BCT's response to Natural England desire to change the bat licensing system - Bat Conservation Trust

Natural England’s recently published ‘Smarter Planning and Licensing Systems: Delivering Better Results for Bats & People’, a blog about their continued focus on making changes to planning and licensing frameworks relating to bats.

BCT welcomes the recognition of the varied ecological pressures faced by our 18 resident bat species. We agree that there is a need for landscape‑scale conservation, skilled workforces, effective compensation, and partnership working. We are particularly pleased to see an indication of commitments to monitoring, evaluation and evidence‑led decision‑making.

However, several areas where changes are proposed require more details before they can be properly assessed. There is also a need for clear safeguards or they risk unintended consequences. Repeated references to more predictable, proportionate or trust‑based systems must not be defined or interpreted in ways that weaken essential protections for bat roosts. Whilst strategic approaches are valuable, there is no 'one-size-fits-all' approach that would work on a site-specific level for all of our 18 bat species with their complex life cycle needs, both in terms of conservation generally and in applying effective mitigation and protection measures on a site-specific basis.

Proposals for more flexible survey requirements, expanded trusted‑partner licensing under Bat Earned Recognition, and off‑site compensation all require further clarification. BCT would be concerned to see off-site compensation becoming the norm as opposed to being used in exceptional circumstances.