SBG standing advice on planning applications

The Bat Group is a consists of a small band of volunteers, and we regret do not have the resources to comment on, or carry out surveys for, individual planning matters.  Hence we rely on local residents to help Bats.  There is also the additional fact that many of the groups volunteers are also Professional Bat Consultants in their day jobs, and hence we have to avoid conflicts of interest.

Our parent organisation the BCT have produced an excellent Planning Advice Pack, and the best advice we can offer you, is to follow its advice carefully and to spread the information in it to your neighbours, as in planning, numbers do count:

If you are aware that protected wildlife species (like Bats) are resident (as opposed to foraging) on a site, then the Council should ask for an Ecological report before granting planning.  Hence do raise this urgently with the council if bats roost on the site and such a report is not already with the planning application.

Ecological Impact Assessments (EIA)

Speaking generally, large developers are now very used to the environmental requirements of planning, and most employ consultancies to carry out Ecological Impact Assessments (EIA), and recommend mitigations.  We are lucky in Somerset to have several highly respected ecological consultancies, and hence the quality of assessments and mitigations supplied to planning and their methodology tends to be high, and usually accepted by planning.  As a Bat Group we submit all our records to the Somerset Environmental Records Centre, and this data is used by all consultants in their reports, hence the Bat Group will not have additional data to add.

Hence we would suggest careful reading of the EIA, and to focus on adding known facts they may have missed, or local aspect they may have been unaware of.  (e.g. Other unrecorded protected species locally they may have missed), when you raise any objections to the Planning proposal.

Large developments

The other documents to look out for on larger developments are these key documents:

  • Landscape & Ecology Management Plan (LEMP)
  • Construction Environmental Management Plan (CEMP)

These are just as important as the EIA, and in particular you should definitely comment on these if they do not meet the recommendations of the EIA.

While developers are now very good at getting environmental concerns past planning, the experience is they are less good at meeting the environmental conditions placed on their planning permission, both during construction, and post construction maintenance. This tends to be where monitoring by local residents, and informing the council (and police as required) of breaches and environmental damage is so important.

Out of date planning surveys

We are sometimes asked if a old bat survey, that is past the expiry date set out in the document, will be accepted?

In theory a valid objection to planning could be made on the basis of a Bat survey that is out of date.

However in practice, there is a large amount of opinion and discretion in the planning process.  We have seen Bat surveys several years out of date accepted by Planning authorities.

Our thoughts would be that if the survey has found a significant maternity roost, especially if it is an uncommon or rare species, then a valid objection could be made, and the authority would probably have to request a re-survey, as the mitigations needed could well have changed.

However if the original bat survey found just commuting, foraging or night roosting, then a out of date survey would probably be accepted (unless very old).

There was a test case recently at Wolborough in Devon, on a 4 year old mitigation plan for Greater Horseshoe bats, which might prove useful background reading on this subject.

Please do not hesitate to contact the Bat Group if we can be of any other help.