25th March 2021

Increasing reports of concerns around HS2

Joe Nunez-Mino

Bat Conservation Trust is an independent conservation organisation that makes decisions based on scientific evidence in order to pursue our vision of a world rich in wildlife where bats and people thrive together. We have recently been contacted by many members of the public with concerns relating to the HS2 project. BCT has limited resources and so does not currently have the capacity to investigate or provide specific advice on local planning or development cases. We rely on concerned members of the public to help us protect bats by bringing matters to the attention of the relevant authorities when there is a danger to bats and/or the law is being broken. We have information available via our website to help with any campaigns. This provides clarity and transparency on the law along with information about how decisions should be taken and implemented. These free resources can be accessed via our website HERE

We do occasionally publish position statements where a case threatens a bat population of national importance or has the potential of setting a precedent that could undermine the legislation that protects bats and other wildlife. We have previously issued a position statement on HS2 which can be found HERE.

We have tried to gain clarity on the approach that HS2 is taking to bat surveys, mitigation and licensing (see below), which are the most common areas of concern for members of the public, along with the associated potential for bat crime.

Bat Surveys

HS2 has informed us that they have used an alternative method to survey for bats in some of the woodlands on the Phase One HS2 route, with information gained from Advanced Level Bat Survey Techniques (ALBST), along with other supporting survey methods, rather than emergence and dawn surveys of each individual tree. This approach is described in more detail in this webinar: YOUTUBE VIDEO (bats are covered from around 24 minutes into webinar). We have not had the opportunity to assess this previously untested approach but it is approved by Natural England.

Any queries relating to survey work should be directed to HS2. Contact details are provided below.

BCT is organising the next UK Bat Steering Group meeting on the topic of tree/woodland surveys and mitigation and the HS2 approach will be discussed as part of the agenda – representatives of Natural England will be present. Representatives of the Woodland Bat Technical Advisory Group, made up of experts in the field of tree-roosting bats and surveys/mitigation, will be invited to the meeting. We hope this will provide more clarity on alternative approaches to bat surveys of woodland, along with other matters.


In England, destruction or damage to a bat roost is illegal unless an appropriate licence has been obtained from Natural England allowing the activity to go ahead legally. The licence is informed by survey work (which Natural England will have reviewed) and contains important conditions regarding how the work should be carried out (e.g. timings, working methods).

If you have information relating to licensed activities on HS2 that you think needs to be brought to the attention of Natural England or would like to seek information on licences issued to HS2, you should contact them. Contact details are provided below.

Wildlife Crime

If you believe a wildlife crime is being committed or is about to be committed on the HS2 project and you have evidence to support this (including HS2 or other survey reports, evidence of no licence in place to allow activities, photos, videos, records of bats) then you should report the matter to the police by calling 101. During the call you should obtain a Police Incident Number. Where appropriate and where capacity allows we can engage with the relevant police force on the matter and offer independent support and guidance through our Wildlife Crime Project.

Loss of Ancient Woodland

Regardless of the approach taken to bat surveys, mitigation and licensing, the overarching issue cannot be ignored, which is that HS2 involves the removal or damage of at least 108 Ancient Woodlands (source: Woodland Trust). These are irreplaceable habitats that have developed over hundreds of years, which support countless species of wildlife. The loss of bat roosts and commuting and foraging habitats in these Ancient Woodlands cannot be compensated for within a meaningful timescale for important bat populations by any amount of new planting, veteranisation of trees and the erection of bat boxes. For this reason, Bat Conservation Trust urges HS2 to reconsider its plans so that it can minimise disturbance and avoid destruction of ancient woodland. Unless HS2 reconsiders its plans, the Bat Conservation Trust cannot support the approach of the HS2 project.

Contact details

HS2: HS2Enquiries@hs2.org.uk, Freephone: 08081 434 434, Minicom: 08081 456 472

Natural England: hs2@naturalengland.org.uk or enquiries@naturalengland.org.uk

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