Throwing bats under the train: HS2’s bat tunnel and the dangerous spin behind deregulation

The Planning and Infrastructure Bill (PIB) has been framed as the solution to an inefficient planning system supposedly held back by excessive environmental regulations. At the centre of this narrative? The HS2 bat tunnel, referenced at least ten times during PIB’s second reading.

Here is some key background to this story:

🔹 What is the bat tunnel? The Sheephouse Wood Bat Protection Structure (the real name of the bat tunnel) is a 900m-long structure designed by engineers to prevent the killing of rare bats and other wildlife by HS2’s high-speed trains as they travel through a fragment of biodiversity rich ancient forest.

🔹 Why does the bat tunnel exist? HS2’s route cuts through a cherished bluebell wood, home to 13 protected bat species, rare invertebrates, and legally protected breeding birds. This site holds local, national, and international conservation importance, and the law mandates measures to reduce harm. For more info, see Natural England’s response.

🔹 Who decided to build the bat tunnel? Not conservationists, and definitely not bats either! HS2 Ltd suggested it and parliament approved it (more detail on this below).

🔹 Why is the bat tunnel controversial? The bat tunnel is controversial because politicians now claim it was an unnecessary expense caused by environmental laws. But as we’ll explain in this article – this is far from the truth.

🔹 Why does it matter? The bat tunnel is being used to scapegoat bats and weaken environmental protections - without solving the real causes of planning delays. On top of that, implementing badly designed legislation is likely to lead to even more problems around planning decisions.

The table below separates rhetoric from reality, exposing the misleading claims about the HS2 bat tunnel and environmental laws.

Politicians are distorting past decisions of previous governments to justify weakening environmental protections. Government rhetoric suggests that conservationists forced the bat tunnel to be built - but that’s simply not true. And we think their rhetoric is working, as BCT is flooded with questions about our supposed involvement. But we had nothing to do with it!

Here are the facts about who actually proposed and approved the bat tunnel:

• HS2 Ltd, a government-owned company, proposed the structure. You can read what they have to say about it here.

• Parliament debated and approved it. As part of the HS2 planning process, ministers and MPs indirectly approved it as part of the High Speed Rail (London - West Midlands) Act 2017 which set the legal framework for HS2’s construction. The House of Commons and House of Lords Select Committees on HS2 reviewed the mitigation strategy and did not oppose it.

• The government chose not to conduct a Strategic Environmental Assessment (SEA). This could have flagged a better route and avoided the need for the bat tunnel altogether.

The Planning and Infrastructure Bill (PIB) will not fix the perceived issues with the planning system, but it will make it easier to destroy wildlife and habitats. Here are some key reasons why PIB won't work:

🔹 HS2’s failings were due to poor management - not environmental laws

Multiple cross-party inquiries have found that HS2's delays and cost overruns stem from mismanagement, not nature protections. Reports highlight:

• Underfunding and political interference.

• Poor route planning, leading to expensive last-minute fixes.

• Costly compensation payments due to flawed decision-making.

🔹 Housing delays aren’t caused by bats and other wildlife

Rhetoric suggests that bats and other wildlife prevent affordable housing being built. But where is the evidence for this?

Again, we do have evidence from government reports which identify underfunding, developer inefficiencies, skills shortages, and poor project management as factors which delay infrastructure projects rather than environmental regulations.

You can read more about the real problems delaying housing here:

• Review of the legislation protecting wildlife

• A third of homes granted planning permission are not being built

• Our shared future A TCPA White Paper for Homes and Communities January 2024

But wildlife keeps getting the blame. Recently, the distinguished jumping spider was blamed for blocking 15,000 homes but this was not true. You can find out more about this here: Conservation charities step into set the record straight after PM wrongly claims spiders stopped 15,000 home development.

🔹 The Planning and Infrastructure Bill and its rhetoric around the bat tunnel ignores the real fix

If the government really wanted to prevent future ‘bat tunnels’, they would strengthen, not weaken, early-stage environmental planning to avoid costly mistakes.

Nature has real economic value:

• Bats save farmers billions globally by controlling agricultural pests and reducing pesticide use.

• The UK’s biodiversity crisis threatens ecosystem services that underpin food production, flood protection, and public health.

• Scrapping protections won’t ‘free up’ growth - it will accelerate environmental losses which lead to economic losses.

Nature is vital to our safety, health and well-being:

• Weakening protections risks not only biodiversity loss but also the quality of life for future generations.

• Nature sustains the air we breathe, the water we drink, and the spaces we rely on for well-being.

• Green spaces improve mental and physical health.

• Thriving ecosystems build resilience against climate change and extreme weather.

International legal commitments:

Environmental laws exist to protect natural resources, ensure sustainable development, and preserve biodiversity for future generations. Countries sign up to these laws to foster global cooperation and address pressing environmental challenges.

• The UK is bound by agreements like the Bern Convention and the Convention on Biological Diversity.

• The UK’s National Biodiversity Strategy and Action Plan commits to halting and reversing biodiversity loss - yet the PIB contradicts these commitments.

Instead of using misleading rhetoric to justify environmental deregulation, policymakers should:

• Integrate nature into planning early, avoiding harm before expensive mitigation is needed (in a planning context, mitigation refers to the steps taken to reduce the negative impacts of a project).

• Fix inefficiencies in project management - many cost overruns stem from poor management, not environmental laws.

• Base policy on evidence, not political spin - ecologists aren’t ‘blocking progress’; they offer solutions that balance development and conservation.

You can find more from BCT on this here:

Avoidance, Mitigation & Compensation

Cost effective measures to reduce planning delays whilst delivering for species

Better planning needs real solutions, not blame games

• Share the facts: Help debunk the bat tunnel myth when you see it.

• Contact your MP: Ask them to oppose the PIB’s attack on nature.

• Stay informed: Follow BCT for updates on how to protect vital environmental laws by joining our campaign mailing list.

Let’s make sure conservation science isn’t misrepresented to justify reckless deregulation.