Bats: advice for making planning decisions
How to assess a planning application when there are bats on or near a proposed development site.
Applies to England
This is Natural England’s ‘standing advice’ for bats. It is a material planning consideration for local planning authorities (LPAs). You should take this advice into account when making planning decisions. It forms part of a collection of standing advice for protected species.
You should read this guidance alongside Protected species and development: advice for local planning authorities.
Following this advice:
- avoids the need to consult on the negative effects of planning applications on bats in most cases
- can help you make decisions on development proposals
You may need a qualified ecologist, who will be familiar with industry guidance on survey and mitigation, to advise you on the planning application and supporting evidence. You can find one using either the:
- Chartered Institute of Ecology and Environment Management (CIEEM) directory
- Environmental Data Services directory
How bats are protected
All bat species are European protected species (EPS) protected under the Conservation of Habitats and Species Regulations 2017.
It is an offence to:
- deliberately kill, injure, disturb or capture them
- damage or destroy their breeding sites and resting places (including when bats are not present)
- possess, control or transport them (or any part, alive or dead)
- sell, exchange or offer for sale or exchange
It is also an offence under the Wildlife and Countryside Act 1981 to intentionally or recklessly:
- disturb them while they occupy a structure or place used for shelter or protection
- obstruct access to any structure or place used for shelter or protection
- possess or transport them (or any part, alive or dead)
- sell, offer or publish an advert to sell them
Several species of bats are included on the list of species of principal importance in England under section 41 of the Natural Environment and Rural Communities Act (2006). Some species are also listed as vulnerable, endangered and critically endangered on the Red List for England’s Mammals on the Mammal Society website. You must consider the conservation of all bat species as part of your planning decision. Find out more about your biodiversity duty.
The developer must comply with the legal protection of bats.
The developer may need a bat mitigation licence to carry out their development proposal.
When to ask for a survey
You should ask for a survey if a development proposal is likely to negatively affect bats or their:
- roost habitats
- foraging habitats
- commuting habitats
A survey is needed if one or more of the following applies:
- distribution and historical records suggest bats may be present – you can search the National Biodiversity Network Atlas by species and location
- the development site includes or is close to any built structures, on or underground, that provide commuting, foraging or roosting opportunities for bats
- the development site includes or is close to trees, shrubs, rock formations, quarries, natural cliff faces or water bodies that provide commuting, foraging or roosting opportunities for bats
- the development proposal includes lighting of buildings or green spaces close to habitats that bats tend to use
- the development is a wind farm proposal close to a site designated for bats or close to habitats that bats use for commuting and foraging
Absence of a record does not mean there are no bats. It could mean there is no survey data available for that location.
You must check if the ecologist holds the appropriate and up-to-date survey licence to carry out surveys for bats. CIEEM publishes:
Bats in buildings
Construction, demolition, extension, conversion, renovation or maintenance proposals could affect a bat roost in a building or barn. You should ask for a survey where buildings are likely to contain roosts, including when they are near habitat that could be important for commuting and foraging. These include buildings that:
- have minimal artificial lighting
- are close to woodland or water
- have uneven roof tiles and large roof timbers
- have cracks, crevices and small openings
- have a roof that warms in the sun with a large roof space for flying
- have hanging tiles or timber cladding on south-facing walls
Bats underground
Excavation for development could affect bats roosting underground. You should ask for a survey where roosts are likely and if any of the following apply to the underground site:
- it is close to other valuable habitats for roosting, commuting or foraging bats
- it is large enough to maintain a range of temperatures and humidity
- it has cracks, crevices and rough surfaces
Bats in trees
Tree felling for development could affect a bat roost. You should ask for a survey where roosts are likely and where the tree is any of the following:
- within ancient woodland or parkland, or is an ancient or veteran tree
- large and irregular (although individual bats are frequently found in smaller trees)
- has natural cavities, most commonly ash, beech or oak
- damaged by rot, weathering, woodpeckers or lightning – it can be dead
- has loose bark or bark with crevices in it
- covered in dense ivy
Wind farm proposals
Wind turbines can affect bats. They can fly into the tower or blades, or suffer from air pressure changes (known as barotrauma), particularly if the turbines are located on commuting routes or within foraging areas.
You should ask for a survey if a wind turbine proposal is any of the following:
- near a site designated for bat populations
- within 50 metres of features or habitats that provide commuting, foraging or roosting opportunities for bats
- within 50 metres of habitats such as wetland, wet grassland, trees, scrub, hedgerow, caves or buildings
Read the guidance for developers, planners and ecological consultants in Bats and onshore wind turbines: survey, assessment and mitigation. The guidance applies to onshore wind energy developments. It’s not intended for use with single wind turbines, micro installations under 50 kilowatts, or offshore wind farms.
What to survey for
To avoid negative impacts on bats as far as possible, surveys must:
- be carried out in the most recent, appropriate season – except if licensing policy 4 is used
- identify the bat species and size of population
- identify the type of roost and its importance, and any access points used by bats to enter the roost
- identify important flight routes and foraging areas used by bats close to proposed developments
Survey work can include:
- roost inspection
- recording site emergence or re-entry
- recording bat activity and back-tracking
- trapping, radio tagging and tracking
Assess the effect of development on bats
Developers should submit information with their planning application on how their development proposal avoids or mitigates harm to bats.
Species vulnerability
The effect of a development proposal on a bat population will need to consider the predicted level of impact based on both the:
- conservation status of the bat species affected
- importance of the development site for bats at a local and national level
For example, Bechstein’s bat is a woodland species with a localised distribution, found in southern England and south-east Wales. Development proposals in these areas could be very significant to the national population of this species. Common pipistrelle are the most common and widespread bat species. The effect of a development proposal would be less significant to the national population but could still be very significant to a local population.
Qualified ecologists can advise on reliable information on bat species, their distribution and conservation status, which you could read, including:
- chapter 10 of Natural England’s ‘A Review of the Population and Conservation Status of British Mammals’
- National Bat Monitoring Programme (NBMP) Annual Report
- Natural England Access to Evidence - Defining Favourable Conservation Status
These resources may not be accessible to assistive technology.
Avoidance, mitigation and compensation measures
Where possible, development proposals should avoid negative effects on bats. Where this is not possible, the developer will need to include adequate mitigation or, as a last resort, compensation measures in their development proposal to allow you to make a planning decision.
To avoid possible effects on bats and their roosts, developers could redesign the development proposal to
- leave bat roosts in place
- leave supporting habitat features, like vegetation around waterbodies, in place
- alter the timing of works to avoid sensitive times to bats, such as maternity and hibernation seasons
- change the methods of working to make sure bats are not harmed when works start
Where this is not possible, the development proposal should include mitigation and compensation measures. These should be proportionate to the likely effect on the bat species present. The development proposal could:
- create new roosting places within the existing building or structure
- create new roosting places in different buildings or structures
- redesign lighting to avoid roost entrances, commuting routes and foraging habitats
- create dark commuting corridors for bats between roosting and foraging areas
- increase the provision of insect rich habitats for example like sustainable urban drainage, balancing ponds and flowers that release scent at night time
For more information about avoidance, mitigation and compensation measures read:
If the destruction of a bat roost is unavoidable, you must make sure all of the following apply:
- there is no net loss of occupied and unoccupied roost sites
- roost types are replaced on a like-for-like basis
- the affected bat population can continue to function as before
For more information on mitigation plans and compensation measures, read Protected species and development: advice for local planning authorities.
Planning and licence conditions
The developer may need to apply for a bat mitigation licence if their activities are likely to affect bats. They should work with a suitably experienced and licensed ecological consultant to do one of the following:
- apply for an EPS bat mitigation licence
- use the Natural England bat mitigation class licence
- use the Bat Earned Recognition scheme (Bat ER)
You may also need to add mitigation or compensation strategies as a condition of planning permission. Before you can grant planning permission, you must do both of the following:
- work with the ecologist to make sure any mitigation or compensation conditions you impose do not conflict with the requirements of the relevant bat mitigation licence
- be confident that Natural England will issue a licence – read section 4 of Protected species and development: advice for local planning authorities
You do not need to consult Natural England on the wording or discharge (approval) of any conditions you impose on a development proposal. Natural England is unable to provide advice on this.
Enhance biodiversity
To meet your biodiversity duty, you should suggest ways for the developer to:
- create new or enhanced habitats on the development site
- achieve improvements in biodiversity through good design
- follow other relevant plans and strategies for nature
Site management and monitoring
A wildlife licence is likely to need site monitoring. This is to check that any mitigation has been implemented correctly and to see if bats return to the site. Monitoring should be proportionate to the impacts of the development on bat populations. Survey work may need to be carried out over a number of years.
Management may also be needed to make sure roosting sites remain fit for purpose and accessible to bats and that suitable habitats are retained.
This may all be written into a site management and monitoring plan, depending on the predicted impacts of the development on bat populations.
Updates to this page
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This guidance has been improved and updated. This includes the following changes. In the section on how the species are protected, the list of offences has been updated to match the relevant legislation. In ‘Planning and licence conditions’, new wording has been included about planning conditions, including the discharge of conditions and issuing of licences. New information has also been included about the Bat Earned Recognition scheme.
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First published.