deliver this news it is rarely greeted with cheers, however these surveys are required in order to satisfy planning.
It is importance to note that LPAs should not condition these surveys, as the outcome of the bat surveys could result in changes to the final development plans being necessary (for example, if a bat loft is needed that wasn’t included on previous plans). Therefore, these surveys have to be completed before planning will be granted. As the surveys are seasonal, depending on the time of year that you contact an ecological consultancy for a bat survey, unfortunately you may need to wait months before you can complete the surveys you need for planning.
This highlights the importance of contacting an ecological consultant at an early stage if you think bats may be present within your development site, as waiting until a bat survey is requested could mean having to wait several months before the surveys can be completed.
Once all of the bat surveys are complete and planning has been approved, there is more to do, as if bats are present within the building, a bat licence from Natural England is likely to be required in order to undertake the works legally.
This licence requires planning permission (or similar) to be in place for the works, so it can only be applied for once planning has been achieved. The licence will require an ecological consultant to produce an application form, method statement, works schedule and licence figures to be submitted to Natural England.
Depending on what bats are present, it may be necessary to commit to putting up bat boxes, using bat access tiles in the roof, set aside a loft space for bats to use, or even create a purpose-built new bat loft in some cases.
Once the licence is complete, supervision of the works by an ecological consultant is likely to be necessary to ensure that bats aren’t killed or injured.
How to make this process as easy as possible?
- Consider ecology as early on in the development process as you can. Ecological surveys can require long waiting periods if you are forced to wait for the correct season to conduct surveys, so getting these surveys done ahead of time, can save you waiting later on. It is important to note that ecological surveys do have an expiry date, typically only being valid for a maximum of 18 months.
- Understand that planning is the only tool that local government has in order to ensure that legislation protecting bats is being followed. This is one of the reasons why planning is often not granted until after protected species surveys are complete. Enforcing legislation and checking that it’s being followed is expensive and time consuming, so the LPA will want to make sure that these protected species requirements are complete prior to giving approval.
- Accommodate protected species requirements within your expected costs and timings. As the LPA will first only request an initial PRA survey, many clients expect that costs will be limited. However, as shown above the process can end up being protracted and may require multiple surveys and reports in some cases.
A final word – plan ahead!
At the start of the process, it can be difficult to determine the level of survey effort required at a particular site. Often the LPA will only request a ‘bat survey’ when responding to planning requests and will not elaborate further.
However, that single bat survey can often lead to a much to a more in-depth process of surveys, reporting and licensing, with seasonal timing constraints and potential changes to the development design, in order to ensure a successful planning application. There may even be lighting considerations that require you to take into account how light spill across your development will impact upon roosting bats after the development is complete, along with other planning conditions.
This can all become overwhelming and the best way to mitigate for this is to involve ecologists at an early stage of your development design, plan ahead so that you can plan around any potential issues before they arise.
Peter Hacker, Senior Ecologist