Background and context
- Natural England
- South Downs National Park Authority
- LPAs
- Chichester District Council
- Horsham District Council
- Arun District Council
- Mid Sussex District Council
- Waverley Borough Council
The Sussex Bat Protocol applies within Sussex in the south east of England, including the South Downs National Park. Three Special Areas of Conservation (SACs) are covered by the Protocol including The Mens SAC, Ebernoe Common
SAC, and Singleton and Cocking Tunnels SAC. These SACs lie near a number of
Local Planning Authority (LPA) areas, including The South Downs National Park Authority, Chichester, Horsham, Arun, Mid Sussex, and Waverley, and are generally surrounded by a mix of farmland, small villages, and wooded valleys.
The Sussex Bat Protocol encompasses these three European sites, which are underpinned by Sites of Special Scientific Interest (SSSI) of the same name, with Ebernoe Common also designated as a National Nature Reserve (NNR).
The qualifying features of all SACs are the population of the Bechstein bats and Barbastelle bats using the SACs as a roost. Sites with maternity roosts are important as these are where female bats come together in the late spring and summer to give birth to and raise young, and so are critical to the conservation of the species. In addition to the SACs containing roosting sites, bats also require access to habitats outside the designated boundary of the SACs.
Ebernoe Common SAC is a complex of woodlands supporting both Barbastelle bat and Bechstein bat maternity roosts. The Mens SAC is a woodland which provides maternity roosts for Barbastelle bats. Singleton and Cocking Tunnels SAC is comprised of two disused railways tunnels which support large numbers of hibernating bats in the winter, including species such as Barbastelle bats and Greater Horseshoe bats. These tunnels are also important in the autumn when large numbers of bats congregate to swarm and mate.
These bat species also utilise land outside the SAC boundaries for commuting and feeding, referred to as Functionally Linked Land (FLL) (South Downs National Park Authority, n.d.). The foraging range of Barbastelle bats can extend up to 5km from a roost. This species has a preference for wet meadow and riparian habitats (Greenway 2004, and Greenaway 2008). Bechstein's bat has a smaller foraging range of 1-2.5km and tend to forage in and around woodland in which they roost (Schofield and Morris, 2000).
Ecological driver and scheme details
The Protocol defines two zones of influence around the Sussex Bat SACs, to account for the FLL that bats use for commuting and feeding. The Key Conservation Area, extending up to 6.5km from each SAC, where development proposals may have the potential to affect bat populations, and an outer Wider Conservation Area that extends from 6.5km to 12km from the SACs. Within this outer zone, bats may still be present, particularly along strategic commuting routes and within higherquality habitat networks and while impacts are less likely to be routine across this wider area, certain development proposals may still be relevant to the integrity of the SACs.
The Protocol sets out expectations for mitigation and avoidance in principle. Development should be carefully sited and designed to retain key habitats, including woodland, hedgerows, riparian corridors, and other linear features used by bats for commuting and foraging. Where development occurs near these features, the Protocol recommends the use of buffers to reduce disturbance and preserve connectivity. The Protocol also highlights the importance of sensitive lighting design and requires that construction and vegetation management avoid sensitive periods such as breeding, maternity, and hibernation seasons. It emphasises that impacts on FLL should be avoided where possible, particularly where high-quality or wellconnected habitats are affected. Where impacts cannot be avoided, the Protocol indicates that mitigation should maintain habitat connectivity and ecological function, rather than focusing solely on replacement habitat.
Where some habitat loss or disruption is unavoidable, mitigation and enhancement may be appropriate. The Protocol sets out requirements for this which focuses on maintaining ecological function rather than replacing habitat, including the creation of connecting woodland or hedgerows, improving riparian corridors, or enhancing understorey vegetation.
The Protocol identifies development related pressures which primarily arise from changes to habitats used for roosting, commuting, and foraging, both within and beyond the SAC boundaries. Key pressures include the loss, degradation, or fragmentation of woodland, hedgerows, and other linear features. Such habitat changes can sever commuting routes, reduce foraging opportunities, and isolate roost sites, all of which can compromise bat populations. The introduction of artificial lighting is another major pressure, as it can disturb nocturnal activity and disrupt established movement corridors.
Other pressures addressed by the Protocol include changes in land management, such as removal of understorey vegetation, hedgerow trimming at inappropriate times, or intensification of agricultural or forestry practices. Disturbance from construction activity and human presence near roosts or along key flightlines is also recognised as a potential impact.
The Protocol also notes the risk of cumulative impacts from multiple developments across the landscape. Even small-scale changes to habitat or connectivity, when combined with other pressures, can significantly affect the integrity of SAC bat populations.
The Protocol recognises that bat populations associated with the SACs face pressures from a range of development activities across the landscape. These pressures can affect bats both directly through loss or degradation of habitat, and indirectly by fragmenting commuting routes, altering habitat connectivity, or introducing disturbance. The Protocol addresses pressures from both individual developments and cumulative impacts.
The protocol is a strategic level and cross-boundary solution being applicable to development with the South Downs National Park Authority area and also surrounding LPA areas. The outer zone extends up to a maximum distance of 12km from the SACs.
The Protocol applies to any development proposal that falls within either the Key Conservation Area or Wider Conservation Area around The Mens, Ebernoe Common, and Singleton & Cocking Tunnels SACs. It is relevant to developments of all types where there is potential to affect habitats used by the SAC bat populations, either directly or indirectly, particularly development that may remove, degrade, or fragment habitats, or disrupt commuting and foraging routes.
Governance, structure and working arrangements
The Key Conservation Area and Wider Conservation Area extend over multiple Local LPAs. The requirements of the Protocol are secured through local planning policy. An example is the South Downs National Park Authority Local Plan which was adopted in July 2019 (South Downs National Park Authority, 2019). The current Local Plan secures the requirements of the Protocol within Policy SD10 – International Sites.
The Mens SAC, Ebernoe Common SAC and Singleton & Cocking Tunnels SAC
1. Development proposals on greenfield sites and sites that support or are in close proximity to suitable commuting and foraging habitat (including mature vegetative linear features such as woodlands, hedgerows riverine and wetland habitats) within the following ranges as shown on the Policies Map, should have due regard to the possibility that Barbastelle and Bechstein’s Bats will be utilising the site. Such proposals will be required to incorporate necessary surveys and ensure that key features (foraging habitat and commuting routes) are retained, in addition to a suitable buffer to safeguard against disturbance.
- 6.5km: Key conservation area – all impacts to bats must be considered given that habitats within this zone are considered critical for sustaining the populations of bats within the SACs; and
- 12km: Wider conservation area – significant impacts or severance to flightlines to be considered.
2. Proposed use or development of the tunnels comprising the Singleton & Cocking Tunnels SAC will be required to demonstrate that there is no adverse effect on the interest features, including hibernation habitat for Barbastelle and Bechstein’s Bats, or on the integrity of the site.
The emerging South Downs Local Plan evolves this policy further with some minor amendments. This includes Policy SDN3 - The Sussex Bats Special Areas of Conservation (SACs), which specifically embeds the protected sites and the Key Conservation Areas into Local Plan policy.
Where a planning permission is granted and mitigation is required, it is usually secured through planning conditions and legal agreements (such as Section 106 planning obligations). Conditions may require submission and implementation of detailed mitigation measures (e.g., sensitive lighting design, habitat buffers, ecological management plans) before development begins, while legal agreements can secure long-term management, maintenance, and monitoring of retained or created habitats.
Communication and engagement
The Protocol is not a formal joint-authority policy adopted collectively by multiple councils, but rather a technical framework produced by a partnership of the South Downs National Parks Authority and Natural England, and then applied individually by LPAs whose areas fall within its ecological zones.
Monitoring
The protocol itself does not prescribe a monitoring programme, but for individual developments it sets out requirements for post construction monitoring.
In practice, whilst the Sussex Bat SAC Protocol does not explicitly link to multifunctional benefits, the mitigation measures prescribed take a landscape scale approach to habitat enhancement which is likely to have wider ecological benefits.
Good practice highlights
The protocol was prepared through a partnership of Natural England and the South Downs National Park Authority, with implementation by Local Planning Authorities whose areas overlap with the ecological zones around The Mens, Ebernoe common, and Singleton & Cocking Tunnels SACs, including Chichester, Horsham, Arun, Mid Sussex and Waverley Councils. While the protocol is not a formal joint-authority policy, its adoption across multiple LPAs ensures a consistent approach for decisionmaking and coordinated consideration of development impacts on bat populations across administrative boundaries.
Governance is provided through integration with statutory Local Plan policy, for the South Downs National Park this is set out in Policy SD10 – International Sites, which sets out the protocol’s requirements in planning decisions. This approach ensures that development proposals are assessed with regard to both direct and cumulative impacts on Barbastelle and Bechstein’s bats and the integrity of the SACs.
A key strength of the protocol is its evidence-led, adaptive approach. The Key Conservation Area (up to 6.5 km) and Wider Conservation Area (up to 12 km) were defined based on species-specific foraging and commuting ranges, ensuring that planning assessments reflect real ecological needs. Post-construction monitoring requirements are applied to individual developments to demonstrate the effectiveness of mitigation measures and support adaptive management.
The framework also operates at a landscape scale, considering functionally linked land outside SAC boundaries and ensuring habitat connectivity across multiple sites.
Greenaway, F. (2004) Advice for the management of flightlines and foraging habitats of the barbastelle bat Barbastellus barbastellus. English Nature Research Report, Number 657.
Greenaway, F. (2008) Barbastelle bats in the Sussex West Weald 1997 - 2008
Schofield H & Morris C. (2000). ‘Ranging Behaviour and Habitat Preferences of
Female Bechstein’s Bats in Summer’. Vincent Wildlife Trust
South Downs National Park Authority (n.d.). Sussex Bat Special Area of
Conservation. Planning and Landscape Scale Enhancement Protocol. Available at: https://www.southdowns.gov.uk/wp-content/uploads/2018/04/TLL-15-Draft-Sussex-
Bat-SAC-Protocol.pdf (Accessed: 02/02/26)
South Downs National Park Authority (2019) South Downs Local Plan (2014 – 33). Available at: https://www.southdowns.gov.uk/planning-policy/south-downs-localplan/local-plan/ (Accessed: 18/02/26).