DBDUC Greater Horseshoe Bat Report


Development pressures and Greater Horseshoe Bats in the South Devon SAC. Can they survive?

A discussion paper produced by Don’t Bury Dartington Under Concrete (DBDUC)

20thApril  2018


This paper has been produced and collated to aid understanding of the issues facing the survival and conservation of Greater Horseshoe Bats in South Devon; an area subject in recent years to fierce development pressure. It explores the complex habitat requirements of the species, legislation and policies that exist to protect them and questions how these have been applied to recent planning applications in the area. Finally it questions how, with The South and West Devon Joint Local Plan to expand settlements 2014-2034, Greater Horseshoe Bats may be affected and whether their future can be assured.  And whether by converse, the proposed JLP could be considered sound with the potential adverse impact on the important habitat of a protected species.

In part of this paper, a special focus is given to Dartington due to its geographical location in proximity to the 5 SSSIs (Sites of Special and scientific Interest) that comprise the South Hams SAC (Special Area of Conservation) and the proposals within the draft JLP that would increase the housing by 504 houses; a 63% increase in the village in just 20 years. To accompany this paper, a spreadsheet document with the collated results of an investigation into some recent planning applications and associated status in Dartington indicate that LPA planning decisions being made are failing to protect the species. Further permissions for development planning that could impact on this important area for the Greater Horseshoe Bats are therefore cast into doubt on whether adequate impartial professional consideration would be given to this species.


Britain’s largest and rarest bat

The Greater Horseshoe Bat,  Rhinolophus ferrumequinum- a name that reflects the presence of a complex horseshoe-shaped nose leaf which is related to their particular type of echolocation system, are Britain’s largest and rarest bats. They are listed in the UK Biodiversity Action plan and are one of the rarest mammals in the UK. They are long lived and at 17-35g with a wingspan of 350-400mm, they are a striking sight seen flying across the night sky.

The total population in Britain is approximately just 5500 individuals, which are confined to South West England and South West Wales.   A significant proportion, around 2000 individuals are found in South Devon. The Bulkamore maternity roost is considered to be the largest in Europe.

GHBs have a large home range and a complex set of habitat requirements. Unfortunately, their populations have declined by over 90% over the last 100 years. Estimates vary but the Vincent Wildlife Trust (2014) estimate there may be only 3% of the 20thcentury population left. The survival of this species in Britain  demands that all the elements required for feeding, roosting, breeding and travelling in the area  remain stable and able to support and nurture populations. High quality foraging habitats are essential for their survival (Duverge’ and Jones 1994). Understanding, recognising and taking action to ensure that sufficient habitat requirements for all stages of GHBs life cycle is crucial.

Greater Horeshoe Bats have Complex Habitat Requirements

Greater Horseshoe Bats use a network of dark roosts, foraging habitats and commuting routes. Features must be dark as greater horseshoe bats are normally extremely sensitive to increased light levels.

Roosts: A variety of structures are used throughout the year for hibernating, raising young bats (maternity roosts), feeding, mating and resting.  Large numbers of bats will be found in maternity and hibernation roosts and these will be used by generation after generation as these long lived bats stay faithful to the same roosts over time. Less obvious are the roosts used by individuals or smaller numbers of GHBs; some as stopover roosts in summer, when they range further afield and it is believed travel further to neighbouring roosts or foraging areas to mix and cross breed. In summer, GHB’s can travel 12km or more, so interbreeding between all the South Devon colonies is likely and will ensure essential mixing of the gene pool.

Foraging Habitat:GHBs feed in different habitats during the year as availability of prey changes.  Foraging habitats include cattle grazed pastures, the edges of broadleaved woodland, stream corridors, wetlands, tree lines and tall, thick hedges feeding on such prey as moths, dung beetles, cockchafer beetles, dung flies, crane flies, parasitic wasps and caddis flies.  Juveniles may only forage within 1km of the roost and are dependent on cattle grazed pasture that attracts dung beetles.

Commuting Routes:These are linear features which bats follow when moving around the landscape between roosts and between roosts and foraging habitat. GHBs have a weak echolocation call (which bats use to navigate) and therefore generally fly close to the ground (up to 2m) and close to linear landscape features such as hedges, woodland edge and vegetated watercourses which they use for navigation. An easy and visible prey to owls and other predators, GHBs need protection from open skies where they are less visible and likely to be picked off too.  They are extremely light sensitive and require dark areas over which to fly. Wildlife experts have argued that the sudden addition of lights to a GHB’s flyzone can disorientate and shock individuals so much that they die.

Legislation to protect GHB’s

GHBs are strictly protected by both European law and UK law.

They are protected under Schedule 2 of The Conservation of Habitats and Species Regulations 2017, which updates the 2010 Act. This is known as the ‘Habitats Regulations’.  GHBs are a European Protected Species (EPS), which means that anyone wishing to disturb GHBs or their known habitat must obtain an EPS licence from Natural England.  This legislation also states the requirement to conserve linear features in the wider countryside; a key feature in the ecology of GHBs.

Under UK law, GHBs are also protected under Schedule 5 of the Wildlife and Countryside Act 1981 (as amended), which prohibits killing, taking and disturbance of this species.

Their extensive and complex habitat should be safeguarded by the designation of Special Areas of Conservation (SACs) which are designated under the Habitats Regulations (See below).

In addition, the Directive on the Conservation of Natural Habitats and Wild Flora and Fauna (1992) 92/43/EEC is outlined in Article 2(2) and requires Member States to ensure that:

‘Measures taken pursuant to this Directive shall be designed to maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest’.Favourable Conservation Status for species is defined in general terms in Article theHabitats Directive as

‘Conservation status of a species means the sum of the influences acting on the species concerned  that may affect the long-term distribution and abundance of its populations within the territory referred to in Article 2. The conservation status will be taken as ‘favourable’ when:

  1. Population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats, and
  2. The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and
  3. There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.’

In this study, we question whether the extent of development in and around Dartington will severely compromise the Favourable Conservation Status of GHBs in the area.


Special Areas of Conservation (SACs)

Because GHBs are so endangered and vulnerable to any changes or losses in the roosting, sustenance, flyways and the areas between colonies that allow mixing and interbreeding, not only are they protected by stringent legislation, but the habitat of GHBs is protected by SACs, Special areas of Conservation. These designated areas have legal protection equivalent to SSSIs, ANOBs and National Parks.  The designated areas are to protect the bats, other wildlife and the natural fauna including their food network sustenance zone within a 4km diameter radius of underground roost sites.  SACs are designated by the European Commission as part of the European Habitat Directive Program. Changes to their remit or size can only be finally approved at a European level.


Who administers the SACs?

Natural England, part of DEFRA is given the responsibility to protect the SAC zones- including the South Devon SACs.  English Nature is entrusted with these responsibilities from the JNCC (Joint National Conservation), a government advisory panel on behalf of the European Commission to uphold UK and European wildlife laws.


The South Hams SACs

There are five major roost sites with a 4km SAC around them, close to Dartington. The established hibernating roost sites at Bulkamore and Buckfastleigh are two of the most important sites in the country.  The summer roost sites in Berry Head are also critically important to the survival of Greater Horseshoe Bats in the UK.

These SAC sites are also exceptionally good habitats and resting places for many other nationally threatened and European Protected Species such as Lesser Horseshoe Bats and Dormice, so they are also of national importance.

The natural, undeveloped corridors in between SACs are also essential to the survival of these species in the UK. They provide access to extended habitats but are critical to the interrelationship and breeding of colonies. Until these interrelationships are fully understood, development or urbanisation in these areas could have a catastrophic effect on the Greater Horseshoe Bats and other protected species.

From April 2018, the Supplementary Planning Document (SPD) that guides planning decisions and advises planners and developers regarding development in the South Hams SAC and surrounding area is being revised. The draft SPD is out for consultation until 30th May 2018. This 2018 consultation document states:

‘Sustenance Zones are the area within 4km of designated maternity and hibernation roosts which include critical foraging habitat and commuting routes for bats using the roosts.  The SSSI/SAC roosts and the Sustenance Zones are strategically important in maintaining the population of greater horseshoe bats across the South Hams.’

Also that

 ‘Development within, or in close proximity to these sites could therefore have a Likely Significant Effect on the integrity of the South Hams SAC. Even small-scale changes to the landscape have the potential to affect the integrity of the SAC and, therefore, screening will be required for any plan or project which impacts on greater horseshoe bat habitat or flight lines in a Sustenance Zone.’


How protection works in practice.

When a developer submits a planning application, he should first have the site surveyed by a competent ecologist. Initial meetings with planners should inform him that the site is within the SAC or is otherwise potentially a valuable habitat. Ecological consultants should adhere to guidelines set out by the Natural England and SPD, but they are not independent. They are briefed and paid for by developers- so the onus is on the LPA’s ecologist to ensure that the correct surveys are undertaken and the reports are sound. Being in the SAC, or having other European Protected Species on the site, demands that Habitat Regulations Assessments (HRAs) are carried out. For GHBs this includes bat monitoring for at least 50 days over one summer season.  The SPD gives a flow chart that shows clearly when rigorous GHB surveys will be required.

When planning applications are submitted, the LPA ecologist examines the wildlife reports. For any site in the SAC, the developer must demonstrate that HRA surveys have been undertaken. Because GHBs are found in low numbers and use large areas extensively, detailed and long term monitoring is needed to pick up their use of a site. As Statutory Consultees, Natural England are asked to comment, however for almost all sites both within the SAC and elsewhere, NE simply offer ‘standing advice’ and no specific comments. This is probably due to the overwhelming number of planning applications sent. NE leaves almost all the responsibility with the LPA ecologist to ensure that the site has been correctly surveyed.

The presence of GHBs and a host of other protected species; including all bats and dormice should trigger the developer to apply for a European Protected Species (EPS) licence, to be issued by NE to a qualified ecologist- before any works to the habitats commences. In practice, developers’ ecologists often state that if an EPS is found on site during works to develop it, they will seek an EPS then. Given the cost of stopping work and potentially the loss of ability to build, this seems to be putting the fox in charge of the hen house!

Recent experiences on sites where concerns have been raised about clearance of habitats where EPS are known to be present, have resulted in no enforcement action from NE, who do not act as a ‘policing body’. In such cases, NE have explained that they will only enforce against damage to species or habitats where site workers are breaking the conditions of their EPS licence (ref- pers. comm. NE advisors Oct 2017, re works to clear recognised bat and dormice habitat at Brimhay, Dartington). If they do not have one to work on the site and unless a Police officer sees workers harming protected birds or animals, then NE will not take action to enforce a developer to obtain a licence or stop work.

Given increasing pressures on the LPA, diminishing funds and a strong agenda to meet government targets for new housing, both planners and the LPA ecologist are under pressure to deal with the volume of work, but also to approve planning applications if at all possible. Recent high staff turnover has also meant that planning applications are often being dealt with by a succession of planners who have to grasp all the issues pertaining to the site in a short period of time.

When other agencies (such as the Local Enterprise Partnership) who have different priorities are involved in setting housing numbers and growth areas, long term plans can be set to fulfil the aims of government, economic growth and efficient transport first, leaving nature to fit around them. The GHBs are the last to be considered.


Conservation and management for GHBs.

For over twenty years, the importance of this area in supporting the GHB population has been recognised. A Greater Horseshoe Bat Project has been established since 1998 and advisers have been employed to raise awareness and offer Countryside Stewardship payments to farmers and landowners to manage the habitat to provide good conditions for GHBs. These include payments for less intensive cattle grazing and not spraying the land with insecticides.

Education campaigns have spread the word about the value of GHBs in the area and enlisted the help and expertise of enthusiasts from wildlife groups to gather information. Together habitat management, education and monitoring are part of a SIP- a Site Improvement Plan for the species.

Offering the use of bat monitors and training volunteers to use them, has been a successful citizen science exercise in monitoring and mapping the GHBs to increase knowledge of how they use the area. A note of caution however- that increased numbers of GHBs may sometimes reflect the huge increase in recording and is difficult to compare with the much sparser data collected before the project.

Whilst partnership working across organisations is usually to be applauded, in the case of bat conservation, it may limit the effectiveness of protection and mean that funding comes with strings.  The Devon Local Nature Partnership (DLNP) includes conservation organisations, local authority staff and developers working collaboratively. Whilst this can have positive effects in informing developers of their responsibilities to nature and in maximising staff and other resources, the Partnership also offers funding to projects including the Greater Horeshoe Bat Project and its recent survey programme.  Devon Nature Partnership was established in 2012 under the Local Enterprise Partnership. Interestingly, the DNLP has been involved in redrafting the Supplementary Planning Document on GHBs, which we understand loosens some of the constraints on development in the SAC. We shall be publishing our comments on the SPD consultation document later in May.  We also understand that surveys undertaken by the public using GHB Project monitors cannot be used as evidence of GHBs that would limit development and participants have to sign an agreement to this before taking part.

Why Dartington is a critical location for survival of South Devon’s GHBs.

We have chosen to focus on Dartington as our case study area because it a critically important area for the survival of GHBs, yet it is also under considerable pressure from development. Dartington offers:

  1. A concentration of roosts.Data collected by the Devon Bat Group over 15 years from 1995 to 2010, shows the high level of bat activity for many species of bats, including GHBs in Dartington. Collating all the records taken over 1km tetrad squares centred on Dartington village, GHB roosts or hibernation sites can be found in 14 out of a total 36 tetrads that cover a 6km x 6km square centred on the village. This dense concentration of roosts that also indicates a criss-crossing of bat flights and activity over Dartington as bats forage and feed in the areas between.
  2. Dartington is close to some of the biggest roost sites in Europe.Local caves provide ideal, stable and safe hibernation roosts and the disused mine at Bulkamore is the largest maternity roost in Europe.
  3. The rich pastures between the roost sites and river offer quality foraging areas.Many are unsprayed and grazed with cattle, the dung of which attract the cockchafer and other beetles sought by GHBs. Recent changes in local farm economies e.g. the loss of Dartington Estate’s dairy herd and replacement with sheep and goats, will reduce the quality of GHB habitat.
  4. The network of until recently, quiet thickly hedged lanes and fields, river and corridors of woodland offer ideal flyzones.Dark and sheltered from predators, they allow the bats to travel between the different roosts, forage areas and other nearby colonies.
  5. Hemmed in roads and urban areas, these linear routes can be pinch points,so are therefore vulnerable. The pinch points in this South Hams area funnel the GHBs through Dartington and beyond.
  6. Dartington is en route to the major roost at Berry Head.. Evidence shows that GHBs can and do fly much further in summer- over 30km flights have been recorded (Bat Conservation Trust, web page 2010).But this flight is not random, it is likely they are flying further to mix and breed with other colonies. With only a few continuously tree lined, dark corridors between the colonies, any developments that fragment the available routes threaten the population’s viability and ultimate survival.

See Appendix 2 for maps illustrating the SAC’s and flyzones and shortest routeways between colonies.


Development- the greatest threat to GHBs in Dartington

In the last five years development pressures in Dartington have escalated. This is largely because local landowners have offered up large acreages under the South Hams Land Availability Assessments (SHLAA) process. It is a ‘call for sites’ from landowners to designate land for development in local plans.

The offer of large acreages of green field sites in Dartington by The Dartington Hall Trust has skewed the allocation of housing within the Joint Local Plan under the South Hams Land Availability Assessments (SHLAA) process. It is a ‘call for sites’ from landowners to designate land for development in local plans. In practice, this means that Dartington will take 55% of ALL housing that has been allocated across the JLP’s designated ‘thriving villages’ for South and West Devon.   By offering large, mostly green field sites for the development of 504 new houses, the village could be set to grow rapidly over the next 20 years

 A predicted increase of 63% in housing plus one large and two smaller employment sites in Dartington parish, the threat of suburbanisation, with the attendant traffic increases and infrastructure additions required, threatens significant disturbance and loss of flyways, foraging zones and summer roosts.In Dartington, excessive development overshadows the very positive conservation initiatives achieved by the GHB and other projects.

This excessive, uneven allocation would seem completely contrary to the legal protection, policies and conservation aims for endangered GHBs. We strongly question the soundness of the JLP in allocating numbers that will almost certainly lead to serious losses of GHBs and their habitat requirements.

In addition, little account is being taken of development between the South Hams and Torbay SACs although the importance of this connecting habitat (shown as adjacent landscape areas on the 2018 SPD consultation paper) is acknowledged. With large areas of development in Paignton and between Paignton and Brixham, there will be more pressure on the Berry Head colony and its interaction with other SACs will be threatened. These bats have less choice of routes between the colonies, being hemmed in by the sea on one side.

Whilst development comes under planning controls that should demand consultation, proper bat surveys and some mitigation for approved developments, the accompanying infrastructure does not. Dartington has already experienced huge traffic increases, an increase in school size, increased parking areas to cope with additional use of facilities, a new mobile phone mast beside the A385 and new lighting around buildings and roadways. All these changes will have a real impact upon GHBs in addition to the actual housing and employment developments.

Light pollution is a particular threat as GHBs are extremely sensitive to light. More houses and more road traffic at night leads to more overall light pollution and more lit areas. Increased housing leads to a need for increased recreational provision. Of particular concern are the floodlit pitches by the River Dart near Totnes. Proposals to provide a Multi Use Games Area that would be lit after dark and to construct a BMX bike track beside the Bidwell Brook; both in a flyzone, will also greatly impact upon a major dark and undisturbed route for GHBs.  Any new developments in dark areas e.g. Broom Park, Woodlands Yard and Beacon Park will mean yet more areas that GHBs will have to avoid and can’t travel through. The maps show this rapid change in light pollution over the area (See Appendix 1).

It is also known that several places in Dartington are crucial to ensuring GHBs can travel through the habitat. They are identified as ‘pinch points’ in both the 2010 and 2018 draft of the SPD.  These are being put under increasing pressure- particularly with developments built or proposed at The Plantation, Meadowside and Brimhay.

As well as sheer loss of habitat and disturbance, development places stress upon the adjoining countryside and its wildlife. Hedgerows and open spaces close to housing and roads often become more ‘manicured’. (Duverge’ and Jones 2003)  argue that hedgerows within the SAC should be at least 4m high and 2-3 m wide and not intensively trimmed, to provide good cover for GHBs.  However in recent years many of the hedgerows lining the lanes and roads of Dartington have been severely flail trimmed with low flat tops, instead of being left a tall ‘A’ shape which promotes healthy growth, as recommended by the Farming and Wildlife Advisory Group.


GHB Protection in Practice: an Overview of planning applications in Dartington.

Government planning advice makes it clear that the LPA are responsible for ensuring that developments do not harm GHBs or their habitat;

‘When determining planning applications, LPAs have a legal duty to ensure that there will be no adverse effects on the South Hams SAC population of greater horseshoe bats. Any application which will have an adverse effect will be refused, other than in exceptional circumstances….. If there is any potential for a development to have a likely significant effect on the SAC’s population of greater horseshoes, the LPA must carry out an assessment known as a Habitats Regulations Assessment (HRA)’. (From SPD Consultation document 2018. The advice is similar to the 2010 SPD).

Furthermore, the NPPF gives planners a clear duty to ensure that developments not only conserve but improve habitats and leave further potential for their improvement; meaning that developments should have a net gain for wildlife, not a loss.

To examine how protection of GHBs in the SAC works on the ground, we looked at many of the planning applications in progress and granted, plus the sites allocated in the Joint Local Plan (2014-34), a total of 19 sites, to gather an overview of how the policies and laws are applied (see Appendix 3).We examined the ecologists’ surveys provided and the result of the application. None were refused on wildlifegrounds.  Whilst the list is not exhaustive, it covers most significant recent and proposed sites and offers an insight into the application of advice, surveys and policy on sites of varying sizes. The table can be found in the appendix.

Even a first look at the table shows a pattern of inadequate surveys being allowed, minimal mitigation accepted and a lack of rigour in applying the policy and guidance that in many cases implies a breach of wildlife law. Green field sites that are developed can rarely offer the enhancements proffered by the NPPF and the additional needs of the site in question for improved roads, lighting and facilities for larger developments affect a far larger area than that actual site and the effects on wildlife beyond the site boundary are rarely considered.

Shockingly, almost all of the planning applications examined did not undertake to survey the sites to HRA standards. They fail NE guidelines and many fail European Habitats Regulations. The surveys and reports were highly variable, but even if ecologists provided good evidence for GHBs or EPS species, almost all concluded that theirdevelopment could be achieved within the guidelines, law and policy and that mitigation measures would compensate for most losses. In almost all cases, NE offered simply standing advice and offered no comment on the mitigation offered, leaving most responsibility with the LPA ecologist.

If developers did not provide HRAs, in most cases, the SHDC ecologist didn’t insist on it; in fact developers were sometimes encouraged to bypass guidance and policy.  At Brimhay for example, the LPA ecologist was active in advising the ecological consultants that HRA surveys were not required. He then explained to councillors at the Development Management Committee in June 2017 that they need not be concerned about GHBs because he stated he knew that the SAC would soon be reduced by 3km and be well outside the SAC. In reality, the SPD consultation paper does not seek any such large area of reduction as he described, and it is out for consultation now until 30thMay 2018.

In some applications the developer’s ecologist made bland statements that there was no need to undertake any wildlife surveys and made opinion statements that they deemed the  habitat was ‘poor’ without any survey evidence, such as for the planned house at Deepdene.  At this site large trees were felled and woodland cleared prior to an application for planning permission being made. No protection existed for GHBs, nor was sanction made over this damage.

At Meadowside the original (2012) ecology report shows a great deal of bat activity including use by GHBs but the ecologist makes considerable effort to explain that a flyway ( in this case the River Dart) can be considered only 500m wide and if measured from the centre of the river, this site is just out. This approach to avoiding an HRA survey and what it might reveal should have been picked up by the LPA. At Puddavine close by (but  outside the 4km used to define the SAC boundary) GHB evidence is clear, even on normal bat surveys- and measures are taken to avoid building close to the hedgerows or wooded margins of the site.

Early surveys on Sawmills Field are interesting, as they show the importance of the wider area for GHBs and show that the A385, then fairly quiet at night, was used as a flyway for them. The implication of the ecologist’s report was that loss of habitat at Sawmills East would be acceptable because of the adjacent good habitat.

However since 2014, the site has been surrounded by development. The disused, low density industrial site at Tweed Mills opposite is being replaced by dense housing. Sawmills West, now a horticultural plot and open field fringed by woodland is proposed for 40 houses in the JLP and opposite, Webbers Yard redevelopment has brought buildings far closer to the road. Loss of hedgerows that offered protection and shielded a major flyway has occurred despite assurances in the application’s Landscape and Environmental Management Plan, and only because local people complained at the removal of a substantial Devon hedgebank was enforcement action taken. Furthermore, the removal of a wooded valley at Brimhay just behind will serve to weaken and fragment the habitat and vital flyways. This increased development in this area of the village has greatly increased traffic on the A385, a roundabout has been installed with widened verges and reduced tree cover.

The ‘domino effect’ upon the habitat, when one development leads to or supports another, means that such areas of suburbanisation have a multiplier of adverse effects upon the SAC habitat. No one authority has taken an overview of the in combination effect of these sites- they were all decided on an individual basis, with the premise that GHBs and other wildlife on the desired site could just ‘go elsewhere’. This clearly is not a viable biological possibility for GHBs or other wildlife.

When it comes to long term planning as in the Joint Local Plan however, an overview would be clearly expected. The evidence however points to serious failings in the plan to properly consider the overall effects on GHBs and other wildlife and of allowing so much development; this seems at odds with aims to conserve England’s most significant stronghold of GHBs.

Permitted on the grounds that developers would mitigate for the loss or damage caused, most mitigation measures suggested are inadequate or unenforceable. At Brimhay for felling 93% of the trees on site, which included clear felling and uprooting an undisturbed hazel coppice close to the brook, the planting of one new hedgerow (which of course could take a century to be of real value to wildlife) was considered adequate. If developers can gain more space and hence more profit or contractors are poorly briefed, an important hedgerow can be lost in a day as at Tweed Mills; the only remedy the planting of a new line of spindly hedging.

Similarly lighting conditions are largely unenforceable. Whilst planners may add conditions for low level street lighting, and high fences to exclude light outside the development, after the build there are no real controls on lowering fences, on residents leaving bright upstairs lights on, installing high wattage security lights or of course the effect of car headlights.

As more development is permitted, road traffic increases and so does the need to ‘improve ‘roads- with all the attendant lighting, roundabouts, crossings and street lights; all of which do not seem to be considered, yet have a great effect upon lighting up whole areas used by GHBs.

Finally, the LPA does not seem to demand that developers demonstrate the effectiveness or otherwise of the mitigating measures they offer. When HRA or other bat surveys show a baseline picture of the GHBs and other bats using a site, then similar surveys should be repeated during construction and after the build, when the houses have been occupied a while. This is never done by developers or LPAs and there is no real evidence that mitigation can conserve GHB use after development. If mitigation does not work, or indeed show an improvement in GBH use, then it is clear that the developments being permitted breach both the Habitats Directive, NPPF and UK planning law.


CONCLUSIONS: The issues facing GHBs in the South Hams SAC

This study indicates that extent of development proposed for Dartington is incompatible with the conservation of GHBs in the area. As a vital reservoir of endangered species, the in combination effects of suburbanisation of large areas of the parish will have a real and damaging effect upon GHBs forever.

In allocating 55% of the housing allocation for all the ‘thriving villages’ for South and West Devon districts to Dartington, the Joint Local Plan is arguably unsound and incompatible with the legal protection, policies and guidance for conservation of this highly endangered species. 504 houses- a 63% growth in housing- plus a large employment site, over 20 years is unsustainable and will cause irreparable damage to the GHB’s habitat and chances of survival.

Whilst policies may appear sound on paper, they are falling far short of protecting the species on the ground. There seems to be no real oversight of the cumulative effects by NE who in taking a passive role and not ensuring the legislation met may be letting the survival of GHBs fall through net.

The LPA appears not to be examining the in combination effects of its decisions on the SAC or adjacent areas either. This study points to a regular pattern of letting developers submit inadequate surveys, allowing inadequate paltry mitigation, with no surveys after these developments to ascertain whether mitigation really works.  Mitigation is not an acceptable alternative to refusal where damage to the habitat will occur, because mitigation usually cannot compensate and the measures recommended won’t be checked and cannot be enforced. The effect of all this is a huge loss of habitat for GHBs and many other species that benefit from high quality diverse habitats.  Species such as GHBs are the canaries down our mine- they alert us to the state of habitats for whole range of wildlife.

Whilst GHB projects educate, advocate and survey areas, we understand they are dependent upon funding linked to development and can’t actively campaign against the serious threat of over development. They can only work positively on the areas that are left.

Bat experts agree that we still have a lot to learn about the complex ecology and habitat use of GHBs. Until we do, allowing a large amount of development in the SAC puts a species on the edge at risk. More comprehensive monitoring of GHBs will aid our understanding, but not if it cannot inform decision making. Gradual, natural growth, as has been experienced throughout the last 50 years may mean that most habitats remain, that connectivity is conserved and that the species slowly adapts its flyways. Rapid growth conflicts with all of the expert conservation advice and its effects will only escalate- it can never be reversed.

Let’s not allow GHBs to be Dartington’s last white rhino!


Who has researched and written this study?

Our study has been collated by residents, not experts but with a deep knowledge of the local area. Between us, we have expertise in wildlife research and management, conservation and planning. We have been actively involved in placemaking, responding to the JLP, Dartington’s Neighbourhood Plan and have an experience in planning and working on sustainable development in Dartington. We aim to promote discussion and change through this paper and will be circulating it widely. The document may be revised and updated, it has necessarily been produced in a short timeframe.

Who will this document been sent to?

Joint Local Planplanning inspectors

SHDC Ecologist and Local Plans Team

SHDC councillors

Torbay Council

Devon Wildlife Trust

Dartington Hall Trust

GHB groups

BAT Conservation Trust UK

Devon Bat Project

Natural England.


European Commission

Hugh Fearnley- Whittingstall

David Attenborough

Bill Oddie

Kevin Mc Cloud

Tom Cox

Molly Scott Cato- MEP

For legal advice and input- Harrison Grant, environmental specialist lawyers.

References include-

South Hams SAC- Greater Horseshoe Bat Consultation Zone Planning guidance 2010 and consultation paper 2018

National Planning and Policy Framework

Greater Horseshoe Bats- Bat Conservation Trust information

Action Plan for the Conservation of Bat Species in the European Union 2014-2020

Action plan for the conservation of the Greater Horseshoe Bat in Europe (Rhinolophus ferrumequinum) R.D. RANSOME (Bat Pro Ltd, Dursley, Glos., United Kingdom) Anthony M. HUTSON (The Bat Conservation Trust, London, United Kingdom) Convention on the Conservation of European Wildlife and Natural Habitats Nature and environment, No. 109   Council of Europe, July 2000

Bulkamore Iron Mine- Views about management, countryside and rights of Way Act 2000, Schedule 11(6) Natural England.

Greater Horseshoe bat Project 1998-2003 Dr Martin Longley, English Nature Devon Area Team.  Natural England.

Roost use, ranging behaviour and diet of Greater Horseshoe Bats. Using a transitional roost.  Journal of Mammalogy, 2009

South and west Devon Joint Local Plan draft 2018.

Bat record research results of study area – Dartington – Devon Bat Group.

Legally protected and notable species records within 1km of SX784620. Devon Biodiversity Records Office

Light Pollution – Dartington & Totnes2015, 2016  & 2017








Light Pollution Measurements – Dartington & Totnes 2013 to 2017 

Radiance Statistics –on a 1km circle
centred on the Cott Inn, Dartington    Area 3.14 km squared.

Year             2017                      Radiance  2.13
2016                      Radiance  2.04

2014                      Radiance  1.87
2013                      Radiance  1.84

Light pollution in most of this sector has been unchanged since 2013.
A  large increase in radiance has occurred due to light pollution in parts of this sector, principally  along the roads.  This light pollution can have a catastrophic effect on Greater Horseshoe Bats, and other critically endangered nocturnal species. This is not being considered effectively by Natural England or other Authorities.

Light pollution measurements are still an emerging science.

Ref:  www.lightpollutionmap.info


Light Pollution  South Devon  2015 and 2016







Appendix 2   Greater Horseshoe Bat Flyways  –   Radio Tracked Flyways- 2010


Greater Horseshoe Bat roost sites – showing direct routes between South Hams SAC’s – through Dartington village.(please note- GHBs will favour dark tree lined linear features to follow)
Appendix 3      Evaluation of recent planning applications and development  sites proposed in JLP
                        in Dartington, in relation to GHB conservation in the South Hams SAC.


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