Reviewing another consultant's ecology report
A technical review checks survey effort against published guidance, tests whether the conclusions follow from the data, and asks whether the mitigation could be built and licensed.
A technical review of somebody else's ecology report is not a rewrite and it is not an opinion. It is a structured check of whether the survey effort matches published guidance, whether the conclusions follow from the data, and whether the mitigation could actually be built and licensed. Done properly it takes half a day for a small site and produces two or three pages a case officer can act on.
Start with the dates. Half the reports that reach a reviewer fail on currency before anything technical is examined, and there is no point auditing survey effort in a report whose data is four seasons old.
Survey dates and whether the report is still current
Record four dates for every report: when each survey visit took place, when the report was written, when the application was submitted, and today.
Ecological data has a working life. The professional guidance treats it as time limited, and the practical position most authorities take is that data more than two to three seasons old needs revisiting, with a shorter period where the site or its surroundings have changed. A building that has been reroofed, a field that has been ploughed, a hedge that has been grubbed out, a neighbouring site that has been built on: any of those resets the baseline whatever the calendar says.
Say so explicitly in the review, with the dates in a table. An officer can act on "the emergence surveys were carried out in 2023 and the barn has since been partially reroofed" in a way they cannot act on "the survey data may be out of date".
Effort against published guidance
This is the core of the review and it is largely mechanical.
For bats, the assessment of roost suitability drives the number of emergence and re-entry surveys required, and the current good practice guidelines set that out by suitability category. Check three things: whether the suitability assessment is evidenced or asserted, whether the number of surveys matches the category assigned, and whether the surveys fell in the correct months and were spaced appropriately. A high suitability building with one dusk survey in April is a deficient report and it is not a matter of professional judgement.
For great crested newts, check the habitat suitability index scores, whether environmental DNA sampling fell within the recognised window, and whether population class assessment was needed for the mitigation proposed.
For reptiles, check the number of refugia, the density across the habitat, the number of visits and the temperature conditions recorded on each.
For breeding birds, check the number of visits, their spacing through the season and the time of day.
For everything, check whether the surveyor was appropriately licensed where a licence was required to carry out the work.
| Common deficiency | What to say in the review |
|---|---|
| Survey effort below guidance for the suitability category assigned | Name the guidance, the category, the required effort and the effort delivered |
| Surveys outside the optimal season | State the months surveyed and the months recommended |
| Roost suitability downgraded without evidence | Ask for the features recorded and photographs |
| No access to a roof void or a locked building | Identify the unsurveyed feature and its suitability |
| Single visit where repeat visits are specified | Ask for the additional visits before determination |
Scope gaps and the features nobody looked at
Read the methods section against the site plan and the red line, then look for what is missing rather than what is there.
The recurring gaps are a roof void that could not be accessed, trees not inspected from height where ground level assessment found potential roost features, land outside the red line that the development will affect, lighting effects on foraging routes, and cumulative effects where other schemes are in the pipeline.
Absence of evidence is reported as absence far too often. A report saying no bats were recorded, where the survey did not cover the part of the building with the highest potential, has not established anything about that part of the building.
Habitat mapping is worth checking against the aerial imagery and against any earlier survey of the site. Parcels that have been merged, boundary features omitted and habitats classified generously all change the baseline.
Baseline condition scoring and its evidence
Where a biodiversity metric sits behind the report, the condition assessments are where the units come from and where the review earns its fee.
Check that a condition sheet exists for each parcel rather than a single line in a table. Check that the criteria were assessed against evidence rather than assumed. Check that the survey supporting the condition assessment was carried out in a season when the criteria could be judged, because grassland condition cannot be assessed in February.
Check the direction of the errors. Baselines scored low and post development conditions scored high is a pattern, and it is the pattern that produces a comfortable percentage gain on paper.
Then check the delivery side. Habitats that are hard to create carry difficulty and time to target condition multipliers, and a scheme that depends on creating them needs the specification and the management plan to match. The spatial risk multipliers apply where delivery is off site, and they are commonly omitted.
Mitigation that is asserted rather than designed
The test to apply is whether a contractor could build it from the document.
"Bat boxes will be installed" is an assertion. A design states the number, the type, the elevation, the height above ground, the orientation, the mounting detail and who checks it. The same applies to bird boxes, hibernacula, ponds, gapping up and everything else.
Look for four things in any mitigation section: a drawing, a quantity, a timing, and a person responsible. A section missing all four is a statement of intent, and a planning condition requiring the development to be carried out in accordance with it will be unenforceable.
Compensation should be proportionate to what is lost. Replacing a maternity roost with two boxes on a post is not proportionate, and a reviewer should say so plainly rather than leaving the officer to infer it.
Licensing feasibility and the derogation tests
Where the works will unavoidably breach the protection given to a European protected species, a licence will be needed, and an authority is expected to consider whether one is likely to be granted before permitting the development.
Three tests have to be satisfied. That the development serves a purpose of the kind the regulations recognise, that there is no satisfactory alternative, and that the favourable conservation status of the population will be maintained.
A review should say whether the report addresses each of them and whether the mitigation proposed could carry the third. Mitigation that is not capable of maintaining favourable conservation status is not a licensing problem to be solved later. It is a reason the permission should not be granted in that form.
The survey and licensing work itself has to be carried out by a suitably licensed ecologist under the relevant regulations, which is worth restating in the review where the report's author is not identified or their licence is not quoted. The protected species survey route and the competence it requires are not optional.
Writing a review a case officer can act on
Officers are not ecologists and are working to a deadline. The review that gets used has this shape.
- A short paragraph stating whether the submitted information is sufficient to determine the application.
- A numbered list of deficiencies, each with the guidance or standard it fails, the consequence for the assessment, and what would resolve it.
- A clear split between items that must be resolved before determination and items that can be secured by condition.
- Suggested condition wording where conditions are appropriate.
- A closing recommendation in one sentence.
Point three is where a review earns its keep. Officers need to know which objections are fatal and which are administrative, and reviewers who present everything at the same weight get ignored.
Where to stop and recommend resurvey
Stop when the gaps are structural rather than presentational. If the survey effort falls materially below guidance, if the season was wrong, if a feature with high potential was never accessed, or if the data predates a physical change to the site, further analysis of the existing report is wasted effort.
Say it in one sentence, give the specification for what should be done and when the window opens, and stop there. An honest recommendation to resurvey saves more time than a detailed critique of a report that cannot support a decision.
The wider question of how effects are judged once the baseline is sound is a separate exercise, and the approach to significance of effects is what the resurveyed data eventually feeds. Reviewers who take on sign-off work can be found through the professional directory.
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.
Frequently asked questions
How old can ecological survey data be before it needs redoing?
Professional guidance treats ecological data as time limited, and most authorities expect data more than two to three seasons old to be revisited. The period shortens where the site or its surroundings have changed. A reroofed building, a ploughed field, a grubbed out hedge or a neighbouring development all reset the baseline whatever the date says.
What is the fastest way to test survey effort?
Compare the roost or habitat suitability category assigned in the report with the survey effort the relevant good practice guidance specifies for that category, then check the months and the spacing of visits. A high suitability building surveyed once, outside the optimal season, is deficient as a matter of method rather than judgement.
How should mitigation be tested in a review?
Ask whether a contractor could build it from the document. Look for a drawing, a quantity, a timing and a named responsibility. Bat boxes will be installed is an assertion. Four boxes of a stated type at a stated height and orientation on a stated elevation, installed before first occupation, is a design a condition can enforce.
What should a review say about licensing?
Whether the report addresses the three derogation tests and whether the mitigation proposed could satisfy the requirement to maintain favourable conservation status. Mitigation that cannot is not a licensing problem to be resolved later. Say so plainly, because an authority is expected to consider licensing prospects before granting permission.
When should a reviewer stop and recommend resurvey?
When the gaps are structural rather than presentational: effort materially below guidance, the wrong season, a high potential feature never accessed, or data predating a physical change to the site. Give the specification for what should be done and when the window opens, then stop. Further critique of an unusable report wastes everyone's time.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.