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This blog post was published under the 2015-2024 Conservative Administration

Bat licensing at Jones Hill Wood

Posted by: , Posted on: - Categories: Licensing

Image of 'Natural England' logo.

By Dave Slater, Natural England's Director for Wildlife Licensing and Enforcement cases.

On 30 March, Natural England issued a bat licence to HS2’s contractors for works at Jones Hill Wood, Buckinghamshire. I’m aware that some people are concerned about licensing works in this area, so I’d like to explain a bit more about our role in species licensing and our decision regarding Jones Hill Wood.

Natural England’s role in licensing development is to ensure that activities affecting protected species are carried out without damaging those populations. We don’t have powers to stop projects that have been approved, or to delay them unnecessarily, nor do we have powers to prevent the felling of ancient woodland if it has been approved by the planning system.

When a developer applies for a licence to undertake works that will impact on protected species, Natural England assesses whether the works can be carried out in a way that maintains the conservation of the species in that area. We take our regulatory role very seriously; all licences that are issued include conditions that the licensee must apply with. We monitor compliance with licence conditions and will take enforcement action if they are broken.

At Jones Hill Wood, we have undertaken a careful assessment of the impacts in this area and requested further hibernation surveys.  Our assessment has concluded that the felling of 0.7 hectares of woodland at Jones Hill Wood will not be detrimental to the favourable conservation of the overall bat populations in this area.

Our decision takes into account a number of elements including the areas over which bats forage and the wider available foraging resource, the proposed methodology for minimising harm to roosting bats, and the compensation measures that must be put in place, which include creating new roosting features, bat boxes and the planting of 3.2 hectares of woodland habitat and fruit trees on an adjacent site. The effect of these compensatory measures will be monitored over a period of many years. The licence also sets out measures that must be undertaken to ensure no bats are harmed during tree and vegetation clearance at the location. Some further details on impacts and compensation measures are included below.

We’ll continue to work both with HS2 and other concerned stakeholders during the works, and our staff will undertake a site visit during felling to ensure that licence conditions are being met.

Impacts and compensation at Jones Hill Wood

The works at Jones Hill Wood have the potential to affect the following species through the loss of breeding sites and resting places: damage or destruction of up to 4 common pipistrelle resting places and 1 breeding site, 1 soprano pipistrelle resting place, 1 barbastelle resting place and 1 breeding site, 1 noctule resting place, 2 brown long-eared bat resting places and 1 breeding site, and 1 Natterer's bat resting place. Works could also result in indirect disturbance of bats (if present) and the transport / possession / control / capture of bats.

The confirmed losses are:

  • 19 trees with potential roosting features as part of the removal of 0.7 ha of ancient woodland
  • one common pipistrelle roost
  • alteration to conditions of trees with potential roost features in the retained areas of the wood.

Impacts will be mitigated and compensated as follows:

To ensure that no bats are harmed during tree and vegetation clearance in this location, the licence confirms the following measures:

  • All pre-fell climbing surveys / felling works will be undertaken under the direct supervision of suitably qualified ecologists.
  • All felling activities will be supervised by the Named Ecologist or accredited agent, and all felling works, actions and bats encountered will be fully documented;
  • All the trees with suitability for roosting bats that are to be felled will firstly be climbed, potential roost features (PRFs) inspected and then only felled if all PRFs in each tree can be fully checked and bats are found to be absent from each PRF.
  • Any roosting bats found in any PRF through the pre-fell checks will be carefully removed and released in line with the required capture and release procedures.
  • If bats cannot be removed an emergence survey followed by dawn re-entry survey in suitable weather conditions will be undertaken in relation to the confirmed roost (using infrared (IR) cameras) to identify when bats have left the roost and not re-entered. This will be followed by tree climbing and soft blocking of the roost prior to felling. If tree climbing is not possible the tree must undergo a Destructive Search by Soft Felling.

To address the loss of foraging and roosting habitat in this location on bats, the following measures must be implemented as mitigation/compensation:

  • Provision of 24 replacement roost features (bat boxes, or natural roost features salvaged from trees which have been felled and then relocated).
  • All bat boxes will be erected under supervision of the Named Ecologist or accredited agent.
  • Planting of a further approximately 3.2 ha of woodland habitat and fruit trees on an adjacent site.
  • The placement of felled tree trunks (monoliths) within the ancient woodland receptor site.  At least x3 monoliths to be installed.
  • Enhancement of existing woodland edge through the creation of graded habitats, grassland and waterbodies.
  • New native-species rich hedgerows will be planted. Vegetation will be allowed to grow to the base of the hedgerows. Grassy margins allowed to develop alongside the hedgerows will provide increased invertebrate prey for bat species.
  • Post mitigation monitoring will comprise habitat assessments that will verify the successful establishment of new habitat creation and its suitability for bats long-term to determine the effectiveness of mitigation. Monitoring will also include bat box inspections, activity surveys, and static detector monitoring.

Common questions and answers:

Since the news of the licence being granted, Natural England have received correspondence and questions on social media on the licence at Jones Hill Wood. Please see more detail below:

Q: Does Natural England endorse the felling of ancient woodland?

A: Any loss of ancient woodland is significant and should be avoided.  The decision to progress HS2 taken by Government, and endorsed by Parliament, accepted some loss of ancient woodland. The planning system does allow for this in some exceptional circumstances as long as it is minimised and mitigation and compensation is in place. Following the decision to proceed with HS2, Natural England has been instrumental in ensuring this compensation and mitigation is workable and meaningful. We have continued to work closely with HS2 along the route to minimise impact as works commence on the ground.

Q: Is Natural England scrutinising HS2 fully when considering applications of wildlife licences?

A: We follow the same principles for all developments. Decisions on license applications often require an assessment of highly complex data, in which survey information on protected species is rarely complete.  Our staff frequently need to make finely balanced decisions using professional judgement based on their expert knowledge of the species in question. Because the circumstances of each development is unique, we have some flexibility in determining the level of survey information that is necessary to understand the impacts of works. We are required under the regulations to take account of the impact and cost of delays to works, when considering if further surveys are needed to provide sufficient certainty that the conservation status of a species can be maintained.  Such decisions are made wholly independently of the wants of developers or any other interested parties.

Q: Can we prove that the mitigation in place will properly minimise impacts and that the compensation will replace lost habitat?

A: The mitigation measures and compensation provided in the text above are widely established in ecological practice. Natural England staff are confident in their assessment that these measures provide adequate compensation to maintain the conservation status of bats impacted by works at Jones Hill Wood. In this assessment we take account of the fact that bats are known to use multiple roosts at different times of the year and that barbastelles for example may use several maternity roosts, each for a few days at a time. The loss of one roost feature within a network of woodlands is considered in this context. It is HS2’s responsibility to ensure these measures are implemented properly, and we will monitor and take action as needed to ensure compliance.

Q: Has this licence been challenged in the courts?

A legal challenge to the granting of the Jones Hill Wood bat licence was made on 12 April 2021.  On 16 April, the High Court issued an injunction to stop works at the woodland pending consideration of a Judicial Review of the circumstances in which the licence was granted.

Q: What was the outcome of the legal challenge?

On 23 April a hearing took place to decide a) whether permission should be granted for a substantive hearing for Natural England’s licence and b) whether the injunction should stay in place until that hearing. On 27 April the case for a Judicial Review was found to be ‘not arguable’ by the High Court and therefore permission for a full Judicial Review was denied.  The suspension of the licence was also reversed.

Q: What did the judgement say?

The judgment from the hearing of 23 April can be viewed at this link. Natural England is satisfied that, following a full day’s hearing, the Court agreed that our assessment of the licence application was undertaken in an appropriate manner and that our decision to grant the licence was in accordance with relevant legislation.

Q: What is happening at Jones Hill Wood as a result of the court’s decision?

As of 27 April, the licence granted to HS2 contractors can be used to permit works affecting certain species of bats. Natural England understands and sympathises with those who are concerned at the felling of woodland and the impact on protected species. As explained elsewhere on this blog, the licence clearly sets out the conditions under which these works are to be carried out, so that they will not be detrimental to bat populations. Our staff will continue to monitor the use of this licence to ensure that these conditions are adhered to.

Q: How will the licence holders compensate for ecological losses made in the area?

The compensation measures that must be put in place include creating new roosting features, bat boxes and the planting of 3.2 hectares of woodland habitat and fruit trees on an adjacent site.

Some further details on impacts and compensation measures are included above.

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  1. Comment by April Boardman posted on

    How can we be sure these conditions will be properly adhered to by HS2 contractors? They have shown little regard for wildlife or indeed human residents since starting their work. Are the ecologists checking the area Independent or are they contracted by HS2?
    Planting trees will not make up for loss of established trees for many years either.

  2. Comment by Amanda Gazidis. posted on

    I am deeply upset and shocked that you are issuing a licence for the felling of Jones Hill Wood and the unique ecosystem there. This is an ancient Woodland which has trees upto around 350 years old and the presence of rare species.
    This is the inspiration for Fantastic Mr Fox and a site that should be preserved for future generations to enjoy, it is a part of our history. It is tragic that HS2 is ploughing through it when the route could be diverted. I am heartbroken about your decision on so many levels,

    Amanda Gazidis.

  3. Comment by Veronica Potts posted on

    Tony Juniper
    I understand you have given permission for HS2 to destroy part of Jones Hill Wood. I think the name Natural England is a complete misnomer. To take this decision at all is reprehensible but this is the height of the nesting season. You are a puppet organisation for the worst excesses of this government, nothing more. Shame on you.

  4. Comment by Jill eyers posted on

    Yes you make up very good ‘rules’ which if HS2 followed them would maybe have been better for protection of species affected or killed outright in these works. But now they have blatantly broken most of these ‘rules’ and have not trained their ecologists or tree felling personnel to an adequately competent level - then what will you do now?
    I can guess what you will do - nothing. Over many years I have been very dismayed in the incompetence of NE. Your organisation is full of words, has many meeting, even more guidelines and reports BUT does absolutely nothing to those trashing our wildlife and habitats in an illegal way. Shame on you. NE is unfit for purpose.

  5. Comment by Graham Adams posted on

    Powerless and pointless, laws for some , but not for others.
    Nature pays heavily every time and our land disappears for ever,
    Apologies to future generations.
    They will not thank us.
    What a farce.

  6. Comment by Paul Bigland posted on

    Thanks for posting this, it's factual and informative and puts the nonsense spread by those opposed to HS2 into perspective.

  7. Comment by Frances Robinson posted on

    Re bat licence for HS2 at Jones Hill Wood. How you "say" you will expect it to be done in this way?
    "We’ll continue to work both with HS2 and other concerned stakeholders during the works, and our staff will undertake a site visit during felling to ensure that licence conditions are being met.

    We monitor compliance with licence conditions and will take enforcement action if they are broken."

    "Our staff will undertake "A" site visit "
    NOT GOOD ENOUGH SHOULD BE DAILY AT LEAST? Meanwhile when they not constantly monitored, they break all the rules.
    Am reporting your incompetence to DEFRA.

  8. Comment by Thelma watson posted on

    What is your use? Are you also taking cash from HS2?
    Please do come to visit us and see what HS2 have done to our once natural and peaceful village.

  9. Comment by Jonathan Wheeler posted on

    What even is the point of Natural England anymore? You simply won’t stand up and protect our countryside. I know your budgets have been slashed year on year, but that’s no excuse for your obvious lack of moral backbone.

    The whole organisation should be shut down, because otherwise it’s just going to be used as a mask behind which developers can hide. “National England has approved our work.”


  10. Comment by Mary Sargeant posted on

    The conditions to be followed look as if Natural England has made some sort of effort to put in place conditions to provide some level of protection for bats. Unfortunately there is absolutely no way for any scrutiny to show visual evidence that the recommendations are carried out within a time limit that will make these measures ACTUALlY protective of bats. Experience shows that felling teams at HS2 do not carry out most of the recommendations of Natural England. There is no visual evidence to prove or disprove their compliance with these recommendations and no sanctions applied to them if they fail to comply. Natural England pays lip service only, to caring for England’s natural world. They appear to be an organisation created to provide greenwash for rapacious and exploitative companies carrying out various types of destruction to the natural environment in order to create profit of the financial kind while creating loss of the natural environment kind!

  11. Comment by Roisin Bennett posted on

    Not impressed at all. You should not be allowing any felling during nesting season. Seems to me that HS2 can do what they like. Do you monitor all sites ? personally I don't think you do.

    Very sad that you are allowing all this devastation to continue.

  12. Comment by christine paterson posted on

    Unless you provide the Ecologist and someone you trust to be present during felling - all your advice will be ignored.... and much suffering will occur. It's a shame that you haven't seen the footage taken of HS2 ecologists in action

  13. Comment by Sylvia watson posted on

    Barbastelle bats are very rare! They cannot live in a bat box or a left over bit of tree that has been salvaged , they need ancient woodland , I am horrified by your plan to destroy such rare bat roosts , terrible decision to grant bat licence

  14. Comment by Maria Bagnoli posted on

    All that work for a train that no one wants.
    Even the most empty headed soul would know the obvious alternative would be to find another route instead of moving mountains to accommodate this wasteful project.
    Natural England are working to protect HS2 not the other way round.
    Every one knows you can't replace one habitat with an artificial one.
    It's shameful .
    You have no morals or accountability.
    We are in the worst bio diversity crisis of all time.

  15. Comment by Chris Gannaway posted on

    In the real world mitigation measures take significant time to bed in therfore there is no guarantee that they will work. The licence therfore has no real benifit for the protected species and is just a paper exercise.

  16. Comment by Val Saunders posted on

    When ecologists are employed by HS2 and mainly refuse to discuss with tree protectors is it any wonder people feel betrayed by HS2?! There should always be an independent body supervising or carrying out the work especially when so much of our precious woodland is at stake!!!

  17. Comment by Lorna Hill posted on

    You are not protecting our land and wildlife as you should - you know that. Just another example of the greed driven agenda. You do not seem to exist to preserve but rather to protect those destroying our natural england.

  18. Comment by Helen posted on

    This just isnt good enough - Natural England should have the interests of nature as its priority which clearly isnt the case here. HS2 do not respect the creatures living in the areas it is destroying and need to be held to account for their behaviour. You cant destroy habitat and claim it wont have any impact on the creatures living there. You cant cut down ancient woodland and simply replace it with new saplings elsewhere. It takes years for trees to grow - so it would take 50yrs for us to get the benefits from the new trees compared to what the ancient woodlands offer us now. There is a climate emergency (as declared by the govt) we need to protect wildlife, their habitat and our trees. We need impartial advisors - not those influenced by those in power who have financial interests.

  19. Comment by Fiona Quick posted on

    All that is mentioned here is bats. What about hedgehogs (some are still deep in hibernation and cannot run) and nesting birds?

  20. Comment by Gemma Rogers posted on

    No amount of mitigation can make up for the loss of these woodlands. HS2 are hired thugs I have watched them gloating about cutting woodland with my own eyes.

  21. Comment by Marian Hoffman posted on

    Unanswered questions: How can the planting of "woodland habitat and fruit trees" nearby help displaced bats and other wildlife now? I've seen a photo of the rows and rows of saplings. It will be several years before they're any use.
    I have seen HS2 workers in action and find it difficult to imagine them behaving with the care prescribed above.
    At what point of the disobeying of the terms of the licence will anything be done to sanction and control HS2 Ltd and by whom?
    It is probably too late now to save Jones Hill Wood, but similar and worse catastrophes will be visited on many ancient woodlands, hundreds of nature reserves Sites of Special Scientific Interest and wildlife sites all along the line.

  22. Comment by sian lloyd posted on

    This is just awful. Despite the fact that ancient woodland is our most valuable resource Natural England are now complicit in its destruction, And the mitigation plans are a joke. Planting samplings in plantations does NOTHING for the bats now. By the time they have matured - if the survive there will be no bats. there will be no wildlife. there will be no nature. this is a travesty of epic proportions and natural England are just standing by.

  23. Comment by Jeanette Moore posted on

    Call yourselves Natural England it’s disgusting and giving licences to act out these atrocities against our wildlife and countryside/woodland is a disgrace, SHAME ON YOU!!!

  24. Comment by Jacob lane posted on

    Dear natural england

    You are a disgrace

    Yours sincerely

    Jacob Lane

  25. Comment by Chris Hanlon posted on

    You should all resign, you clearly don't like nature to be supporting HS2. Ecological and Environmental destruction on an industrial scale, how do you sleep at night.

  26. Comment by Patricia Mallett posted on

    Natural England should be renamed "No Ethics when it comes to preserving wildife". Letting HS2 shine bright lights to remove bats, and then letting them cut down Jones Hill Wood despite rare bats living in it, is a national disgrace.
    Natural England granted a licence allowing the loss of multiple bat roosts and the loss of breeding sites for three bat species. The mitigation and compensation they require from HS2 is to put up a few bat boxes.
    Shame on Natural England.

  27. Comment by Pip Evans posted on

    I would like to add my voice to those who fear that HS2 contractors are not being adequately scrutinized at this site. The fact that contractors are seen climbing trees, removing objects and concealing these in black bin bags is outrageously concerning. What were they doing and where is Natural England at this as point? HS2 must be held accountable for every life destroyed or we will be living in an Unnatural England. Please please step up and be more vigilant. Our future depends on wildlife being saved at all costs.

  28. Comment by Charles Liggett posted on

    What is the expertise of the people who designed the mitigation measures? What experience do they have with bats and, more precisely, with the species in question? There are so many non-sequitors in the supposed justification that it is difficult to know where to start. Natural England has lost all credibility with all those who depend on it to protect our rapidly depleting nature resources. I am in total despair.

  29. Comment by Dom Walker posted on

    I am beginning to think Natural England is a misnomer?
    You appear to have lost sight of your role in protecting our countryside, certainly if Buckinghamshire and your complete lack of backbone when it comes to HS2 is anything to go by.

    You are letting this company walk all over you and our countryside in their size 9's. Get a grip of this woefully inept situation please.
    Thanks Dom Walker of Aston Clinton

  30. Comment by M Gomez posted on


  31. Comment by Trisha Powell posted on

    Do you really expect me to believe that planting 3.2 hectares of saplings will replace the total destruction of huge areas of ANCIENT WOODLAND AND WILDLIFE habitat!. the clue is in the word Ancient. 300 year old Oaks have been destroyed! How can you justify that? Trees with nesting birds destroyed. the list goes on and on. I am devestated by the destruction of so much of our precious Woodland especially at a time of environmental awareness of the effects of Global Warming. All this to save 20 minutes on a train journey that few will use because of Working from Homeor who could afford the fare,This HS2 is a travesty of justice and a waste of Millions of pounds that is Needed elsewhere.

  32. Comment by M McGrath posted on

    How can you say you are independent of all interested parties when you are a part of government, the same government that it pushing forward with HS2 despite evidence of its environmental damage and negative climate impact.

  33. Comment by Leean Young posted on

    It is quite shocking and unbelievable what is taking place with HS2. I am having works done to my house and have to put bath boxes surrounding the property, take tiles off one by one and not move any existing trees. I have no problem with any of this but I do have a problem with the fact that these rules do not apply to the HS2 project. The destruction to bats and the larger habitat is shocking and I fail to understand how these decisions have come to be.
    Clearly money and power mean more than the environment to natural England. It is very sad to witness and the impact on future generations of wildlife is criminal.