Our letter to DEFRA Secretary of State

Dear Secretary of State,

Norwich Western Link Road, Norfolk

Our attention has been brought to the letter written to you by a number of Norfolk MPs and PCCs on 2 April concerning Natural England’s publication of the Favourable Conservation Status report for Barbastelle Bats relating to the proposed Norwich Western Link Road. We think the letter contains an ill-advised and unfair attack on the dedicated work of Natural England specialists and the main contributor, a renowned expert in this species, and shows a misunderstanding of the way the report has been written, as well as the purpose of the report itself.

You will be aware that the production of Favourable Condition Status reports is a fundamental prerequisite for meeting the statutory obligations of the Conservation of Habitats and Species (Amendment) (EU Exit) Regulations 2019. In Natural England’s publication of June 2021 “Defining Favourable Conservation Status in England Natural England’s approach” (Evidence Information Note EIN062 EIN062 Edition 1 Defining Favourable Conservation Status in England.pdf) it stated:

Principle 2: A definition of favourable conservation status is based on the best available evidence on the ecology of the habitat or species. The definition of favourable conservation status should be based on ecological evidence as far as possible, recognising that the knowledge base is highly variable and usually incomplete. Pragmatic decisions based on best expert judgment, proxy values and rules of thumb may often be needed for a workable definition. Favourable conservation status definitions can be revised as ecological understanding advances.

The publication of the Favourable Conservation Status report for Barbastelle bats adheres to this principle. It is designed to set a benchmark for the species against which developments can be assessed.

In particular, the letter states several times that the guidance in the report is ‘arbitrary’. This is simply not the case and is a misunderstanding of the process for evaluating the conservation status of rare and poorly studied species. Barbastelle bats need specialist survey techniques to understand the population and the way they utilise habitats, beyond standard bat survey techniques more commonly practised. Their rarity, compounded by the lack of such specialist surveys, means that our knowledge of Barbastelle bats is limited. The Favourable Conservation report uses the best available evidence to estimate population size, range and status. This is not arbitrary, but in line with the principle outlined above.

Given that we have known for a very long time that Barbastelle bats are both exceptionally rare and threatened, it is no surprise that the best available evidence used in the report indicates that the UK population is in unfavourable conservation status.

Norfolk County Council itself published the Norfolk Biodiversity Action Plan for Barbastelle Bats in 2009 (Microsoft Word - Barbastelle _Final - 2 March 2009_ _2_.doc (norfolkbiodiversity.org) which stated both that species is one of the UK’s rarest mammals and that Norfolk is one of the strongholds for this species. Norfolk County Council’s plan stated that its low population density and slow population growth make it particularly vulnerable to factors such as:
  • Loss and fragmentation of a broad mosaic of habitats including ancient semi-natural woodland, mature species-rich hedgerows, ancient trees and wood pasture, invertebrate rich pasture land and sympathetically managed riparian habitats;
  • Loss, destruction and disturbance of roosts or potential roosts in buildings, trees and underground sites; and
  • A reduction in numbers of insect prey as a result of habitat simplification, stemming from factors such as insecticide use and intensive grazing.
Norfolk Wildlife Trust and many other nature conservation bodies and experts have warned Norfolk County Council many times that the Norwich Western Link proposal, which would be built through what we know to be one of the most important areas for Barbastelle bats in the UK, would be extremely damaging (eg 2022-08-17 Our Open Letter, in objection - Norfolk Wildlife Trust). We also wrote to the Secretary of State for Transport in October 2023 reiterating our concerns about the Government funding the proposal in the light of its damaging effects 2023-10-16 We raise concerns for funding - Norfolk Wildlife Trust. The proposal would go directly against Norfolk County Council’s stated aim in its own BAP plan to maintain the status of the population where it is known to exist.

The Bat Conservation Trust Barbastelle - UK Bats - Bat Conservation Trust states:
The barbastelle is very rare, only found in southern and central England and Wales. Very few breeding sites are currently known in the UK and it is important that surrounding environments of these and winter hibernation sites are maintained. It is thought that they prefer pastoral landscapes with deciduous woodland, wet meadows and water bodies, such as woodland streams and rivers.”

Norfolk County Council is very well aware that the part of the Wensum Valley affected by the road proposal exactly fits this description as it is a landscape rich in old growth deciduous woodland, wet meadows and water bodies, which makes this area of critical importance to the species both in Norfolk and the UK. As we have pointed out many times, merely redirecting the route to avoid individual roost trees does not mitigate the impact of this proposal because of the way the species uses the landscape.

We already know that attempts at mitigating the effect of the Norwich Northern Distributor Road on barbastelle populations through a single green bridge and other methods proven to be ineffective has already led to the decline of populations affected by the road and that proposals to repeat this mitigation method on the Norwich Western Link would also be doomed to failure.

We therefore urge you to recognise the validity and importance of Natural England’s evidence-based Favourable Conservation Status report and support them to deliver their specialist statutory role. We hope you agree that Natural England is the government’s adviser on nature and must be able to speak independently, bringing a considered position based on evidence.

We hope you will encourage Norfolk County Council and the MPs to work constructively and positively with Natural England, Norfolk Wildlife Trust and the many other conservation bodies concerned about the proposal to develop a solution which ensures the prosperity of our local communities in harmony with the area’s special wildlife.

Yours sincerely,
Eliot Lyne, Chief Executive, Norfolk Wildlife Trust
Beccy Speight, Chief Executive, Royal Society for the Protection of Birds
Craig Macadam, Conservation Director, Buglife
Dr Pam Taylor, Trustee, British Dragonfly Society
Anthony Robert Leech, Chairman Norfolk & Norwich Naturalists’ Society
Craig Bennett, Chief Executive, The Wildlife Trusts
Chris Dady, Chairman, CPRE The Countryside Charity (Norfolk)
Dr Geoff Brighty, Chair of Norfolk Rivers Trust
Jack Taylor, Programme Lead, Woods Under Threat Woodland Trust
Charlie J. Gardner PhD, FRSA, Associate Senior Lecturer at the Durrell Institute of Conservation and Ecology (University of Kent)