22nd January 2025
The Bat Conservation Trust is concerned because planning reforms in a new Working Paper include scrapping the need for site surveys and on-site impact avoidance or mitigation for some building developments in England. We believe this could cause devastating impacts on our 18 bat species as well as damage irreplaceable habitats. As such, we have responded to the government and ask bat conservation supporters to help us.
We don’t need to pit developers against nature
Our wildlife laws have wrongly been attacked in certain quarters of the media and in politics. However, multiple government reviews have found that the legislation is fit for purpose and that it is the implementation and lack of funding for local planning authorities and Natural England that need to be addressed.
The government’s proposed planning reform will create a confusing situation for planners and developers, most of whom want to work within the law and play their part in nature recovery.
The planning process could and should play a crucial role in nature recovery. However, as they stand, the proposals in the new Working Paper will not have a positive impact and will in fact have a negative one.
Why the planning reform Working Paper is a threat to wildlife

Proposed planning reform will create a confusing situation for planners and developers. Credit Hugh Clark.
The proposals in December 2024’s Working Paper will, if applied, undermine nature recovery by weakening or removing the protection provided by the Habitats Regulations and the Wildlife and Countryside Act 1981. You can find out why these protections are necessary here: Are UK bats threatened?
Proposals include removing the requirement to carry out site surveys and the need for on-site impact avoidance or mitigation when submitting planning applications in certain circumstances. The results would have devastating impacts on our 18 bat species and many others, as well as on irreplaceable habitats. Beyond this, it would be impossible to measure the impacts due to skipped surveys, which would normally form a baseline for comparison.
Changes could allow developers to pay into the newly proposed Nature Restoration Fund to break the law and avoid taking necessary steps to protect species and habitats on the sites they are working on. Furthermore, the proposals would disincentivise developers from engaging proactively with nature recovery.
Additionally, the Working Paper includes a reference to expanding District Level Licensing. However, this type of scheme does not readily translate to bats and would negatively impact their recovery. You can read more about this idea in a blog by our Head of Biodiversity, Jan Collins: District Level Licensing won’t work for bats, not all species are the same.
The Working Paper contradicts the National Planning Policy Framework
Confusingly parts of the Working Paper seem to agree with our own position on the need to 'rebuild nature at the same time as building the sustainable homes, clean power, and other infrastructure we need,' as outlined in our Bat Conservation Manifesto.
This confusion deepens when the Working Paper is compared to the National Planning Policy Framework (NPPF) updated in December 2024. This sets out the government’s planning policies for England and how these should be applied.
In the NPPF, it is stated that planning policies and decisions should:
'Contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures and incorporating features which support priority or threatened species such as swifts, bats and hedgehogs.'
However, proposals in the Working Paper contradict the NPPF by not minimising impacts and unlinking any compensation from the affected site.
How BCT is working on this issue
We continue to defend bat conservation where it has been presented inaccurately in the news and by politicians. You can find many examples of this on our news page.
In December 2024, we contacted the Secretaries of State for the Ministry of Housing, Communities and Local Government and the Department for Environment, Food and Rural Affairs, highlighting several cost-effective measures to reduce planning delays whilst delivering for species.
We welcomed the government’s invitation to respond to the Working Paper to inform discussions with communities and the development sector for the next stage of this policy development. Our response: BCT Response to the Ministry of Housing, Communities and Local Government.
BCT will carry on our advocacy for bats as these proposals develop.
Help us fight for bats
The protection of bats, our environment and wider natural heritage, does not need to be sacrificed to achieve ambitious development targets. BCT is working hard to prevent this from happening but we need your support. Here are some ways you can help.
Contact your MP (you can find contact details online):
- Flag our concerns with the Working Paper by sharing this news piece with them.
- Share our planning briefing: Cost-effective measures to reduce planning delays whilst delivering for species.
We have also created a template text which you can download from HERE
If you are part of a local bat group or other organisation, respond to the Working Paper proposal. The response portal is Planning Reform Working Paper: Development and Nature Recovery. And for reference, our response is here.
Donate or join the Bat Conservation Trust: Support Bats
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