Bat mitigation class licence costs and registration

The bat mitigation class licence exists to take the low risk cases out of the bespoke queue. Where a scheme affects a small roost of a common species, a consultant who holds registered consultant status can register the site under the class licence and start work in a fraction of the time a bespoke application takes. That speed is the value, and the cost of the class licence route is mostly the cost of the consultant who can use it, rather than the charge for the licence itself.

Bespoke licence or class licence

Both routes exist under the Conservation of Habitats and Species Regulations 2017, which make it an offence to damage or destroy a breeding site or resting place of a European protected species without a licence. Bats are the species that brings most English development projects into contact with that regime.

A bespoke licence is applied for by the developer, with a named ecologist, for a specific site and a specific method statement. Natural England determines it against the three tests in the Regulations: that the work is for a purpose the Regulations permit, that there is no satisfactory alternative, and that the action will not be detrimental to the maintenance of the population at favourable conservation status.

A class licence works differently. Natural England has already granted the licence. What happens on a project is registration of the site by a consultant who has been accredited as a registered consultant under that licence, with the consultant taking responsibility for eligibility, method and compliance.

Who can hold and register under a class licence

Registered consultant status is granted to individuals, not to practices. Natural England sets the requirements, which combine a survey licence for the species, a defined level of documented experience of bat mitigation work, and an application assessed on the quality of that evidence.

Status has to be maintained. Registrations are audited, poor practice can lead to removal, and a consultant who loses status mid-project leaves the developer to find another registered consultant or fall back to a bespoke application.

That is the point a client should probe at appointment. Ask whether the individual, not the firm, holds current registered consultant status, when it was last renewed, and how many sites they have registered in the past two years. A practice with one registered consultant who is fully booked is not the same as a practice with three.

What the charges actually are

Natural England publishes a charging scheme for wildlife licensing, and the position on which services attract a charge has changed over time. Check the current published scheme rather than a figure from an older project, and ask the consultant to itemise the licensing charge separately in their fee proposal so you can see it.

The larger costs sit elsewhere. Budget for them as separate lines.

• Drafting the method statement and, for a bespoke application, the reasoned statement addressing the three tests.
• Building the mitigation: bat lofts, access tiles, boxes, sometimes a purpose-built structure, all of which are construction costs rather than ecology fees.
• Supervision during the works, which on a licensed site usually means an ecologist present for soft strip and roof removal.
• Post-development monitoring, commonly over several years, with a report to Natural England each time.
• Compensation habitat where the mitigation cannot be delivered on the building itself.

Treat the monitoring as a long tail liability with an owner. On a scheme that will be sold, decide early who funds and carries out monitoring in year five, because the developer who signed the method statement may be long gone.

Timescales and the build programme

The sequencing constraint catches more programmes than the cost does.

1. A preliminary roost assessment can be done at any time of year.
2. Emergence and re-entry surveys run through the summer season, and a roost cannot be characterised without them.
3. Planning permission has to be in place before Natural England will issue a bespoke licence, so the licence application follows the decision.
4. The licence or registration then has to be obtained before any work that would affect the roost.

Miss the survey season and the whole chain slides by a year. That is the risk worth pricing at the point of land acquisition, in the same way as any other sequenced investigation programme, such as a contaminated land investigation where a Phase 2 depends on a Phase 1 and both depend on access.

The class licence compresses step four, not steps one to three. It is a saving of weeks on a programme whose critical constraint is usually a survey season. And it saves nothing at all if the consultant is booked out until September.

Reporting obligations that carry cost

Licensing is not finished when the roof comes off.

Class licence registrations carry reporting requirements to Natural England on a defined cycle, and bespoke licences carry the returns set out in the licence itself. Both expect evidence that the mitigation was built as described, photographs, and monitoring results against the predictions in the method statement.

Where monitoring shows that mitigation has not been taken up, the licence conditions may require remedial action. That contingency rarely appears in a development appraisal and it should, because retrofitting a bat access into a completed roof is disproportionately expensive.

Where a bespoke licence is unavoidable

The class licence has eligibility limits, and they exist for good reasons. Expect to need a bespoke licence where the roost is a maternity site, where it supports a species of higher conservation concern, where numbers are high, where hibernation is involved, or where the impact cannot be described as low.

A consultant who tries to force a site into the class licence because it is faster is exposing both of you. The registration can be rejected, the works stopped, and in a serious case the offence is a criminal one under the 2017 Regulations and the Wildlife and Countryside Act 1981.

The evidence base that decides which route applies comes from the survey work, so commission it properly. A Bat Survey that characterises the roost, and a Protected Species Survey covering anything else present, are the documents on which the licensing decision rests. Surveys and any mitigation licence require a suitably licensed ecologist under the Wildlife and Countryside Act 1981 and the Conservation of Habitats and Species Regulations 2017, and an AI-assisted draft is a starting point for that professional rather than a substitute for them.

Budget licence work as a separate line from survey work, with its own programme float. See PlanScope pricing if you want the planning documents drafted while the survey season runs.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.