November 2024
What is District Level Licensing and how could it affect bats?
District Level Licensing (DLL) is an approach already used in the protection and conservation of Great Crested Newts when local populations will be negatively impacted by a development. The scheme can reduce the need for developers to carry out site-specific surveys and mitigation, instead requiring a payment to support targeted compensation measures away from their site, such as the creation of new ponds and other habitats. The aim is to provide a net increase in suitable habitat for this species, benefit populations and streamline planning and licensing.
The Nature Restoration Fund announced in the Budget has sparked discussions about DLL approaches being rolled out for other protected species, including bats. However, this type of scheme does not readily translate to bats and would negatively impact their recovery from significant historical declines. Whilst strategically placed and well-designed bat roosting features and dark wildlife corridors can benefit some bat species and should be encouraged, this will not compensate for development that does not consider bats at the site level.
Limitations of DLL for bat conservation
Firstly, we don’t know where all the bat roosts are so prediction of risk is challenging! Robust data on bat roost occurrence is difficult to collect without detailed, site-specific surveys. Predictive modelling to identify higher and lower risk areas (as has been done with Great Crested Newts) is less effective for bats because most areas of the UK, including urban and coastal areas, offer suitable roosting and/or feeding habitat for at least one of our 18 species. Bats are also more mobile, and some species exhibit roost switching behaviour, moving between multiple known roosts in a woodland or town. As a result, ‘risk zones’ for our 18 bat species don’t work that well because risk is difficult to predict, except in the case of a handful of very well-studied species and populations that exhibit high site fidelity.
Secondly, providing compensatory habitats for our 18 bat species is challenging. Great Crested Newts are a single species with straight forward and well understood ecological requirements. In comparison, the UK supports 18 different species of bat, each with its own distinctive ecological requirements which, for many species, are not well understood. Some bat species require highly specific conditions to survive. Other bat species are generalists, they can use a wide variety of roost types and habitats. Even so, all UK bat species are long-lived, and their survival depends on the use of well-established roosting and feeding areas. Ponds and terrestrial habitats created for GCNs tend to be readily colonised; colonisation of newly created bat roosting habitat can take many years and is not always successful for the target species. Our 18 bat species can’t easily be catered for by providing generic, offsite compensatory habitats.
Thirdly, as Natural England have acknowledged, DLL may result in the killing of newts on development sites. A similar approach would be disastrous for bats, quite apart from the ethical and legal issues it raises. At certain times of year, such as during the maternity season, a significant proportion of the local population will gather in a single location. If this location is destroyed this will have a huge impact on bat populations. Female bats typically only produce one pup per year so population growth and recovery from losses is very slow, meaning that populations cannot easily bounce back. A development affecting a swarming site, which attract bats from a wide geographical area during the autumn, could be devastating. Bats are also highly vulnerable when gathered in hibernation sites over the winter when their food resources are limited. All this means that even a small development involving the loss of a single structure which supports an important roost could have a devastating impact on local populations of the species concerned if carried out without site-specific consideration of bat conservation.
Fourthly, providing offsite compensatory habitats outside of the core sustenance zone of a roost (defined as ‘the area surrounding a communal roost within which habitat availability and quality will have a significant influence on the resilience and conservation status of the colony using the roost’) means that the bats affected by the development could take too long to find them or may not find them at all, which could impact breeding success and/or winter survival rates and thus populations.
Finally, the impacts of development on Great Crested Newts are simpler and better understood. For our 18 bat species, development impacts are often more complex and less researched, not least because there are 18 species in the UK.
Solutions are already available
The question should be: is the existing planning and licensing system broken for bats? The Government (2012) and Red Tape Initiative (2018) reviews, both found that the Habitats Regulations were fit for purpose, but both found issues with their implementation. Solutions to improve implementation of existing systems and processes are readily available, see below:
Conclusion
If applied to bats DLL could significantly undermine bat conservation. In comparison, small amendments to existing systems and, most importantly, improving resourcing would preserve certainty, be much easier to organise and would most certainly be less costly for the public purse, giving the planning and licensing system a genuine, unprecedented opportunity to work well for people and nature!
Jan Collins is Head of Biodiversity at The Bat Conservation Trust
The opinions expressed in this blog are the authors' and not necessarily those of the wider Link membership.
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