10th February 2022

Bat Conservation Trust response to the Quinquennial Review consultation

Every five years, the country nature conservation bodies (Natural England, Natural Resources Wales and NatureScot), working jointly through the UK Joint Nature Conservation Committee (JNCC), review Schedules 5 and 8 of the Wildlife and Countryside Act (WCA) 1981. The review will provide recommendations to the Secretary of State for the Environment, Food and Rural Affairs and to Ministers for the Environment in the Scottish Government and Welsh Government for changes to these schedules. This is known as the Quinquennial Review (QQR).

JNCC lead on a consultation to gather evidence and views about the proposed changes to the way species are included or excluded under this important piece of legislation. The Bat Conservation Trust has provided a response to the consultation which you can download HERE

We have welcomed the opportunity to raise some concerns, the main ones being:

  • The use of IUCN red listing is not appropriate for listing under the schedules, namely IUCN’s own guidance states “The Red List should… not be interpreted as a means of priority setting”.
  • The importance of expert opinion as part of the process to address matters of data deficiency, future threats, long‐term declines, and species particularly vulnerable to human activities.
  • The definition of ‘direct human pressures’ provides very narrow framing since human induced threats often have a significant role in driving declines for many species.
  • The definition of the term ‘place of shelter’ does not align with that given in the Habitats Regulations 2017 which is "any structure or place which any wild uses for shelter or protection" rather than that proposed which uses terms such as ‘regularly’ and ‘permanently’.

Our full response can be downloaded HERE. We hope these will be given full consideration so that the protection is not weakened in a way that could undermine some of the conservation gains made through the WCA over the last 30 years.

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