The Bat Earned Recognition (ER) Pilot Project is a partnership project between Natural England (NE), the Bat Conservation Trust (BCT) and the Chartered Institute for Ecology and Environmental Management (CIEEM) which seeks to design and test a scheme to streamline the mitigation licensing process for bats in England.
This streamlining will be achieved through a new Class Licence, where NE formally accredits ecologists who can demonstrate appropriate competency to undertake bat roost mitigation work. Once accredited, ecologists usually need only submit minimal information to Natural England when registering a site under the Class Licence. This Site Registration application undergoes a light touch assessment and a licensing decision is issued rapidly.
The BER concept builds on the existing Bat Mitigation Class Licence (BMCL) system currently used as a streamlined licensing route for the lower conservation risk licence applications – and applies this approach to both lower and higher conservation risk roosts, covering the majority of bat licensing work.
The Bat ER Pilot commenced Winter 2020, with a Register of Interest for Pilot ER Candidates in Summer 2021 and Assessment for Accreditation Sept 2022 - May 2022. Accreditations under the Pilot are now closed although successful ER consultants are able to continue to submit Site Registrations during the Beta phase of the project
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FAQ Document
Section A - Introduction
1. The Bat Earned Recognition (ER) Pilot
The Bat ER Pilot had space for 100 individuals to undergo the assessment process. However, 215 individuals registered an interest in being involved in the pilot which meant that not all respondents could be selected to take part. A sample of participants which represented a wide geographical range, size of business and level of experience were carefully selected to test the scheme to the fullest. 57 ER candidates were successful in achieving ER accreditation in the pilot. (AL1 – 33; AL2 – 18, AL3 – 6).
No. Unfortunately, we are unable to share a list of ER Consultants at this time. As a pilot project it is felt this would not be appropriate at the time. However, we expect that a shared list of ER consultants will be available in the event the scheme is rolled out fully by Natural England.
No details will be shared without the permission of the registered ER Consultants first.
13 bat expert professionals were employed, 12 as ER Assessors and 1 as the ER Moderator. All were recruited from the bat ecology community to undertake accreditation assessments of the ER pilot candidates.
Assessors were recruited through an Expression of Interest exercise, from which Assessors were selected on the basis of their CV and an interview.
Assessors needed to meet a set of criteria; be accredited at the same or higher Accreditation Level that they were assessing, and to have attended mandatory training on NE ways of working and assessing candidates for Earned Recognition accreditation.
Assessors also have an obligation to undertake a minimum level of industry-relevant continuing professional development (CPD) each year, together with any refresher training provided by NE.
It does this via:
• Prior robust assessment of the ‘competence’ of ER Consultants;
• Ensuring effective data collection; and
• Compliance checking and monitoring.
We will design the process to ensure that any data collected is done so in a way to facilitate analysis and interpretation, to better understand outcomes for bat populations and inform the evidence base for the effectiveness of mitigation and compensation.
Yes, the evaluation report for the pilot is now complete and available via partner Bat ER webpages.
Further, an Evaluation Report Addendum is expected release in January 2023 to take into account further data collated from the processing of Bat ER Pilot Site Registration submissions undertaken post-preparation of the main report itself and until end December 2022.
2. Bat Earned Recognition (ER) Beta
Bat ER Beta remains part of the Bat ER Project Pilot phase, however, is a transition phase between the initial Bat ER Pilot and anticipated ER roll out by Natural England. It seeks to improve the existing systems and materials developed for the ER Pilot in response to the pilot's evaluation and feedback received. The undertaking of the BETA phase is critical to ensuring that its ‘fit for purpose’ and aligned with internal systems.
We are looking to recruit a further 100-150 candidates to participate in the improved Bat ER Beta accreditation process with assessment in Jan-March 2023.
• Aug 2022-Jan 2023 – Improve Bat ER materials/processes from pilot versions for Beta by Natural England, partners and a team of consultants
• Nov 28 – End Dec 2022 – Bat ER Beta Application period for interested individuals
• Early Jan 2023 - Confirmation of Bat ER Beta Candidates, Assessors and Moderator by Natural England
• Jan-March 2023 – Bat ER Beta Assessments
• April 2023 – Confirmation of Bat ER Beta Accreditations and release of associated Accreditation Certificates to successful Bat ER Beta Candidates
This timeline is subject to change.
A decision as regards potential ‘roll out’ of Bat ER into Natural England’s ‘business as usual’ processes is expected early Spring 2023. It is anticipated that Bat ER will eventually become the main route for bat mitigation licences. However, no decisions on this have yet been made.
You can apply for ER Assessment under Beta between 28 November 2022 and 31 Dec 2022. Applications can be made via the ‘Apply Now’ link on the CIEEM Bat ER application page.
We are looking to take a further 100-150 candidates through the improved Bat ER Beta Assessment process starting January through to end March 2023.
Applicants will be informed as to whether they are accepted for Bat ER Beta Assessment in the first week of January 2023.
Individuals interested in applying should be aware that the following are pre-requisites to application:
- Holding a Level 2 Survey Licence
- Membership of a Professional Body meeting our criteria. This is currently: The Chartered Institute of Ecology and Environmental Management (CIEEM); and The Institute of Chartered Foresters (ICF).
Natural England confirms that individuals who expressed an interest previously but were not selected for the pilot, or were unsuccessful in completing assessments, are able to re-apply.
Bat ER Beta Assessors were selected from those that had most experience with the Bat ER Pilot, and include a number of the Bat ER Pilot Assessors as well as individuals that had most had most understanding and experience with Bat ER via Site Registration submissions. The majority are AL3 accredited. The selected individuals were approached directly, based on this experience.
All Bat ER Beta Assessors will hold an accreditation level equal to, or higher than, the candidates they are assessing.
Furthermore, a conflict of interest (COI) policy will apply to ensure the process of assessment is applied openly and fairly. Both Bat ER Assessors and Candidates are encouraged to state a conflict of interest arises and have that considered. Alternative allocations will be applied where required.
Yes, all unsuccessful pilot candidates are able to reapply for Beta.
Individuals interested in applying should be aware that the following are pre-requisites to Bat ER Beta application:
- Holding a Level 2 Survey Licence
- Membership of a Professional Body meeting our criteria. This is currently: The Chartered Institute of Ecology and Environmental Management (CIEEM); and The Institute of Chartered Foresters (ICF).
All previously unsuccessful applicants should also be aware that they will be required to complete the assessment process from Beta Stage 1 through to 4. That is, previous stage passes achieved during Bat ER Pilot assessment will not count towards assessment for Bat ER Beta.
Further, we ask that all applicants are confident as to the accreditation level to which they should apply.
Accreditation achieved under Bat ER Beta will last at least 2 years from the date of accreditation.
A decision as regards when re-assessments will be required is expected late Spring – Summer 2023 following an internal review of the Bat ER Project overall and a decision as to potential full implementation of the scheme by Natural England
During the Bat ER Beta phase all existing bat mitigation licensing routes will be open and licence applications will be processed as usual. If the decision is taken to implement the Bat ER scheme in the long term it is possible that Bat ER will eventually become the main route for bat mitigation licences. However, no decisions on this have yet been made.
It is expected, however, that the time and cost savings associated with Bat ER licensing will drive its increased take-up given the significant advantage it offers over traditional licensing routes
Natural England has the planned capacity to undertake 150 Accreditation Assessments for Bat ER Beta. Natural England received 177 Beta applications and was, therefore, unable to take all applicants through this round.
In order to meet the required maximum number for Beta, and ensure a breadth of applicants to ‘test’ the Beta systems, Natural England applied the following prioritisation sifting criteria, in descending order to determine ‘who’ was selected:
1. Applicants who are amongst the ‘most prolific bat mitigation licence applicants’* -to ensure that sufficient site registrations are submitted under Beta (21 in total).
2. Applicants who Registered their Interest in the Bat ER Pilot in 2021 but weren't selected (48 in total).
3. Applicants who voluntarily decided to halt the accreditation process during the Bat ER Pilot in 2021 through either personal reasons or complexity concerns (10 in total).
4. Sole Trader applicants not covered by the above criteria (11 in total) – to ensure we had a good range of ‘types/size’ of organisation testing the process.
5. Applicants not covered by the above criteria whose geographic coverage included northern regions (North East -11; North West – 10; Yorkshire – 7) - to ensure a geographic balance of applicants in Beta.
6. Applicants who were selected for Bat ER Pilot in 2021 but were unsuccessful (3 in total).
This took the number of candidates to take through Beta to 121. The additional 29 were selected using a random number generator.
This leaves us with a remainder of 27 unselected applicants which we are, regrettably, unable to take through Bat ER Beta at this time.
Importantly, an addtional 9 applicants applied for the Trees and Woodlands Annex only and were existing accredited Bat ER Consultants under the Bat ER pilot Class Licence. The decision was taken to take all 9 through the process in addition to the agreed 150 new candidates in order to test the Annex to the fullest.
* …‘most prolific bat mitigation licence applicants’ – those submitting 4 or more applications 2021/22 in line with data supplied by Natural England’s Wildlife Licensing Service.
3. Existing Bat ER Consultants
In correspondence issued to all Bat ER Consultants under the Pilot on 29 September 2022, Natural England confirmed it has established a general principle of rolling over all Accreditation Certificates issued for those who successfully passed the Bat ER Pilot to cover the ER Beta phase. Further correspondence from Natural England to Bat ER Consultants on 16 November 2022 confirmed the Period of Accreditation now extended to the end of March 2023 to correspond with the anticipated completion of Bat ER Beta assessments.
We are in the process of looking at the Bat ER Pilot data and may identify some Pilot ER Consultants for further checks during Beta.
See answer to 3.1 above in relation to Accreditation Certificates.
Existing ER Consultants will be able to continue submitting Site Registrations from 1 January 2023 onwards.
There is an intention to introduce a new Bat ER Annex as part of the Beta phase, covering trees and woodlands. The process for existing ER Consultants to apply for new Annexes is currently being developed.
We will not be assessing changes in accreditation level for existing ER Consultants during Bat ER Beta. We will subsequently develop an appropriate process for progressing through the Accreditation Levels so that Consultants are able to take full advantage of all ER opportunities.
Section B - Bat ER Class License & Associated Annexes
4 The Bat ER Class License WML-CL47
The Bat ER Class License (WML-CL47) is not publicly accessible and is only available to those who have access to it via successful Bat ER accreditation.
Once a Bat ER Consultant has completed the ER assessment process, signed their Accreditation Certificate and formally received their signed Accreditation Certificate from Natural England, that individual is permitted to rely on the Bat ER Class Licence for sites that been successfully registered with Natural England. After issuing the signed Accreditation Certificate, Natural England will invite the ER Consultant to access a dedicated MS Teams Channel where the following documents and links are stored and available:
• Bat ER Class Licence WML-CL47
• WML-CL47 Applicant Declaration Form
• Bat Earned Recognition (ER) Pilot – An overview of the process for ER Consultants to use the ER Class Licence WML-CL47 (Doc ref: CL47Guidance01)
• Minimum Expectations for Bat Mitigation, Compensation, Monitoring and
Management (Doc ref: CL47Guidance02).
• Bat ER Enforcement and Disciplinary Position
• Link to WML-CL47 Site Registration Form
• Link to WML-CL47 Licence Return Form
• Link to WML-CL47 Monitoring Form
Similar to the Bat Mitigation Class Licence (BMCL) [WML-CL21], the Bat ER Class Licence comprises a series of licence annexes that specify the species and number of roosts that can be registered under each licence annex. The ER accreditation assessment process will determine the accreditation level (AL1, AL2 or AL3) for each ER Consultant and, therefore, eligibility to use the Bat ER class licence annexes.
5 Accreditation Levels and Licence Annnexes
ER Accreditation Levels and Associated Licence Annexes used developed for the Bat ER pilot are undergoing some alteration for Bat ER Beta. The details of these are being developed now. Summary tables are provided via the Bat ER Beta applicatopn page - under 'Resources'.
At this location you can also find the Bat ER Beta Competency Framework which describes what evidence is required for each Accreditation Level.
Species groups for the pilot were presented in a Bat ER Accreditation Levels Table. Species were grouped according to population size and conservation status. Group 1 contains the most abundant species in England and Group 3 contains Annex II species and other rare species with restricted distributions.
Please be aware that this Table is being reviewed for Beta and will be shared here as soon as it is available
The inclusion of core ranges of bat species was considered when developing the Accreditation Level Table. This would be relevant to a small number of Group 2 species and all Group 3 species. Ultimately it was decided that an ER Consultant at all levels should be able to appropriately assess the conservation significance of a roost and determine appropriate mitigation and compensation measures wherever that roost is located in England.
Yes, accredited Agents and Assistants are permitted under the ER Pilot and Beta, with licence conditions and guidance in place. There is no ER assessment process for Accredited Agents during ER Pilot and Beta.
Section C: The Accreditation Process
6 Application Requirements
Yes. For the Beta phase of ER it will be a requirement to hold a minimum of a Level 2 Natural England bat survey class licence, but there will not be a minimum time period imposed.
Yes. Membership of a professional body was not a requirement during the pilot. However, this is requirement for Beta and Natural England has agreed a set of criteria for such bodies.
Natural England is currently in dialogue with relevant professional bodies and expects CIEEM and the Institute of Chartered Foresters (ICF) to meet these criteria. There will be a minimum grade of membership of each relevant professional body where the criteria are met. For CIEEM this would be Associate, Full and Chartered level membership. For ICF and any other professional bodies, acceptable levels of membership will be determined.
Yes. Accreditation will not be restricted only to ecologists who have previously held bat mitigation licences, but all applicants will need to provide examples of their work, including bat mitigation projects. Ecologists looking to gain accreditation would need to gain knowledge, skills and experience through working with others, training and keeping up to date with the latest research and guidance. This is in line with the current system for gaining a full bat mitigation licence or subsequent licences for additional species and roost types.
Examples of work carried out under bat mitigation licence (not necessarily as the Named Ecologist) and work carried out under non-licensed Method Statement will need to be submitted as part of an application for accreditation. For some competencies, other types of work will be considered if no practical mitigation examples are available. These will include:
• Ecological surveys and mitigation plans that you’ve produced in support of planning applications
• Planning or participating in monitoring or research projects
• Designing robust schemes that avoid or lessen impacts
• Advising on large scale development projects
• Planning and delivering recognised training courses
• Being responsible for protected sites
7 Accreditation Assessment Process
We assess competency using four different methods of assessment:
• Stage 1 Multiple Choice Questions (MCQs);
• Stage 2 Online Scenario Tests (OSTs);
• Stage 3 Portfolio Evidence; and
• Stage 4 Professional Interview
All four methods of assessment must be passed to gain Bat ER accreditation.
Assessment will be relevant to the Accreditation Level applied for at application stage.
All four accreditation stage assessments are currently hosted digitally on a Moodle platform hosted by CIEEM. Each Beta candidate will be registered to Moodle by Natural England and be provided with access details via email. These details should be used by the candidate to log onto the Moodle platform to undertake assessments.
Yes. If you decide to remove annexes or lower the accreditation level being applied for, you can do this at any stage of the assessment process. Requests to apply for a higher level and/or additional annexes will depend on how far along the accreditation process you are and will be determined on a case-by-case basis.
Yes. If the ER Assessor feels that a candidate has not demonstrated sufficient competence to warrant a particular Accreditation Level, they are able to recommend that a lower Accreditation Level is awarded. This will be reviewed by Natural England on a case-by-case basis.
Where a genuine Conflict of Interest (COI) arises, Natural England will seek to assign an alternative assessor, or QA the assessment before making the accreditation decision.
Yes. Assessment for Accreditation under Beta will run between January and March 2023, and only in exceptional circumstances will extensions will be considered.
Each of the four stages of the assessment needs to be passed in order to achieve accreditation. Failure of any of the stages will mean you do not achieve accreditation.
Contact the Natural England Bat Earned Recognition Project Team via the ER Mailbox earnedrecognition.bat@naturalengland.org.uk.
Contact the Natural England Bat Earned Recognition Project Team via the ER Mailbox in the first instance - earnedrecognition.bat@naturalengland.org.uk
8 Evidencing Competency
During accreditation assessments, candidates will be assessed against the Competency Framework (add link). There is no intention to use the number of previous licences held to assess accreditation candidates, although candidates will need to demonstrate all competencies, which will often require submitting and discussing examples of mitigation work.
There is no time limit on evidence submitted, although more recent evidence is preferable in helping demonstrate a current level of competence. The Earned Recognition assessment process focusses on robustly testing whether someone is competent using a blend of methods to assess existing levels of knowledge and understanding in addition to prior experience and skills evidenced by the portfolio. CPD in support of an application must include 15 hours or more of CPD activity in last 12 months (or 24 months if time has been spent away from work) and relevance to professional bat practice.
Yes, we are looking for evidence of competence and the nation/country in the UK in which the competency has been employed will not usually be relevant.
It is recommended that Consultants keep their own records which can be shared without breaching company policies, or utilise publicly available planning records.
No, referees/sponsors will not be required as part of the assessment process.
All competencies will be assessed independently through the ER scheme. This is because the process for assessing competencies for professional body memberships will not have specifically focused on bats. These criteria may also differ, and it is important to have the same system for everyone.
However, in relation to professional body membership, assessed competence for ER may help to evidence competence for upgrading membership / applying for Chartership.
9 ER Re-assessment and progression
We will not be assessing changes in accreditation level for existing ER Consultants during Bat ER Beta. Natural England will develop an appropriate process for progressing through the Accreditation Levels and maintaining Accreditation upon wider roll-out of Bat ER
Section D: The ER Licensing Process
10 The ER Site Registration Process
Registration of a site under the WML-CL47 licence is via an online form. A link to this digital form is provided once an ER Consultant completes the ER Accreditation process. The Registered Consultant will receive a PDF copy of their site registration request once it is submitted. .
To identify the location of SSSIs and European sites, refer to the Magic map system. You can search for and view details about all SSSIs by using Natural England’s Designated Sites system, including the citation and the list of operations requiring Natural England’s consent for each site..
The definition of a roost varies depending on the structure, how bats are using it and the judgement of the person who has undertaken the surveys. A whole structure or part of a structure may be considered as a roost, depending on the circumstances. For example, 3 common pipistrelle bats may be using separate roof tiles as roosting sites/access points but the roof structure itself could be considered as 1 roost because it is in use by a single species. But if 2 common pipistrelle bats and a whiskered bat are using roof tiles –then as there are 2 species this would be considered to be 2 roosts. If brown long-eared bats are using a structure for different purposes, for example as a feeding roost and a day roost, there would be 2 roosts, even though it is 1 species.
In the Bat ER Class Licence, a roost is defined as: A single structure or part of a structure, used by a single species for a single purpose.
In this situation, the steps to follow are set out in the Bat ER Class Licence. The ER Consultant should contact the Natural England Bat ER Team as soon as practicable. The ER Consultant should confirm the species found, the number of bats found, details of previous surveys and/or additional pre-works inspections and what is proposed as additional or revised mitigation and compensation.
Natural England will respond and confirm in writing whether the unexpected find can be authorised under this licence, or whether an individual licence, or registration by a different ER Consultant with the relevant Accreditation Level, is required.
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The Licensee (the ER Consultant) and Joint Licensee (the person or organisation who has instructed the ER Consultant to carry out licensed activities) for each Registered Site are responsible for all activities carried out under the licence; including activities carried out by any Accredited Agent and any Assistant. However, this responsibility is limited to them doing what is reasonably possible to ensure that other persons acting under the licence comply with it.
The Licensee and Joint Licensee can exercise their duty of care to do what is reasonably possible by providing clear and correct written and/or verbal guidance for others acting under the licence and ensuring they understand those instructions. Licensees can also place contractual obligations on other parties (normally contractors) to follow certain instructions.
Depending on the accreditation level, survey reports may be required as part of this site registration application. As per standard individual licence applications to mitigate impacts to bats and their roosts, we may require a masterplan, habitat management and maintenance plan, survey, impact, mitigation and / or compensation maps dependent on the risk level and impacts occurring on site. These can be uploaded to the digital form when submitting a site registration request.
The length of time a site is to be registered for is included in the authorised site registration email.
Where a multi-plot or phased development is occurring on a site, a Masterplan and Habitat Management and Maintenance Plan is required, as standard for EPS-MIT individual licence applications. Each phase of impacts to bats will likely require a new site registration application, depending on the timescales between impacts. If an ER Consultant is deregistered during the implementation of a licence, the Joint Licensee (person or organisation who has instructed the ER Consultant to carry out licensed activities) would be required to appoint a competent ER Consultant replacement.
Information to be submitted in a site registration request is streamlined as far as possible. For some AL2 and all AL3 applications, it is necessary to provide survey, impact, mitigation and/or compensation maps to inform the site registration application.
For cases falling in Accreditation Levels 1 and 2 where no elements are a risk to the Favourable Conservation Status (FCS) of bats, the site registration application would not be flagged for a full assessment of the application and the licence would be issued on that basis.
Compliance checks are being completed on many of the sites registered to ensure we are capturing enough information on the site registration application form to inform whether there is a risk to the FCS of the species being impacted.
A compliance monitoring strategy was implemented during the pilot, and ongoing, which comprises a combination of targeted and random monitoring. Natural England is completing compliance checks on registered sites for all accreditation levels, whether cases are flagged for manual assessment or not. Individuals who are falling below the standards of their accreditation level will be subject to investigation and appropriate sanctions.
Where survey guidelines are not followed, this is stated on the site registration form and the case is flagged for some level of manual assessment by Natural England to determine if the survey is appropriate and sufficient in that case. ER consultants must be able to justify any approach where they have deviated from survey guidelines, and/or used their professional judgement to determine an approach.
Where a consultant states that guidance has been followed and where subsequent compliance checks find this is clearly not the case, that would be subject to enforcement action. Enforcement actions could involve a range of sanctions depending on severity and could result in de-registration from the licence.
Section E: Compliance and Enforcement in ER
11. Compliance and Enforcement in ER
An integral part of the Bat ER concept is that resource moved away from detailed assessment of all site registrations can be dedicated to increased compliance checking of licensed actions.
A compliance monitoring strategy comprising a combination of targeted and random monitoring was implemented during the pilot and is ongoing. Natural England will undertake compliance testing on registered sites for all accreditation levels, and individuals who are falling below the standards of their accreditation level will be subject to investigation and appropriate sanctions.
Ultimately it would be Natural England's decision as to whether someone can remain as an ER Consultant following disciplinary and/or enforcement action by their professional body. Membership of an approved Professional Body remains a requirement for Bat ER accreditation.
Section F: Further Information and Training
12. Further Information
Via partner websites:
• Earned Recognition Project - Project collaborations & Partnerships - Bat Conservation Trust (bats.org.uk)
• Earned Recognition | CIEEM
This FAQ document will also be regularly updated.
Via newsletter and social media updates:
• Natural England - Wildlife Licensing newsletter
• Bat Conservation Trust – Bat Bulletin and Linked In
• CIEEM – eNews
Contact the Natural England Bat Earned Recognition Project Team via the ER Mailbox earnedrecognition.bat@naturalengland.org.uk
13. ER Training
This is currently being considered. Links will be provided here when available.
This is currently being considered. Links will be provided here when available.