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27 March 2014
In response to feedback from consultants, including the team at ECOSA, Natural England (NE) have revised the EPSM (European Protected Species Mitigation) licensing process regarding bats.
As part of the introduction of annexed bat licences, Natural England aim to reduce the time taken to award licences by contacting the consulting ecologist directly for any clarification needed, rather than always triggering a formal Further Information Request (FIR) procedure which invariably causes to delays to the granting of licences and works on site. Instead, a simple telephone call to the named ecologist which, with ECOSA's simple team structure, can be taken by a nominated second should your Project Manager be unavailable, can be followed by an email confirmation process.
Natural England warn that FIRs will still be used for "poor quality applications" which will still require a complete resubmission of the licence application and up to 30 days for the application to be considered. However, at ECOSA, our in-house experience is of FIRs being used to challenge applications on finer details of method or development plans, as part of Natural England's due diligence process. It will be very much to the advantage of our clients that we have the opportunity to clear such matters with a brief conversation with the team at NE with any small revisions to proposals confirmed by email.
The annex referred to is a supplement to the EPSM licence issued. It contains the detail of the licence granted including numbers and species of the bats that may be affected by the planned works, timings of scheduled works, actions to be taken to minimise disturbance and habitat mitigation solutions to be installed. It is understood that this succinct presentation of the parameters of the licence will be of particular value for the efficiency of any necessary revisions to the licence. Only those details of the original licence application that have changed will need to resubmitted.
The team at ECOSA welcome the changes brought in by Natural England. We are confident that our clients will benefit from the greater efficiency in application processing. It is also hoped that the higher standard of submission demanded by the revised process and the explicit detail of the 'annex' will result in licences which are more easily enforced and therefore better serve appropriate wildlife protection.
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