Supplementary Document - Preliminary Bat Roost Assessment. (SP-1)

Purpose of this Document

This supplementary document aims to provide detailed survey methodologies deployed by ROAVR, relevant legislation and bibliography used in creating the main Preliminary Roost Assessment (PRA) report. The goal is to ensure the main report remains clear and free of confusing terminology.

Scope of the Report

The PRA report assesses the roost potential of trees, buildings, or structures at the site, evaluates surrounding habitats, and their suitability for supporting bats, whether for roosting, foraging, or commuting. It also identifies potential impacts on bats due to proposed developments and outlines the need for further surveys and mitigation measures to comply with wildlife legislation and secure planning or statutory consent.

Survey Methodology

To compile the report, the following steps were taken:

Desk Study

An ecologist conducted a desk study, reviewing statutory designated sites that support bats, notable habitats, and granted European Protected Species Licences (EPSL) listed on the Magic.gov.uk database. This included an assessment of the surrounding landscape using Google Earth and OS Maps. Local ecological records (LERC) within a suitable radius of the site may also be obtained from the local records centre, especially if bat roosts are confirmed during the PRA or subsequent surveys. The data from this study is confidential and summarised in the report’s conclusions and recommendations.

Field Survey

A field survey was conducted to record baseline information on the site’s trees, buildings, or structures, including their suitability to support bat roosting, foraging, or commuting. Where appropriate (and particularly if a topographical survey is not present), the What3Words location of trees with PRFs will be highlighted with a suitable hyper link.

Preliminary Roost Assessment

The PRA methodology follows best practice guidelines as outlined in Collins, J. (2023), "Bat Surveys for Professional Ecologists —Good Practice Guidelines," 4th edition. Trees, buildings, and structures are mapped and classified based on their roosting potential. This includes mapping roosting features and any evidence found, with surveyor positions noted if follow-up surveys are needed. While evidence is sought, some bat species may not leave direct evidence due to their biology and roosting behaviours. Where no direct evidence is found, the assessment considers desk study findings, habitat conditions, and landscape context. The site’s suitability for supporting roosting bats is then ranked on a scale from none to high, with recommendations for follow-up surveys if necessary.

Impact Assessment and Recommendations

Potential impacts on any identified roosts or roost features from the proposed development are assessed. Recommendations for further surveys and mitigation are provided based on these assessments, referencing tables 7.1 and 7.2 of the 2023 bat guidelines. Opportunities for site enhancement for bats are also outlined if no further surveys are needed.

Survey Plan and Limitations

A survey plan and location map are included in the report. It’s important to note that while every effort is made to describe the roost potential or find evidence of roosting bats, this report offers only a preliminary assessment of bat presence based on site conditions and known species distribution. Specific survey limitations (e.g., site access, weather conditions, etc.) are discussed in the report’s conclusions and recommendations.

References

The report references several key documents and guidelines, including Collins, J. (2023) and the Bat Tree Habitat Key (2018), among others. Relevant legislation, such as The Conservation of Habitats and Species Regulations 2017 and The Wildlife and Countryside Act 1981, is also cited to ensure compliance.

Guidelines & Proportionality

This report adheres to guidelines such as Collins, J. (2023) and British Standard 42020 (2013). Drone use, if applicable, is conducted under appropriate operational authorization. The ecological surveys and assessments are proportionate to the predicted risk to bats and the scale of the proposed development, as recommended by government planning guidance.

References

• Bat Tree Habitat Key. (2018). Bat Roosts in Trees: A Guide to Identification and Assessment for Tree-Care and Ecology Professionals. Pelagic Publishing Ltd.Chartered Institute of Ecology and Environmental Management (2020). Guidelines for Accessing, Using and Sharing Biodiversity Data in the UK. 2nd Edition. Chartered Institute of Ecology and Environmental Management, Winchester.
• Chartered Institute of Ecology and Environmental Management (2017). Guidelines on Ecological Report Writing. Chartered Institute of Ecology and Environmental Management, Winchester.
• Collins, J. (2023). Bat Surveys for Professional Ecologists —Good Practice Guidelines, 4th edition, Bat Conservation Trust, London.
• Garland, L. & Markham, S. (2008) Is Important Bat Foraging and Commuting Habitat Legally Protected? http://biodiversitybydesign.co.uk/cmsAdmin/uploads/protection-for-bat-habitat-sep-2007.pdf
• Institution of Lighting Professionals (2023). Guidance Note GN08/23 Bats and Artificial Lighting at Night. Bats and the Built Environment Series Publication.
• JNCC (2004). Bat Workers Manual, 3rd Edition. http://jncc.detra.gov.uk/page-2861
• Magic Database. http://www.magic.gov.uk/MagicMap.aspx
• Reason, P.F. and Wray, S. (2023). UK Bat Mitigation Guidelines: a guide to impact assessment, mitigation and compensation for developments affecting bats. Chartered Institute of Ecology and Environmental Management, Ampfield
• Natural England Designated Sites View. https://designatedsites.naturalengland.org.uk/SiteSearch.aspx
• National Planning Policy Framework (2023). https://www.gov.uk/government/publications/national-planning-policy-framework
• Wray, S., Wells, D., Long, E., Mitchell-Jones, T (2010) Valuing Bats in Ecological Impact Assessment. IEEM In-Practice. Number 70 (December 2010). 

National and European Legislation Afforded to Species

The Conservation of Habitats and Species Regulations 2017 (as amended)

The Conservation of Habitats and Species Regulations 2017 (as amended) aims to promote the maintenance of biodiversity by requiring the Secretary of State to take measures to maintain or restore wild species listed within the Regulations at a favourable conservation status.

The Regulations make it an offence (subject to exceptions) to deliberately capture, kill, disturb, or trade-in the animals listed in Schedule 2.

However, these actions can be made lawful through the granting of licences by the appropriate authorities. Licences may be granted for a number of purposes (such as science and education, conservation, and preserving public health and safety), but only after the appropriate authority is satisfied that there are no satisfactory alternatives and that such actions will have no detrimental effect on wild population of the species concerned.

The Wildlife and Countryside Act (WCA) 1981 (as amended)

The Wildlife and Countryside Act (WCA) 1981 (as amended) implements the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention 1979, implemented 1982) and implements the species protection requirements of EC Birds Directive 2009/147 /EC on the conservation of wild birds in Great Britain (the birds Directive). The WCA 1981 has been subject to a number of amendments, the most important of which are through the Countryside and Rights of Way (CRoW) Act (2000).

Other legislative Acts affording protection to wildlife and their habitats include:

Natural Environment & Rural Communities (NERC) Act 2006

Wild Mammals (Protection) Act 1996

Bats

All species are fully protected by Habitats Regulations 2010 as they are listed on Schedule 2. Regulation 41 prohibits:

• Deliberate killing, injuring or capturing of Schedule 2 species (e.g. All bats)
• Harass a bat or a group of bats (Scotland)

Deliberate disturbance of bat species in such a way as:

• To impair their ability to survive, breed, or reproduce, or to rear or nurture young;
• To impair their ability to hibernate or migrate
• To affect significantly the local distribution or abundance of the species
• Damage or destruction of a breeding site or resting place – even if bats are not occupying it at the time.

Bats are afforded the following additional protection through the WCA as they are included on Schedule 5:

• Intentional or reckless disturbance (at any level)
• Intentional or reckless obstruction of access to any place of shelter or protection
• Possess or advertise/see/exchange a bat of a species found in the wild in the EU (dead or alive) or any part of a bat

Effects on development works:

A European Protected Species Licence (EPSL) issued by the relevant countryside agency (i.e. Natural England, Natural Resources Wales, Scottish Natural Heritage) will be required for works likely to affect a bat roost or an operation which are likely to result in an illegal level of disturbance to the species will require an EPSM licence. The licence is to allow derogation from the legislation through the application of appropriate mitigation measures and monitoring.

NATIONAL PLANNING POLICY

National Planning Policy Framework 2021

The National Planning Policy Framework promotes sustainable development. The Framework specifies the need for protection of designated sites and priority habitats and species. An emphasis is also made on the need for ecological infrastructure through protection, restoration and re-creation. The protection and recovery of priority species (considered likely to be those listed as species of principal importance under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006) is also listed as a requirement of planning policy.

In determining a planning application, planning authorities should aim to conserve and enhance biodiversity by ensuring that: designated sites are protected from harm; there is appropriate mitigation or compensation where significant harm cannot be avoided; measurable gains in biodiversity in and around developments are incorporated; and planning permission is refused for development resulting in the loss or deterioration of irreplaceable habitats including aged or veteran trees and also ancient woodland.

The Natural Environment and Rural Communities Act 2006 and the Biodiversity Duty

Section 40 of the Natural Environment and Rural Communities (NERC) Act 2006, requires all public bodies to have regard to biodiversity conservation when carrying out their functions. This is commonly referred to as the ‘biodiversity duty’.

Section 41 of the Act requires the Secretary of State to publish a list of habitats and species which are of ‘principal importance for the conservation of biodiversity’. This list is intended to assist decision makers such as public bodies in implementing their duty under Section 40 of the Act. Under the Act these habitats and species are regarded as a material consideration in determining planning applications. A developer must show that their protection has been adequately addressed within a development proposal.

European Protected Species Policies

In December 2016 Natural England officially introduced the four licensing policies throughout England. The four policies seek to achieve better outcomes for European Protected Species (EPS) and reduce unnecessary costs, delays and uncertainty that can be inherent in the current standard EPS licensing system. The policies are summarised as follows:

Policy 1; provides greater flexibility in exclusion and relocation activities, where there is investment in habitat provision;

Policy 2; provides greater flexibility in the location of compensatory habitat;

Policy 3; provides greater flexibility on exclusion measures where this will allow EPS to use temporary habitat; and,

Policy 4; provides a reduced survey effort in circumstances where the impacts of development can be confidently predicted.

The four policies have been designed to have a net benefit for EPS by improving populations overall and not just protecting individuals within development sites. Natural England now recognises that the Habitats Regulations legal framework now applies to ‘local populations’ of EPS and not individuals/site populations.

Drone Use.

ROAVR Group was one of the first companies in the UK to regularly deploy unmanned aircraft for data collection to support arboricultural and ecological consultancy. Our directly employed staff all (as a minimum) hold an A2 CofC qualification and are operating under our Operational Authorisation, an annual permission applied for and granted by the UK Civil Aviation Authority. ROAVR believe that it is not possible to fully assess complex roof lines for potential roosting features without using this technology and in most cases the data is far more superior and robust than that gathered using traditional ground based methods such as ladders and binoculars. Only a small element of the data collected can be made available within the final PDF report and this is summarised within the field study elements. ROAVRs OPerator ID is GBR-OP-63WQD93CFL2F.