Guidance - Bat Low Impact Licensing (BLIMP) - An ecologist's guide

What is it?

BLIMP (Bat Low Impact licensing) is a way of streamlining bat licensing for ecologists, allowing them to permit works with low conservation impacts to go ahead, providing the situation meets clear criteria, without the need to submit individual licence applications for each development site.  Prior to permitting works to commence on a site the ecologist must notify NatureScot licensing team of the site details, and receive confirmation that the site has been registered.

BLIMP licences rely on licence holders understanding and adhering to the terms and conditions of the licence, carrying out bat surveys according to best practice as set out in the document entitled "Bat Conservation Trust, Bat Surveys for Professional Ecologists, Good Practice Guidelines (4th Edition), Collins, J., 2023, and ensuring that all bat survey reports and bat protection plans are written in a way that adheres to the current industry standard.  

If licence holders do not comply with the terms of their licence it will be revoked.  The NatureScot licensing team will monitor works carried out under BLIMP licences annually by reviewing a random sample of bat surveys and bat protection plans and visiting a selection of sites to ensure works are being carried out in accordance with the terms and conditions of the BLIMP licence.

When can the BLIMP licence be used?

A BLIMP licence can be used if all of the following conditions are met:

1. The site is on mainland Scotland;

2. The proposal only affects soprano pipistrelle or common pipistrelle bat roosts which are not used for breeding or as hibernacula;

3. Bat surveys of the development site have been overseen by an ecologist who holds a current bat survey licence valid for Scotland, in accordance with best practice as outlined within the document entitled: "Bat Conservation Trust, Bat Surveys for Professional Ecologists, Good Practice Guidelines (4th Edition), Collins, J., 2023;  

4. Works on site affecting bats will commence within 24 months of the date bat surveys were completed;

5. A site specific bat protection plan written by an ecologist who holds a current bat survey licence valid for Scotland, is in place, which details how works will be carried out on site to minimise the impacts of works on bats and bat roosts;

6. There is no alternative to the proposal (a simple design change) that will avoid the impact to bats and/or bat roost.  The site specific bat protection plan referred to above must clearly consider alternative options which would avoid impacts to bats and bat roosts, and a justification given for discounting these options if appropriate;

7. The proposal has planning permission or a building warrant in place, is required in order to prevent serious damage to property, or is necessary for preserving public health or safety;

8. The site has been registered with NatureScot licensing team (see details below);

9. Prior to works commencing on each site: Purpose-built woodcrete bat box(es), suitable for the species of bat present and the time of year works are being carried out, are erected on a suitable structure, in a sheltered position, within 100 metres of the site; or a suitable alternative roost site identified in the bat protection plan has been made available to relocate any bats found during works;

10. Prior to works commencing on site, all workers have been briefed by the licence holder or agent appointed by the licence holder, about the likelihood of bats being found on site, the terms of the licence, the requirements of the bat protection plan, and protocols in Annex IV "Agent Authorisation to Oversee Works on Site";

11. A copy of the site specific bat protection plan and “Annex IV - Agent Authorisation to Oversee Works on Site" is displayed on site for the duration of all works covered by the BLIMP licence.

What will the BLIMP licence permit?

A BLIMP licence will permit the following actions;

• damage or destruction of soprano pipistrelle or common pipistrelle bat roosts which are not used for breeding or as hibernacula, on mainland Scotland;
• temporary disturbance of those species in those roosts
• obstructing access to those roosts
• temporary handling of any bats of those species found during the course of works

The BLIMP licence will not cover activities affecting other bat species or other types of roost.  However, this will not preclude working under the BLIMP licence at a site where other species or roost types are present providing that the works will not affect them.   

How works should be undertaken

It is important to ensure that when works are undertaken that affect bat roosts they should be carried out with due care and attention to minimise the welfare risks that might be posed to any bats that might be present.  In these low-impact cases, we consider that it will not always be necessary for the licence holder to be present providing that the persons carrying out the work do so with that due care and attention.  This is a judgement for the licence holder to make, but they should consider factors such as the potential risks to bats and the level of technical skill or experience to carry out the on-site activity in question. 

Who will be covered by the licence?

Given the above, a BLIMP licence holder can therefore authorise people on site to carry out those activities.  This effectively means that they will be acting as agents on the BLIMP Licence holder’s licence.  It will therefore be crucial for the licence holder to ensure that the agents understand what they can or cannot do.  Each time an agent is authorised by the BLIMP licence holder to oversee works on site an “Annex IV - Agent Authorisation to Oversee Works on Site" must be signed by the appointed agent prior to works commencing on site.  The signed form must be retained by the licence holder for their records.

How do you register a site?

The licence holder must record each new site covered by their BLIMP licence on their “Annex III - Permitted sites and returns form”, by completing all the columns (A-I) within the green and white sections of the form (site name, site grid reference (minimum six figure), the proposed start and end dates of works, the bat roosts affected, the licensing purpose for which the works are required, justification of the purpose, alternatives considered, roost number, species and roost type).  The updated form must be sent to [email protected] each time a new site is added, and the licence holder must receive confirmation that NatureScot Licensing has received this notification and registered the site prior to any works commencing on site.

How do you submit a licence return?

The BLIMP licence holder must provide NatureScot licensing team with a completed “Annex III - Permitted Sites and Returns Form”, which list each site covered by the BLIMP licence, with all columns (A-M) on the sheet completed for each site.  The return must be submitted within one month of the expiry of the licence.  This information must be sent by email (including your licence number in the subject line of the email) to: [email protected].

Who can get a BLIMP Licence?

The BLIMP licence will be issued to any ecologist who holds a current bat survey licence for Scotland, and has either held or been the named agent on a minimum of three “works affecting bats” licences for Scotland in the last three years.  The ecologist must have carried out the survey work themselves in support of the three development licences, and have written or signed off the Bat Protection Plan.  All survey work must be deemed to have been carried out in accordance with current best practice by the NatureScot Licensing team.  Quality of previous applications will be assessed by NatureScot Licensing Officers and will be based on adherence to current best practice documents and industry standards, and justification of non-standard approaches.

The licences will be issued for a 2 year period after which a review will take place by NatureScot Licensing Officers of the work carried out under these licences, in particular looking at adherence to the terms and conditions of the licence and quality of bat surveys and bat protection plans produced against best practice.  During the year Licensing Officers or Operations staff will also visit a selection of sites to ensure works are being carried out in accordance with the terms and conditions of the licence.

How we will monitor standards

Licence holders will be expected to retain bat survey reports for all registered sites, and to provide these together with site specific bat protection plans, to NatureScot Licensing on demand for quality assurance checks.  NatureScot will check a random sample of bat survey reports and bat protection plans from all licence holders, we will also visit some sites to check compliance with licence conditions.

When might a BLIMP Licence be revoked?

Where deviation from best practice has clearly taken place with no reasonable justification within the bat survey report, or the terms and conditions of the licence have not been upheld, there may be grounds for revoking the licence.  Surveys and Bat protection plans must meet criteria set out in “Annex II - BLIMP bat surveys and bat protection plans checklist – a guide for ecologist”, and adhere to best practice guidance described in the Bat Conservation Trust Bat Surveys for Professional Ecologists Good Practice Guidelines (4th Edition), Collins, J., 2023.

What we will look for

Have bat surveys been carried out by an appropriately licenced ecologist, and do they accord with current best practice guidance?

• The bat surveys do not have to be carried out by or overseen by the BLIMP licence holder, but they must have been overseen by an ecologist who holds a current bat survey licence valid for Scotland, and all other surveyors must be shown to have suitable survey experience.  The surveys must also have been carried out in accordance with best practice as outlined within the document entitled: "Bat Conservation Trust, Bat Surveys for Professional Ecologists, Good Practice Guidelines (4th Edition), Collins, J., 2023”.  The BLIMP licence holder is responsible for making sure that any bat surveys used to inform works on a site covered by their BLIMP Licence accord with best practice and have been undertaken by appropriately licenced/experienced ecologists.  This is to give confidence in survey results.

Has the bat survey been undertaken within 24 months of the start date of the works?

• Our current guidance is that bat surveys are valid for a period of 24 months, after which further survey work to update the results must be carried out.

Description of site

• The report should give a clear description of the site layout, building/structures/trees present that will be impacted by works, and surrounding habitat.  The description should be clear enough to give a licensing officer an accurate picture of what the site looks like, the structures present that will be impacted by works and should be accompanied by maps/photographs to illustrate this.  If there are buildings or structures on site that are not to be impacted by works and therefore do not form part of the bat survey, this should be made clear in the survey report.

Details of proposed works

• Details of the proposed works and how they will affect each building/structure/tree on site covered by the bat survey should be detailed and clear.  For example, ‘roofing works’ alone would not be sufficient, but roofing works including the removal and replacement of slates and sarking in areas x, y, z on building 1 would be.

Bat Survey Coverage

• The number of surveyors present during each survey should be given, and diagrams/photographs must be included to show surveyor positions around each structure surveyed, for each survey undertaken.  This should clearly show that all aspects of the structure with bat roosting potential were adequately covered during each survey.

Names of surveyors and their survey experience

• The names of all surveyors present during the surveys should be listed.  Details of their survey experience and their licence number if they have one must be given.  This is required to give licensing officers confidence in survey results.

Survey equipment

• Survey equipment for all surveys/surveyors should be listed. All bat detectors must include recording functionality.

Survey start/end time

• This should be included for all activity surveys. This can be either the exact times of the start/finish or the length of time before/after sunset/sunrise (in accordance with best practice).

Sunset/sunrise times

• This should be included for all activity surveys so that we can be confident that surveys started/finished at appropriate times in accordance with best practice.

Weather

• Details of temperature, wind speed and precipitation must be given. This should show that surveys are carried out in appropriate weather conditions where bat activity is likely.

Limitations/constraints and deviations from best practice

• All limitations of the bat surveys (including the PRA), and any deviations from best practice must be detailed and a justification given as to why survey results are still robust and comprehensive.

Emergence/return time

• Times of all bat emergences/returns should be detailed.

Species

• Bat Species should be identified for all emergences and/or returns. If the species is not identified clearly from echolocation, then species should be identified by other means (bat in hand/dropping analysis/DNA etc.).

Numbers

• The numbers of bats emerging/retuning at each location should be provided as accurately as possible.

Roost location and entry/exit points

• The numbers of bats emerging/retuning at each location should be provided as accurately as possible. All bat roost locations and their entry/exit points should be identified and made clear in the bat survey report (using maps and photographs).

Roost types

• Roost type should be given for each roost in each structure impacted by works together with a robust reasoning for this assessment.

Confirmation of no other roosts on site that will be impacted by works, but not covered by BLIMP

• A BLIMP licence must only be used to cover work on sites where bat roosts impacted are those covered under the terms of a BLIMP licence. If other roosts are found on site and will be impacted by works (i.e. maternity roosts), then an individual licence for the site must be obtained.

Consideration of Satisfactory Alternatives

• There must be a Site Specific Bat Protection Plan written for each site covered by BLIMP. This must clearly consider alternative options to the proposed works which would avoid impacts to bats and bat roosts. A justification must be given for discounting these options as appropriate. The conclusion of this consideration of alternatives must be that there is no alternative to the proposed works (a simple design change) that will avoid the impact to bats and/or bat roosts.

Details of the impact of works on each roost and is it sufficient

• Details of the impact of works (disturb, obstruct, damage, destroy) on each bat roost present in the structure(s) should be detailed in the Bat Protection Plan.

Details of proposed mitigation and is it sufficient.

• Details of all mitigation proposed to minimise the impact of works on bats should be included in the Bat Protection Plan and should be appropriate for the roost types and works proposed. This must include provision of mitigation as specified by the conditions of the BLIMP licence.

Details of proposed compensation and is it sufficient

• Details of any proposed compensation for the loss of roosts should be detailed, and should accord with the English Nature Bat Mitigation Guidelines (2004) for the species/roost type.

How do I apply for a Bat Low Impact Licence (BLIMP)?

To apply for a Bat Low Impact Licence (BLIMP) please email [email protected] with the following information:

Name

Organisation/consultancy name (if this is your work address)

Address and postcode

Type of address (home or work)

Contact telephone number(s)

Scottish Bat Survey Licence Number

Please provide the licence numbers of three Scottish “works affecting bats” licences that you have either held or been the named agent for in the last three years. You must have carried out the bat survey work in support of these licences, and have either written or signed off the bat protection plan for these licences.

Please note:

• That it is an offence under Regulation 46 of The Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) to knowingly or recklessly provide false information in order to obtain a licence.
• That failure to comply with any conditions included on any licence granted in respect of this application may constitute an offence.

How we adhere with the Data Protection Act and the Scottish Regulators' Strategic Code of Practice

Please telephone the Licensing Helpline on 01463 725 364 if you require any assistance.

Published: 2019