1. Best Practice in Biodiversity
Report Writing for Development
Sites
Adam Egglesfield
Senior Ecologist
Hampshire County Council Ecology Group
01962 832334 / 07718 146584
adam.egglesfield@hants.gov.uk

2. This talk will cover…
• Why biodiversity reports are needed
• When they are needed
• What purpose reports should serve
• Different approaches for different situations

3. This talk is not…
• Teaching planning officers how to be
ecologists…
• Telling experienced consultants how to do their
job!

4. Why?
Before making an application, the applicant needs
to know what (if any) ecological issues need to be
addressed, and how to address them.
Before making a decision, the planning officer
needs to know what the issues are and if they
have been fully addressed.

5. Why?
• Planning Authorities:
– Legal drivers
– PPS9 / NE standing advice / Habitats Regulations
– Case law (Woolley, Cornwall case)
– Robust evidence on which to base planning
decisions

6. Why?
• Developers:
– Ultimately, to gain planning permission
– Reducing risk of non-compliance with legislation
– Reducing risk of delays to work programmes
– Reducing risk of being the target of legal action
– Potential for obtaining positive public relations
– Satisfaction at achieving benefits for biodiversity

7. When?
• PPS9 & Circular:
– Para 98: The presence of a protected species is a
material consideration when a planning authority is
considering a development proposal that, if carried
out, would be likely to result in harm to the species or
its habitat.
– Para 99: It is essential that the presence or otherwise
of protected species, and the extent that they may be
affected by the proposed development, is established
before the planning permission is granted.

8. When?
• 1APP
– ‘…is there a reasonable likelihood of the
following being affected adversely or conserved
and enhanced within the application site or on
land adjacent to the application site?
• Protected and priority species
• Designated sites, important habitats or other
biodiversity features’

9. When?
• Natural England standing advice on
protected species
– Full protected species information must be
provided with application – to include surveys, and
if necessary, a mitigation strategy that can be
secured through conditions or other mechanism
– Provision of this information should not deferred
as condition of any permission

10. When?
• Applicants – HIPOG Biodiversity Checklist for some
types of application (but not always householder)
– Submitted with application
– If not submitted or incorrectly completed, application
shouldn’t be validated
– Has this identified the need for further biodiversity info?
– Planning officers can request further info from applicants

11. When?
• Planning officers – can use the HIPOG Biodiversity
Checklist, plus:
– HBIC screening of weekly planning lists
– Informal discussions with LPA ecologist
– Own assessments or thoughts from site visits or other
knowledge (e.g. neighbours, other nearby developments)

12. When?
• Bats
– Pre-1914 buildings with gable ends or slate roofs, regardless
of location (although many others!).
• Reptiles
– Brownfield sites, rough / bare ground, railways, allotments,
cemeteries etc
• Nesting birds
– Denser vegetation (hedges, brambles), older buildings,
garages etc

16. What?
• Remember the audience
– Planners
– General public (informed or uninformed)
– Natural England
– Wildlife Trust
– LPA ecologists
• It will be scrutinised
• It must be clear – time is a factor…

17. What?
• Every project is different
• Standard report-writing guides e.g. IEEM (2008).
Guidance for Ecological Report Writing. Professional
Guidance Series.
• Ultimately, needs to do the job it is supposed to do
• Tailor content to the project – dense report won’t be
read by a householder; brief report unlikely to be
sufficient for larger development.

18. What?
• Basic structure
– The brief
– Methodology
– Survey results
– Impact assessment / discussion / analysis
– Recommendations
• Basically, tell the story…

19. What?
• Project brief
– Why was the ecologist brought in?
– Has the applicant been advised if any other work needs
doing? Two-way process between consultant and applicant,
don’t assume that the client always knows what they need
– Does the ecologist have all the relevant detail? Up to date
plans, timescale, other constraints?
– Planners – is the survey relevant to the development?

20. What?
• Methodology (1)
– Desk study? HBIC / NBN / MAGIC / mapping / aerial
photos etc
– Standard methods? E.g. JNCC Phase 1; BCT survey
guidelines; Froglife reptile survey guidelines; NE GCN
survey guidelines
– Any deviation from these? – some are more rigid than
others, need more justification.
– Although guidelines are just that, they are based on sound
principles. E.g. Bats – we often don’t see dawn re-entry
surveys, when these can be particularly useful e.g. swarming
of young bats around entry points.

21. What?
• Methodology (2)
– Personnel / qualifications (don’t need full CV – just that
they are an ecologist, reassurance that they are, for example,
a licence holder for a particular species)
• Lots of ecology reports submitted by architects, pest controllers etc!
– Timing (time of year / time of day) – if outside optimum
survey periods, state why and if this would affect results
– Equipment used, with comments on constraints, suitability
e.g. different bat detectors

22. What?
• Methodology (3)
– Extent of survey – site / immediate surroundings / wider
landscape following links or networks
– Constraints e.g. access problems (GCN ponds)
– Weather conditions
– Numbers / locations of surveyors (is this sufficient? – could
you really have looked at all the access points with only one
person walking around the house?)

23. What?
• Results (1)
– Results NOT interpretation – e.g. we saw bats, NOT we
found a maternity roost. Save that for the discussion /
impact assessment
– Start from the beginning – describe the site in terms of what
is relevant, and its setting in the landscape (if relevant). Put
it in context. Don’t need it all, can include extra in
appendices e.g. NBN maps, HBIC data.
– Desk study results – International / national / local sites
– General surroundings e.g. adjacent to a wood; in a river
valley; surrounded by modern housing.

24. What?
• Results (2)
– If describing the site, make sure it is relevant to the survey.
E.g. if writing a bat survey report for a house, make sure the
house is properly described, don’t just say it is a house with a
pitched roof.
• What are the tiles?
• What other features are there?
• What is the condition?
• Occupation?
• Recently cleared?

25. What?
• Results (3)
– Fieldwork
– How best to present data? Lengthy text often not ideal –
this could be saved for the discussion.
– Tables / Photos / Maps – essential for Phase 1; Bat surveys
– maps and photos much better at showing things than just
text. Show access points, location of surveyors etc.; Reptile
surveys – location of refugia
– Consistent with other planning documents e.g. same
numbering or names for buildings

26. What?
• Discussion (1)
– What do the survey results tell you?
– Even if nothing was found – just as important. Very hard to
prove absence – importance of robust methods.
– Need for confidence and clarity so LPA is certain that any
decision is robust and defensible.
– Relate to surrounding habitats, linkages and landscape.
– Consider distance e.g. 7.5km Mottisfont Bats SAC; Brent
goose feeding areas near Solent SPAs
– Consideration of relevant law and planning policy

27. What?
• Discussion (2)
– Impact assessment – ties results in with the development
– Value of receptor / scale of impacts
– Construction / operational impacts
– Timescale of impacts
– Avoidance measures? Have these been considered?
– Mitigation – proportional to impacts
– Compensation
– Any residual impacts?

28. What?
• Discussion (3)
– Mitigation strategy
– Must be clear, unambiguous and able to be secured by the
LPA.
– Must be developed in full discussion with the applicant.
– Supported by plans, agreed with applicant
– ‘Will’ not ‘Could’
– Can build in flexibility where appropriate through well-
worded conditions
– Applicant must read the report!

29. What?
• Discussion (4)
– Enhancements
– Is in accordance with Paragraph 14 of PPS9 as well as
Section 40 of the Natural Environment and Rural
Communities (NERC) Act 2006
– ‘Every public authority must, in exercising its functions, have regard, so
far as is consistent with the proper exercise of those functions, to the
purpose of conserving biodiversity’. Section 40(3) also states that
‘conserving biodiversity includes, in relation to a living organism or type
of habitat, restoring or enhancing a population or habitat’.

30. What not?
• Unsubstantiated statements relating to biodiversity.
• Often included as a one-liner in Design and Access
statements. No context or confidence.
• For example…

31. What not?
A bat survey was carried out on the adjoining plot as part of their planning
process in 2008 and no evidence of bats was found on that site.

32. Key points to remember
• Does the report help the applicant?
• Are there unanswered questions?
• Can the conclusions be defended?