12th June 2020
Reports we have been receiving about potential disturbance and damage to bat roosts in trees during the maternity season in Warwickshire woodlands (Kenilworth Sites) due to HS2 Phase One construction is a cause for concern for BCT. We are seeking further clarification around the both the licence and practice on the ground during felling as we have some specific concerns.
As far as we understand at the time of writing, Natural England extended the bat licence permitting felling activities in Warwickshire woodlands known to support maternity colonies to 15 May, two weeks beyond what is considered to be the start of the maternity season. We also understand that this extension was subject to a condition (B13) that states that: Licensable activities impacting satellite, maternity and hibernation roosts must not be undertaken while the roost is in use for these purposes.
Approaches described in the Kenilworth Sites licence Work Schedule to protect bats from harm during felling include:
- Pre-works inspection by Named Ecologist or Accredited Agent - Tree climb by named ecologist / accredited agents of all roost trees and potential roost trees prior to felling to inspect for bats.
- Permanent exclusion measures (e.g. use of one-way excluders prior to permanent blocking of access points or destruction of roost) - Where bats found or features can’t be fully inspected, exclusion process to be undertaken in line with MS.
- Destructive search by soft demolition - Soft felling procedures under supervision of named ecologist / accredited agent for trees unsafe to climb or where PRFs not fully accessible.
(MS = Method Statement, PRF = Potential Roost Feature)
We are seeking further clarification around the licence extension and around practice on the ground during felling because we have the following specific concerns:
- It is not always possible to establish presence/absence of bats in tree features because they are not always safe to access for inspection and are sometimes too extensive for thorough inspection, even with equipment such as an endoscope. How can the absence of maternity colonies be established with certainty before permanent exclusion or soft felling in such cases?
- If bats are found it is not always possible to establish whether or not they are breeding bats just from inspection surveys because the bats are tucked away deep into tree features. A small number of bats could represent a maternity colony in their own right or may be joined by others later, which is an especially high risk factor when carrying out such work early in the maternity season. How can breeding and non-breeding roosts be separated in such cases in order to protect the breeding ones?
- Tree clearance works around a maternity roost, even if the roost itself is retained, could cause disturbance through noise, vibration and the removal of habitats important for the sustenance of the colony (including suitable alternative roosts). How are these impacts on maternity colonies being accounted for?
- Tree roosting bats will utilise a number of trees within a woodland area over the maternity season. Concerns are that the significant loss of trees in these woodlands will have removed all, or the vast majority, of the alternative roosts available to the impacted colonies.
We are investigating this matter as protecting maternity roosts from disturbance at this sensitive time of the year is particularly important.
1st July 2020