Residential Development, Hampshire: Applying Licencing Policy 4 to avoid project delays


BSG Ecology applied their knowledge of bats and experience and understanding of species licencing to avoid potentially lengthy and costly delays to a residential development where bats, including greater horseshoe, were unexpectedly discovered.


During a residential development project in Hampshire, building contractors had discovered several pipistrelle bats when removing a roof covering. The ecological consultants working on the project at the time were unable to define a way forward, and work had temporarily stopped as a result. Based on our previous success in helping to avoid delays to development by obtaining a bat mitigation licence through the use of Natural England’s Licencing Policy 4, our client approached us to help find a solution.

No bat survey work had been undertaken prior to the granting of planning consent and due to the time of year bats had been discovered (November 2019), no bat activity survey could be undertaken without causing a significant delay to the project, (May-August being the main bat activity survey season). The site owner was understandably very concerned about the cost implications and uncertainty from a lengthy delay to the project, and was looking for guidance as to whether Licensing Policy 4 might be applicable to the situation.


In exceptional circumstances, Licensing Policy 4 permits lower than standard survey effort for European Protected Species (bats in this case). After initial discussion with our client, and a site visit to assess the building and assess the likely status of bat roosts within it, BSG Ecology was able to provide a level of confidence that a successful licence application under Policy 4 was achievable, despite the survey findings adding another layer of complexity to the initial situation.

The building was found to support a soprano pipistrelle maternity roost (1000s of droppings were present), a brown long-eared roost (an overwintering individual was present during the survey) and, most significantly, a greater horseshoe roost. All species were confirmed by DNA analysis of droppings. Greater horseshoe is one of the UK’s rarest bat species.

In order to secure a Bat Licence under Policy 4 and avoid any further delays to the project that might ordinarily come about through the need to undertake further bat survey, we had to demonstrate that:

  1. The costs or delays associated with carrying out standard bat survey requirements would be disproportionate to the additional certainty this would bring;
  2. The ecological impacts of development could be predicted with sufficient certainty and;
  3. Mitigation or compensation could ensure that the licenced activity would not detrimentally affect the conservation status of the local populations of the species concerned.

We worked closely with our Client and their Architect to put forward a comprehensive mitigation strategy. This will incorporate a variety of roost features into a new garage block and involve construction of a stand-alone roost for greater horseshoe bat. We also put together a well-argued and practical case, as to why development should be allowed to proceed without the need for further survey and assessment.


Natural England agreed with our analysis and was satisfied with the mitigation proposed. A licence was granted without any queries from Wildlife Advisors.

Destructive searches of the building were able to proceed in March 2020, avoiding the costs of further bat surveys in the summer and thereby allowing works to proceed at least six months sooner than might otherwise have been the case.

Client Feedback

“I was very pleased with the technical advice and support I received from BSG Ecology in particular the work of David Stiles who handled the case. I was very impressed by David’s grasp of the potential financial impact the project faced and his can do attitude in getting the project back on track with minimal disruption successfully navigating through a relatively unknown and rarely used piece of legislation.” 

Mr M J Price

Bats, Projects, Protected Species, Residential/ Commercial Development, South East