Wrong Plan. Wrong Site. has uncovered fresh evidence of bat activity at MOD Bicester Site A, raising serious questions about the ecological work underpinning the Government’s proposal and the use of powerful floodlights at the site over the weekend.
Wrong Plan. Wrong Site. is a non-political campaign. We would work constructively with our local MP regardless of which political party they represented, and our opposition to this proposal is not based on party politics.
But being non-political does not mean being silent when a government gets something wrong.
The current UK Government happens to be a Labour Government, and we believe it now has some very serious questions to answer about what is happening at MOD Bicester Site A.
Over Friday and Saturday night, powerful floodlights were reported illuminating parts of the proposed development site. At the same time, local residents have been gathering evidence of bats actively using the area.
Bats are legally protected in England. Government guidance specifically identifies artificial lighting as something capable of affecting bats, including lighting outside a roost where it illuminates an entrance. It also says developments should be surveyed where they are close to habitat used by bats or where proposed lighting could affect commuting or foraging habitat.
Natural England’s guidance is also explicit on one particularly important point: an absence of existing records does not mean bats are absent from a site. It may simply mean that adequate survey data does not exist for that location.
That makes what happened at Site A this weekend all the more concerning.
Bats detected within minutes
On Saturday night, Bicester resident and qualified zoologist Dr Claire Brenner visited the area with a bat detector alongside a local resident with ecological experience.
Within minutes, they recorded bat activity.
In a video recorded at the scene, Claire said:
“I’m down here with my bat meter… and you can see very clearly on the screen right now that we are picking up multiple bat species.”
Claire has also obtained information from the Thames Valley Environmental Records Centre which, she says, identifies nearly 6,000 records of protected and notable species in the wider area around the site.
The underlying planning application is for temporary asylum accommodation for up to 1,256 people at Bicester Garrison Site A, with the Secretary of State listed as the applicant.
The application includes ecological documents and correspondence with Natural England, but the evidence now being gathered locally raises an obvious question: was the ecological baseline sufficiently complete before activity began on the site?
The wrong records?
One of the most troubling issues raised by Claire concerns the ecological records search used in connection with the proposal.
According to documents submitted by the Home Office in its planning application, the preliminary ecological work relied on records from a Buckinghamshire database despite Site A being in Oxfordshire, while a search of the Thames Valley Environmental Records Centre produced extensive records for protected and notable species in the surrounding area.
That allegation now needs a clear response from the Home Office and its ecological consultants.
There is an important distinction here. A database search alone does not establish whether bats are roosting on a particular part of Site A, nor does the presence of bats automatically mean a criminal offence has occurred.
But equally, the law does not allow a developer simply to assume that protected species are absent because a database search did not find records.
Natural England’s planning guidance specifically warns against doing exactly that.
Why were powerful floodlights being used?
That brings us back to the floodlights. Wrong Plan. Wrong Site. has now received evidence that powerful lighting was used around Site A on both Friday and Saturday night.
Artificial lighting can alter the way bats leave roosts, forage and travel through the landscape. Natural England advises developers to redesign lighting where necessary to avoid roost entrances, commuting routes and foraging habitat, while the Bat Conservation Trust has repeatedly highlighted construction lighting as a potentially significant issue for bats.
We therefore want a straightforward answer from the Government: What ecological assessment was undertaken before these floodlights were switched on?
Was a qualified bat ecologist consulted? Were known or potential commuting routes considered? Were the lights positioned or shielded to minimise disturbance? And were any licences considered necessary?
Those are not unreasonable questions. They are questions any private developer would be expected to answer.
Claims about HS2 need to be treated carefully
There have also been comparisons locally with controversial lighting used during construction work connected with HS2.
There is documented evidence that campaigners complained about powerful spotlights being directed towards woodland associated with bat activity during HS2 works, and the Bat Conservation Trust raised broader concerns about construction lighting during the HS2 programme. But allegations that lighting was deliberately used to drive bats away were contested, and we cannot currently establish that as a proven tactic.
For that reason, our concern at MOD Bicester is based on what can be established here and now: powerful overnight lighting, confirmed bat activity nearby, and unresolved questions over the adequacy of the ecological evidence.
That is serious enough.
The Government should be held to the same standard as everyone else
This is where public frustration becomes entirely understandable. If a private developer submitted an application affecting protected wildlife, it would be expected to undertake appropriate surveys, identify potential impacts and put mitigation in place before carrying out potentially harmful work.
The Government should be held to no lower standard.
Natural England states that where development work would otherwise unlawfully affect bats, a mitigation licence may be required. That includes deliberately or carelessly disturbing bats, damaging or destroying breeding or resting places, or obstructing access to them.
Nobody is above that law simply because the applicant is the Government.
And these wildlife concerns do not exist in isolation. Questions have already been raised about infrastructure, generator use, drainage, contamination and the speed at which this proposal has been progressed. The planning application itself shows the scale of the development proposed at this rural site.
For local residents, the growing impression is of a proposal being pushed forward while fundamental questions are still being answered after the event.
That is not good enough.
We are gathering evidence
Wrong Plan. Wrong Site. is now actively gathering photographs, video, bat recordings, historic ecological records and other evidence relating to Site A.
We are also seeking input from appropriately qualified bat and ecological experts so that the evidence can be independently assessed.
If that evidence shows protected species are being disturbed unlawfully, then the relevant authorities should investigate and take whatever action the law requires.
Our legal challenge is already underway, and environmental concerns form an important part of the wider scrutiny of this proposal.
Dr Brenner summed up the concern in her video from the site:
“The government knows [the evidence] exists. The government is choosing to push ahead.”
Whether what has happened at Site A ultimately amounts to a wildlife offence is a matter for the appropriate authorities and, if necessary, the courts.
But the Government cannot reasonably ignore the evidence now being presented to it.
There are bats at and around Site A. Powerful floodlights have been used at night. Serious questions have been raised about the ecological work underpinning the proposal. Those questions now require answers.
And until they are answered, activity capable of disturbing protected wildlife should be subjected to the closest possible scrutiny.
