A variety of UK bat species make their home in Surrey, so any planning application that may impact them will probably require a bat survey. If you are planning a development and bats are found on your site, you will need to follow guidance and carry out bat mitigation and compensation measures to enable your scheme to go ahead.
Surrey and development
While Surrey is a very green county with areas of Green Belt land, there is a high demand for housing, and house building is encouraged: it is one of the most densely populated shire counties in England with a population of 1.2m. Surrey is also the most wooded county in Great Britain: 22% of its area is woodland, compared to the national average of 12%, and it has designated conservation areas and semi-natural ancient woodland providing suitable bat habitat. The government has calculated that over 6,300 new homes are needed, and Surrey County Council aims to protect and create new habitats to support biodiversity alongside development.
Surrey’s 2050 Place Ambition document aims to promote `good growth’. It wants to see `proportionate and sustainable growth’ to sustain a strong economy, and improve the environment and people’s health in the cities. Local authorities have a positive attitude to development and are granting planning consents, which is evidenced by the number of housing and mixed-use development schemes and regeneration work. Alongside this, the county council plans to be carbon neutral by 2050. However, the Environmental Bill means that planning applications will be put under increasing scrutiny in terms of their impact on the natural world.
If you need to submit a bat survey, it will need to contain sound evidence as to why your proposed development should be allowed, including details of how the bats impacted will be managed.
Species of bat found in Surrey
The most common bats include barbastelle bats (Barbastella barbastellus), Bechstein’s bats (Myotis bechsteinii), brown long-eared bats (Plecotus auritus), greater horseshoe bats (Rhinolophus ferrumequinum), lesser horseshoe bats (Rhinolophus hipposideros) and various types of pipistrelle bats.
Trees, waterways, rivers and streams all have the potential to support roosting bats due to high insect numbers providing a food source; bats are also found in urban centres, golf courses and green spaces. Roof tiles and loft voids also offer the potential to support roosting bats. While bats nationwide are protected by the Bat Conservation Trust (BCT) which advises local councils in relation to planning, ecologists in The Surrey Bat Group will advise members of the public about bats and development locally. The Surrey Wildlife Trust can also offer advice.
Bats and the law
Developers’ obligations
Bats are a highly protected species and disturbing them without permission is a criminal offence. Relevant legislation protecting bats is laid out in the Wildlife and Countryside Act 1981, and all 17 European bat species breeding in the UK are protected under Schedule 2 of the Conservation of Habitats and Species Regulations 2017, making it an offence to intentionally kill or deliberately capture bats, destroy a bat roost, obstruct access or harm bats in any way.
Bats are also protected under the Countryside and Rights of Way Act 2000, and guidance is also available from organisations including the Bat Conservation Trust, the Chartered Institute of Ecology and Environmental Management (CIEEM) and Natural England.
Specific guidance
As a result, protection afforded to roosting bats, commuting bats and hibernating bats is a material consideration in planning. Detailed guidance must be followed involving bat surveys to avoid disturbing bats. If bats are discovered either before or during development, you need a plan to manage them correctly and avoid committing a criminal offence.
Bat surveys must be carried out by qualified and licenced bat ecologists who will ensure that the necessary bat mitigation is in place to protect native bats and increase the likelihood of a successful application for planning consent.
Guidelines for bat surveys
If there is a reasonable likelihood that bats are present on a development site, or they are discovered following a Preliminary Ecological Appraisal/Extended Phase 1 Habitat Survey, a bat survey will be needed.
Preliminary Roost Assessment (PRA): also known as Phase 1 Bat Surveys or Scoping Bat Surveys
This is an initial assessment involving a surveyor conducting a desk study and a physical inspection of trees and buildings to look for evidence of bat activity. The site will be examined for potential roosting sites, dead bat carcasses, bat droppings, urine stains and feeding remains that would indicate the presence of bats. The Preliminary Roost Assessment will clarify the findings and the bat surveyor will provide detailed guidance about the next steps. If there are bats present on the site, your local planning authority is likely to require further surveys along with appropriate mitigation measures to allow your scheme to go ahead. If the surveyor does not find bats, development works should be able to proceed.
Bat Emergence and Re-Entry Survey (BERS): also known as Bat Activity Surveys
While the Preliminary Roost Assessment can be carried out at any time of the year, BERS have a strict survey season between May and September. This second stage survey involves dusk emergence and dawn re-entry surveys carried out in good weather conditions: surveys can be disrupted by high winds and heavy rain. Bat Emergence Surveys involve licensed ecologists conducting two or three internal and external inspections at the site to monitor potential entry and exit points for bats. Surveyors use specialist equipment including bat detectors to assess the bat species from echolocation calls and can calculate bat populations.
If there is evidence of bats, the survey report will contain appropriate mitigation measures for dealing with the bats correctly in your planning application. Such measures might include installing bat boxes or relocating bats. If bats are not found on your site, evidence in the survey report will satisfy the planning authority and allow your scheme to progress.
While the PRA and BERS surveys will enable you to secure planning permission, a European Protected Species Licence (EPSL) may be needed to move, disturb bats, or destroy roosts. If your development proposal will affect bats and you need a bat mitigation class licence as part of your application, these are issued by the statutory nature conservation organisations Natural England and Natural Resources Wales.
Find an experienced ecological consultancy
It’s important to find a firm with fully licensed ecologists who are experienced in conducting bat surveys according to best practice. A professional consultant will be able to carry out a bat survey and advise you on any further surveys you may need to take to secure planning permission. Bear in mind that a Preliminary Roost Assessment can be carried out at any time of year but there are seasonal restrictions for Bat Emergence and Re-entry Surveys which could disrupt your time frame, so planning ahead is advisable.
