Supplementary memorandum from the Bat
Conservation Trust
The Bat Conservation Trust welcomes the opportunity
to submit a further Memorandum to provide information in addition
to that given to the Committee on 20 May.
The first point relates to Q185; there
are inconsistencies in advice given by SNCOs not only between
different countries, but also within individual countries. For
instance, the law has been broken in the past because of apparent
misunderstanding of the legislation by SNCO staff, and also by
a lack of clarity in the advice letters SNCOs write to householders
with bat roosts. Therefore, resources need to be available for
training of SNCO staff who deal on a day-to-day basis with inquiries
about bat roosts and who send out official letters following up
a visit by a Licensed Bat Worker. This advice needs to be consistent
and correct across the UK.
Also, we are aware that there are variations
in the type of licences issued by SNCOs to bat workers. A "conservation"
or "roost visitor" licence is given to those who have
undertaken sufficient training which enables them to visit householders
with roosts on behalf of the SNCO. In Scotland this licence also
covers survey for bats in hibernation sites; in England a "scientific"
licence for survey of bats in a hibernation sites is needed; in
Wales we understand that the "conservation" and "scientific"
aspects of the licence have been merged. This can lead to confusion
amongst bat workers as to which licence is needed for what, with
the potential for unintentional breaking of the law. Consistency
between the countries issuing these licences would clear up confusion.
The second point relates to Q191; Operation
Bat is an excellent initiative, but we are unsure as to whether
it is able to deliver. BCT has concerns about the lack of resources
being put towards it. Currently not all constabularies have wildlife
crime officers. Even where there are WCOs, these individuals take
on the wildlife crime cases in addition to their normal casework
which means that wildlife crime is often not seen as a priority
by the individual WCO. BCT would like to see more resources allocated
to Operation Bat, and WCOs appointed to ensure coverage across
the UK.
Whilst BCT firmly believes that bat conservation
is best achieved by education and not through enforcement, the
deterrent effect of prosecutions has been shown to be effective
in the timber treatment industry. Up to 1990 there had been eight
bat related prosecutions, six of which were of the timber treatment
industry. We believe that these well-targeted prosecutions combined
with education resulted in much improved working practices; since
1990 there have been no reports of bat related crime connected
with the timber treatment industry.
The third point relates to Q199; BCT
is keen to see the existing method of dealing with roosts in houses
remain with the volunteer Licensed Bat Worker and SNCO; we are
very concerned about the proposal to make the Habitats Regulations
more compliant with the Habitats Directive because we think that
interpreting the Directive in this way is taking it out of context.
It seems to contrast with what the Directive says in its Article
2. Of all the European Protected Species, we think that bats will
fair the worst if these amendments go ahead without a well thought
out system of guidance and resources, because of their association
with human dwelling places.
If the amendments do go ahead then BCT believes
proper interpretation of exactly what Favourable Conservation
Status means for each European Protected Species is essential.
Without this, no proposal could pass all three of the Habitats
Directive "tests", in which case the proposal could
not legally be implemented.
June 2004
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