Loading...
HomeMy WebLinkAbout2560400 - F.I. Received Doc. - Ecological Impact Assessment: Appendix : : Bat Mitigation & Monitoring Plan Clones Single Wind Turbine Ecological Impact Assessment Appendix 1: Bat Mitigation & Monitoring Plan Doherty Environmental Consultants Ltd. August 2026 RECEIVED: 04/09/2026 Clones SWT i Clones Single Wind Turbine Bat Mitigation & Monitoring Plan Document Stage Document Version Prepared by Final 1 Pat Doherty MSc, MCIEEM RECEIVED: 04/09/2026 Clones SWT ii Contents 1.0 INTRODUCTION.................................................................................................................... 1 2.0 BMMP AIMS ........................................................................................................................... 2 2.1 PURPOSE OF THE BMMP ....................................................................................................... 2 2.2 BMMP OBJECTIVES ............................................................................................................... 2 2.3 LEGISLATION & POLICY CONTEXT ........................................................................................ 2 3.0 OVERVIEW OF BAT ECOLOGY AT CLONES SINGLE WIND TURBINE ................ 4 4.0 BAT ACTIVITY MONITORING .......................................................................................... 5 4.1 MONITORING DURATION ....................................................................................................... 5 4.2 MONITORING OBJECTIVES ..................................................................................................... 5 4.3 MONITORING METHODOLOGY ............................................................................................... 5 4.3.1 Overview .................................................................................................................................... 5 4.3.2 Static Bat Detectors ................................................................................................................... 6 4.3.3 Weather & Operational Data .................................................................................................... 7 5.0 BAT CARCASS MONITORING ........................................................................................... 8 5.1 MONITORING DURATION ....................................................................................................... 8 5.2 MONITORING OBJECTIVES ..................................................................................................... 8 5.3 SEARCH METHODOLOGY....................................................................................................... 8 5.3.1 Survey Personnel ....................................................................................................................... 8 5.3.2 Search Area ................................................................................................................................ 8 5.3.3 Class Conditions in Search Plots ............................................................................................... 9 5.3.4 Search Frequency ...................................................................................................................... 9 5.3.5 Search Method ......................................................................................................................... 11 5.3.6 Carcass Persistence and Searcher Efficiency Trials ............................................................... 12 5.4 MORTALITY THRESHOLDS ................................................................................................... 13 5.5 ANALYSIS OF MONITORING DATA ....................................................................................... 15 6.0 REPORTING ......................................................................................................................... 16 6.1 REPORT CONTENT................................................................................................................ 16 6.2 CONSULTATION ................................................................................................................... 16 7.0 ADAPTIVE MITIGATION .................................................................................................. 18 7.1 BLADE FEATHERING ............................................................................................................ 18 7.2 CURTAILMENT ..................................................................................................................... 18 7.3 HABITAT MANAGEMENT ...................................................................................................... 19 7.4 ADDITIONAL MONITORING .................................................................................................. 20 RECEIVED: 04/09/2026 Clones SWT iii 7.5 SIGNIFICANT MORTALITY EVENTS ...................................................................................... 20 8.0 REVIEW OF BMMP ............................................................................................................. 22 8.1 ANNUAL REVIEW ................................................................................................................. 22 8.2 FIVE-YEAR REVIEW ............................................................................................................. 22 8.3 EXTENSION/MODIFICATION OF BMMP ............................................................................... 22 9.0 ROLES AND RESPONSIBILITIES .................................................................................... 24 9.1 APPLICANT RESPONSIBILITIES ............................................................................................. 24 9.2 ECOLOGICAL CLERK OF WORKS / ECOLOGICAL CONSULTANT .......................................... 24 10.0 CONCLUSION ...................................................................................................................... 25 APPENDIX 1: FATALITY THRESHOLD CALCULATION TOOL .......................................... 28 RECEIVED: 04/09/2026 Clones SWT 1 1.0 INTRODUCTION This Bat Mitigation and Monitoring Plan (BMMP) has been prepared to accompany the Ecological Impact Assessment (EcIA) for the Clones Single Wind Turbine (the “Proposed Development”). The purpose of this BMMP is to set out the measures that will be implemented to avoid and minimise adverse effects to local bat populations during the operational phase as well as to monitor bat activity such that adaptive mitigation measures can be implemented as necessary. The BMMP has been developed in accordance with the findings of the bat surveys set out in the EcIA and provides a framework for the implementation, management and verification of mitigation measures throughout the lifetime of the Proposed Development. The BMMP has been prepared with due regard to the requirements of the Wildlife Act 1976 (as amended) and current best-practice guidance, including Northern Ireland Environmental Agency (NIEA) Natural Environment Division (NED) Guidance on Bat Surveys, Assessment and Mitigation for Onshore Wind Turbine Development in Northern Ireland (NIEA, 2026) and Bat Conservation Ireland’s Bat Survey, Assessment and Mitigation Guidelines for Onshore Wind in Ireland (2026). The BMMP should be read in conjunction with the EcIA, which presents the baseline ecological surveys, impact assessment and mitigation strategy for the Proposed Development. The mitigation measures contained within this BMMP are based upon the baseline survey findings, including bat activity surveys, habitat assessments and roost suitability assessments, together with an evaluation of the potential risks associated with habitat loss, disturbance, displacement, barrier effects and collision mortality. The BMMP also establishes the post-construction monitoring requirements necessary to verify the effectiveness of the proposed mitigation, facilitate adaptive management where required, and demonstrate compliance with relevant statutory obligations. Implementation of this BMMP will be the responsibility of the Applicant and its appointed contractors, with ecological oversight provided by a suitably qualified and experienced bat ecologist. RECEIVED: 04/09/2026 Clones SWT 2 2.0 BMMP AIMS 2.1 PURPOSE OF THE BMMP This BMMP has been prepared to support the operational phase of the Proposed Development. The purpose of the BMMP is to establish a robust framework for operational phase monitoring of bat activity and bat mortality, and to define an adaptive mitigation strategy to ensure that the wind farm operates in accordance with relevant wildlife legislation, planning conditions, and current best-practice guidance. This BMMP has been prepared in order to satisfy requirements for operational phase protection and monitoring of bat species at the Proposed Development site. This BMMP establishes the minimum required mitigation and monitoring, and shall be updated following any grant of permission for the Proposed Development to take on board the requirements as may be identified by any associated planning conditions or informative. 2.2 BMMP OBJECTIVES The objectives of this BMMP are to: • Monitor operational phase bat activity across the Proposed Development site over a period of five years; • Monitor bat mortality through systematic carcass searches at all turbine locations over a period of five years; • Assess whether turbine operation is resulting in significant adverse effects on bat populations; • Provide annual monitoring reports to the planning authority; • Establish adaptive mitigation and contingency measures where required, including turbine curtailment; and • Provide mechanisms for periodic review of monitoring and mitigation measures. 2.3 LEGISLATION & POLICY CONTEXT The monitoring and mitigation measures outlined within this BMMP have been developed with reference to the following legislation and guidance: • Wildlife Act 1976, (as amended); RECEIVED: 04/09/2026 Clones SWT 3 • Chartered Institute of Ecology and Environmental Management (CIEEM) guidance; • NIEA NED’s Guidance on Bat Surveys, Assessment and Mitigation for Onshore Wind Turbine Developments in Northern Ireland; • Bat Conservation Ireland guidance on bats and onshore wind turbines; • NatureScot guidance on bats and onshore wind turbines; • EUROBATS Publication Series guidance; • Bat Conservation Trust (BCT) survey guidance. RECEIVED: 04/09/2026 Clones SWT 4 3.0 OVERVIEW OF BAT ECOLOGY AT CLONES SINGLE WIND TURBINE The Proposed Development site is located within a rural landscape in Co. Monaghan and is dominated by a grassland habitats with blocks of conifer plantation also occurring. Baseline ecological surveys (refer to EcIA Section 4.4.2) identified the following bat taxa as active at the Proposed Development site: • Common pipistrelle (Pipistrellus pipistrellus); • Soprano pipistrelle (Pipistrellus pygmaeus); • Leisler’s bat (Nyctalus leisleri); Activity was high for these three species throughout the monitoring period according to the Kepel (2011) bat activity classification adapted for Ireland. During the 2025 monitoring the following results were identified: • A total of 4,888 bat passes were recorded. lowland blanket bog • Activity dominated by Common pipistrelle and Leisler's bat, followed by Soprano pipistrelle. Myotis species, Nathusius pipistrelle and brown long-eared bat were not recorded during the monitoring session, although the proposed development lies with the range of these species in Ireland. The lesser horseshoe bats were not recorded during the baseline surveys and the proposed development lies outside the range of this species in Ireland. Leisler's bat, Common pipistrelle and Soprano pipistrelle have been identified as high-risk species to collision with turbines by NatureScot and the NIEA in their published guidance’s for the assessment of bats at onshore wind energy developments. As such the presence of these species at the Proposed Development site, at high levels of activity, has triggered the need for the provision of this BMMP. The monitoring and adaptive mitigation strategy described below has been designed to account for the potential susceptibility of these species to collision risk and barotrauma associated with wind turbine operation. RECEIVED: 04/09/2026 Clones SWT 5 4.0 BAT ACTIVITY MONITORING 4.1 MONITORING DURATION Post-construction bat activity monitoring shall be undertaken annually for a period of five years following commissioning of the wind farm. Monitoring Year 1 shall commence during the first full bat activity season following turbine commissioning. The bat activity season shall comprise the period of the year from April to October inclusive, subject to prevailing weather conditions. 4.2 MONITORING OBJECTIVES The objectives for the operation phase activity monitoring are to: • Quantify bat activity levels across the operational wind farm; • Assess patterns of bat activity in relation to turbine operation; • Identify species composition and temporal patterns of activity; • Identify any spatial concentration of activity; • Inform assessment of collision risk; • Inform adaptive mitigation where required. 4.3 MONITORING METHODOLOGY 4.3.1 Overview Monitoring shall be undertaken by suitably qualified and experienced bat ecologists. The methodology shall accord with current best practice guidance available at the time of survey, including relevant guidance published by the NIEA, NatureScot, Bat Consesrvation Ireland, Bat Conservation Trust and EUROBATS. Monitoring shall comprise a combination of: RECEIVED: 04/09/2026 Clones SWT 6 • Static automated bat detectors; • Weather data collection; • Turbine operational data review. 4.3.2 Static Bat Detectors Static full-spectrum automated bat detectors shall be deployed annually throughout the five- year monitoring period. 4.3.2.1 Detector Locations A representative sample of detector locations shall be selected to include: • One at the Turbine base; • Detector at turbine blade-sweep height locations where feasible; Control points will be provided as part of the monitoring. The control points will be located outside of the 87m bat buffer implemented as part of the proposed development. Two no. static detector control points will be selected, one along the reamining boundary of the conifer plantation to the west of the proposed turbine and bat buffer and the second along the hedgerow adjacent to the ruined structure to the southeast of the proposed turbine location. 4.3.2.2 Survey Effort Static detector monitoring shall include: A minimum of 10 consecutive survey nights per season i.e. Spring, Summer and Autumn; Monitoring will be completed between April and October inclusive, with spring monitoring to be completed between April and May; summer monitoring to be completed between June and August; and Autumn monitoring to be completed between September and October; Detectors shall be programmed to record bat activity nightly during monitoring sessions, commencing at 30 minutes before sunset to 30 minutes after sunrise. RECEIVED: 04/09/2026 Clones SWT 7 4.3.3 Weather & Operational Data Meteorological and turbine operational data shall be collected concurrently with bat monitoring sessions. Data shall include: • Wind speed; • Temperature; • Rainfall; • Humidity; • Turbine operational status; • Rotor speed; • Curtailment periods, if any during the monitoring session. This information shall be used to assess relationships between bat activity, weather conditions and operational parameters. RECEIVED: 04/09/2026 Clones SWT 8 5.0 BAT CARCASS MONITORING 5.1 MONITORING DURATION Bat carcass searches shall be undertaken at the operational turbine for a period of five years following commissioning in accordance with the NatureScot guidance, Eurobats Publication no 6, and the NIEA NED guidance updated in July 2026, or any subsequent updated guidance. 5.2 MONITORING OBJECTIVES The objectives of carcass monitoring are to: • Identify turbine-related bat mortality; • Determine species affected; • Assess temporal and spatial mortality patterns; • Inform adaptive mitigation and operational management. 5.3 SEARCH METHODOLOGY 5.3.1 Survey Personnel Searches shall be undertaken by suitably qualified ecologists experienced in bat carcass detection. Search personnel shall be trained in: • Carcass identification; • Search protocols; • Biosecurity procedures; • Data recording. 5.3.2 Search Area Searches shall be conducted around the operational turbine. The search radius shall extend to at least 50 metres from the turbine base, i.e. an approximate search area of 100m x 100m grid centred on the turbine. RECEIVED: 04/09/2026 Clones SWT 9 Prior to the commencement of the survey transect lines shall be drawn using Arc GIS within the search plot for the turbine. Transects will be drawn 5m apart within the search plot with a total of 20 transects per turbine search plot, however, in vegetation which is hard to search (e.g. tall heather) this width should be reduced accordingly. All transects will be aligned on an east to west axis in the turbine search plots. Each transect shall be numbered. All transects will be made available on ESRI Field Maps (or similar) to facilitate use of transect by searcher in the field. 5.3.3 Class Conditions in Search Plots There is evidence that search efficiency is influenced by the height and type of vegetation (Morrison 2002). As such conditions on the ground will be reviewed during a search plot assessment prior to the commencement of the bat carcass monitoring and the first search of each monitoring year. The “searchability class” of ground cover within the turbine search plot shall be recorded in line with Limpens et al (2013) using the following descriptions: 1. Bare: paved, bare ground, thin, low vegetation with a cover of less than 10%; vegetation lower than 20cm 2. Half covered: grass-like or herb vegetation; cover 10 – 75%; vegetation lower than 20cm. 3. Completely covered: grass-like or herb vegetation; cover > 75%, vegetation higher than 20cm but lower than 50cm. 4. Too densely covered/inaccessible: herb vegetation higher than 50cm; thicket and bushes, hedgerows, wooded area, crops not to be damaged, deposit of stones/boulder rock, open water or wetland. The search plot ground conditions shall be inputted into a GIS database and searchability class maps shall be prepared for the turbine search plot. 5.3.4 Search Frequency Search frequency shall follow the NIEA NED July 2026 guidance, which states: ‘Carcass searches should be split into blocks of survey effort within which regular searches take place. Searches should take place every 2-4 days within each survey block with one search RECEIVED: 04/09/2026 Clones SWT 10 every two days the recommended frequency for most sites. However, sites with high levels of carcass removal through predation or scavenging may require daily searches. There should be no more than 4 days between each search. Survey blocks should be between 5 and 10 days with the minimum number of searches within each block being 3. For example, in a 10 day survey block: • a search every 2 days = total of 5 searches (day 1, day 3, day 5, day 7, day 9) • a search every 3 days = total of 4 searches (day 1, day 4, day 7, day 10) • a search every 4 days = total of 3 searches (day 1, day 5, day 10) Survey blocks should cover at least two seasons (including summer) on low risk single turbine sites but should cover every season on wind farms and higher risk single turbine sites, with higher coverage during the summer or other high risk period. Carcass searches should be timed to only occur on mornings after a night when there has been favourable weather conditions for bat activity and the wind turbine has been operational.’ The recommended minimum survey effort will be completed in accordance with the details requirements set out for a low risk site as set out in Table 1 of the NIEA NED Guidance Table 1. The extent of this survey effort is set out in Table 5.1 below. RECEIVED: 04/09/2026 Clones SWT 11 Table 5.1: Minimum standards of bat survey effort for wind farms Site Risk Level (taking into account habitat features and records of bats in the area) Low Carcass Searches (Mortality Monitoring) Minimum of 15 carcass searches per turbine across the survey period, covering each season. For example: 3 survey blocks of 10 days, covering each season, with a minimum of 5 evenly spaced searches taking place during each block - e.g. day 1, day 3, day 5, day 7, and day 9. Alternatively: 5 survey blocks of 5 days with a minimum of 3 evenly spaced searches taking place during each block - e.g. day 1, day 3 and day 5.1 5.3.5 Search Method The search method will follow the methods described in the Eurobats guidelines which are as follows: • The searcher shall walk each transect at a slow and regular pace, looking for fatalities within a 2.5m distance either side of each transect line (each transect line will be separated by 5m). • The searcher shall remain alert throughout the search for field signs that may indicate the presence of carcasses. For instance, mobile insects (for example wasps, grasshoppers, flies etc.) are attracted to carcasses. Each search shall start within 30 minutes after sunrise, to minimise removal of carcasses that have appeared during the previous night by daytime scavengers and when the lighting conditions enable any dead bats to be seen. The following shall be recorded: 1 The exact breakdown of carcass search effort can be left up to professional judgement on a site by site basis as long as the total number of searches meets the minimum effort, there is a minimum of 3 searches in each survey block (separated by no more than 4 days) and searches are carried out concurrently with automated surveys. RECEIVED: 04/09/2026 Clones SWT 12 • Species (where identifiable); • Age and sex where possible; • Carcass condition; • Location using GPS; • Distance and bearing from turbine; • Date and time; • Weather conditions. All carcasses shall be photographed and recorded. Where required, carcasses shall be handled in accordance with relevant licensing and biosecurity requirements. 5.3.6 Carcass Persistence and Searcher Efficiency Trials To improve interpretation of mortality data, the following trials shall be undertaken during Years 1 and 2: • Carcass persistence trials; • Searcher efficiency trials. These trials shall be used to estimate carcass detection probability and scavenger removal rates. The requirement for repeated trials in subsequent years shall be reviewed based on findings and agreement with the planning authority. The NIEA NED Guidance provides the following advice to correct for survey biases: ‘…an estimate of carcass removal rates and searcher efficiency should be carried out at each wind turbine site. This will require at least two trained personnel to be involved – the seeker and the tester. Carcass removal trials and searcher efficiency trials can be combined in an integrated trial as they are both time sensitive. Using this method the same test carcasses should be used for both trials and left in place for the duration of the survey period. Further guidance on carcass removal trials, searcher efficiency trials and on the estimation of mortality rates is contained within the NatureScot guidance and Eurobats No.6.’ RECEIVED: 04/09/2026 Clones SWT 13 5.4 MORTALITY THRESHOLDS The following indicative thresholds shall trigger review of mitigation measures: • Repeated mortality events; • Concentrated mortality during specific weather conditions; • Mortality rates exceeding predicted levels; Thresholds may be refined following consultation with the planning authority and statutory consultees. The annual mortality threshold to be applied for this BMMP is based on an adapted use of potential biological removal (PBR) as set out by Frick et al. (2026)2. Frick et al. have published a fatality threshold calculation tool that incorporates modified principles of PBR, general bat reproductive biology, IUCN status, local bat ecology, and facility area to define fatality thresholds for individual wind farms. This tool has been used to calculate the annual fatality threshold for Pipistrelle species and Leisler's bat. Whilst Myotis species and Brown long-eared bat were not recorded during the baseline surveys it is noted that the proposed development is situated within the range of these species in Ireland. As such annual fatality thresholds have also been calculated for these taxa. Table 5.2 sets out the annual fatality thresholds, as calculated using the fatality threshold calculation tool, that will apply for each species during the operation phase of the proposed development. The minimum and maximum bat density estimates used in the model for Pipistrelle species, Myotis species and Brown long-eared bat have been sourced from Frick et al.. It is noted that Leisler's bat population densities in Ireland is substantially higher than in the UK and other parts of Europe. As such for the purposes of calculating PBR fatality thresholds a crude island wide average density derived from population estimates3 has been used to approximate the minimum and maximum densities per km2 for 2 Frick, W. F., Whitby, M., Wilson, D., MacEwan, K. L., Hulka, S., Akre, K. L., & O’Mara, M. T. (2026). A global decision framework for reducing bat fatalities at wind energy facilities. Ecological Solutions and Evidence, 7, e70189. https://doi.org/10.1002/2688-8319.70189 3 Roche, N. & Langton, S. (2024) Population estimates, trends and background information for six Irish bat species. Article 17 reporting 2018 -2023: Supporting document. Unpublished report to RECEIVED: 04/09/2026 Clones SWT 14 Leisler's bat. On this basis the minimum and maximum densities per km2 for Leisler's bat range from 1.6–2.9 individuals/km². Table 5.2: Annual PBR Fatality Thresholds Species PBR Fatality Threshold Pipistrelle species (Pipistrellus pipistrellus, Pipistrellus pygmaeus, Pipistrellus nathusius) 4 Leisler's bat (Nyctalus leisleri) 3 Brown long-eared bat (Plecotus auritus) 2 Myotis Species 1 The fatality threshold calculation tool output table is presented as Appendix 2. It is noted that the calculation of the PBR Fatality Threshold may well evolve during the intervening time period between the finalisation of this BMMP and the commencement of monitoring. As such the Project Bat Ecologist will be responsible for reviewing the above fatality thresholds prior to the commencement of monitoring to confirm their continued applicability or to update in line with current best scientific knowledge. National Parks & Wildlife Service. https://www.npws.ie/sites/default/files/publications/pdf/2018- 2023Art17SupportingDocument_Bats.pdf?utm_source=chatgpt.com RECEIVED: 04/09/2026 Clones SWT 15 5.5 ANALYSIS OF MONITORING DATA Bat calls shall be analysed by an experienced bat ecologist using recognised acoustic analysis software (e.g. Kaleidoscope Project software or other similar software). Analysis shall include: • Identification of bat calls recorded during monitoring to species levels for pipistrelle, noctule and long-eared species; and identification to genus level for Myotis species; • Calculation of the nightly bat activity in terms of bat pass per hour for each night of monitoring; • Calculation of the activity for each species for each monitoring session based on the median bat pass per hour for each session • A description of temporal activity patterns; • A description of spatial distribution of bat activity; • Correlation of bat activity with weather and turbine operational data. RECEIVED: 04/09/2026 Clones SWT 16 6.0 REPORTING An annual monitoring report shall be prepared following completion of each monitoring year. Reports shall be submitted to the planning authority within three months of the end of each monitoring year. 6.1 REPORT CONTENT Each annual report shall include: • Overview of monitoring undertaken; • Survey methodologies employed; • Survey dates and weather conditions; • Bat activity survey results; • Carcass search results; • Species records; • Analysis of activity and mortality trends; • Assessment of turbine-related impacts; • Details of any mitigation measures implemented; • Recommendations for subsequent monitoring years. The report shall also include: • Maps showing detector locations and carcass finds; • Summary tables and appendices; • Raw data where required. 6.2 CONSULTATION Where significant mortality or unexpected impacts are identified, the Applicant shall consult with: • The planning authority; RECEIVED: 04/09/2026 Clones SWT 17 • Northern Ireland Environment Agency (NIEA) Natural Environment Division (NED); • Relevant ecological advisors. Consultation shall determine whether additional mitigation measures are necessary RECEIVED: 04/09/2026 Clones SWT 18 7.0 ADAPTIVE MITIGATION The monitoring programme shall operate within an adaptive management framework. Monitoring findings shall be reviewed annually to determine whether mitigation measures remain effective and proportionate. Where monitoring identifies elevated collision risk or mortality, additional mitigation measures shall be implemented. Options for adaptive mitigation and contingency that will be available as required in order to minimise risk to bats during the operation phase include: • Blade Feathering; • Operation Curtailment; • Habitat Management; and • Additional Monitoring 7.1 BLADE FEATHERING There is evidence that bat casualties at wind farms is reduced by pitching the blades out of the wind (“feathering”) to reduce rotation speeds below 2 rpm while idling. Arnett et al. have reported this reduction to be in the order of 50% when compared with normal idling. In view of this, all turbine blades will be required to be feathered during idling. The implementation of this measure is in line with the current NIEA NED guidelines Guidance on “Bat Surveys, Assessment and Mitigation for Onshore Wind Turbine Developments in Northern Ireland”. 7.2 CURTAILMENT Operational curtailment shall be considered where monitoring identifies significant bat mortality or elevated activity associated with specific operational conditions. Curtailment measures may include: • Increasing turbine cut-in speed during high-risk periods; • Feathering turbine blades below specified wind speeds; • Seasonal shutdown during peak bat activity; • Night-time curtailment under defined weather conditions. RECEIVED: 04/09/2026 Clones SWT 19 Indicative curtailment triggers may include conditions when all the following criteria occur at once: • Low wind speeds; • Temperatures above 10°C; • Low rainfall; • Peak activity periods between sunset and sunrise. Specific curtailment parameters shall be informed by monitoring data and agreed with the planning authority and NIEA. 7.3 HABITAT MANAGEMENT The EcIA has set out a requirement for the implementation of a bat buffer for the operation phase of the proposed development. The following habitat management principles shall apply throughout the operational life of the Proposed Development (35 years): • The turbine buffer zone established around the operational turbine shall be managed to maintain low levels of habitat attractiveness for foraging and commuting bats. Habitat management within this area shall avoid the creation of features that could concentrate bat activity immediately adjacent to turbine blades, including woodland edges, dense scrub, tree planting, wetland habitats, or species-rich linear features. • Areas of forestry removed to accommodate turbine infrastructure and bat buffer distances shall be managed in accordance with the above requirement. Regenerating scrub, self-seeded trees and commercial forestry within the buffer zones shall be monitored and controlled where necessary to maintain the intended separation distance between suitable bat habitat and the operational turbine. • Native hedgerow planting, woodland enhancement and other biodiversity gain measures proposed under the wider habitat management proposed as part of the proposed development have been located and designed to ensure that they do not create new commuting corridors or focal foraging areas that direct bat activity towards the operational turbine. RECEIVED: 04/09/2026 Clones SWT 20 • The Bat surveyor shall liaise with the project ECoW to ensure that habitat restoration and biodiversity enhancement measures remain compatible with bat collision risk mitigation objectives throughout the operational life of the wind turbine. This integrated approach will ensure that habitat management measures are achieved while maintaining an appropriate level of protection for bat populations and avoiding the creation of habitat conditions that could increase collision risk at the operational turbine. 7.4 ADDITIONAL MONITORING Where required, monitoring intensity may be increased through: • Additional detector deployment; • Increased carcass search frequency; and • Thermal imaging or radar surveys; 7.5 SIGNIFICANT MORTALITY EVENTS Where a significant mortality event4 is identified, the following actions shall be undertaken: 1. Immediate notification to the planning authority and NPWS; 2. Review of operational and meteorological conditions; 4 Significant Mortality Event shall be defined as: • Exceedance of any of the species-specific annual fatality thresholds set out in Appendix 1: Table 1; • The discovery of any casualty of a species with an annual fatality threshold of zero within a monitoring year; • The discovery of multiple bat casualties within a single monitoring period indicating a potential collision event associated with particular weather or operational conditions; or • Any mortality event considered by the Project Bat Ecologist to indicate an unexpected or potentially significant impact on bat populations. The above criteria have been developed specifically for the Proposed Development using the species - specific fatality threshold approach set out in this BMMP and do not constitute statutory significance thresholds. RECEIVED: 04/09/2026 Clones SWT 21 3. Assessment of species affected; 4. Implementation of interim mitigation where appropriate; 5. Review and update of the BMMP. RECEIVED: 04/09/2026 Clones SWT 22 8.0 REVIEW OF BMMP 8.1 ANNUAL REVIEW The effectiveness of monitoring and mitigation measures shall be reviewed annually. The review shall consider: • Monitoring results; • Mortality trends; • Effectiveness of mitigation measures; • Advances in guidance and best practice; • Operational changes. Recommendations for modifications to monitoring effort or mitigation measures shall be included within annual reports. 8.2 FIVE-YEAR REVIEW At the conclusion of Year 5, a comprehensive review shall be undertaken. The review shall assess: • Long-term bat activity trends; • Mortality rates; • Effectiveness of mitigation measures; • Need for continued monitoring. 8.3 EXTENSION/MODIFICATION OF BMMP Following the five-year review, the planning authority may require: • Extension of monitoring beyond five years; • Continuation or modification of mitigation measures; RECEIVED: 04/09/2026 Clones SWT 23 • Introduction of additional operational controls. Where monitoring demonstrates consistently low activity and mortality rates, the planning authority may agree to reduce or conclude monitoring requirements. RECEIVED: 04/09/2026 Clones SWT 24 9.0 ROLES AND RESPONSIBILITIES 9.1 APPLICANT RESPONSIBILITIES The Applicant shall: • Ensure implementation of this BMMP; • Appoint suitably qualified ecological consultants; • Facilitate access for monitoring; • Maintain records of operational data; • Implement agreed mitigation measures. 9.2 ECOLOGICAL CLERK OF WORKS / ECOLOGICAL CONSULTANT The appointed Bat Ecologist responsible for undertaking monitoring shall: • Undertake monitoring in accordance with this BMMP; • Analyse survey data; • Prepare annual reports; • Advise on mitigation measures; • Liaise with the planning authority and statutory consultees where necessary. RECEIVED: 04/09/2026 Clones SWT 25 10.0 CONCLUSION This BMMP provides a robust and proportionate framework for operation phase monitoring and management of bat impacts associated with the Proposed Development. The BMMP has been informed by the findings of baseline bat surveys which identified a high level of activity across the monitoring period for Leisler's bat, Common pipistrelle and Soprano pipistrelle . In accordance with relevant guidance for bats and onshore wind energy developments and the precautionary principle, a comprehensive programme of post-construction monitoring and adaptive management will be implemented to verify these conclusions and ensure the continued protection of bat populations. The BMMP commits to five years of post-construction monitoring, incorporating both bat activity surveys and turbine mortality monitoring, together with searcher-efficiency and carcass-persistence trials. This monitoring programme will generate evidence to inform assessment of operational effects and determine whether mitigation measures remain effective throughout the operational monitoring period. The BMMP also establishes a clear adaptive management framework, whereby monitoring results will be reviewed annually and appropriate mitigation measures introduced where required. These measures may include enhanced monitoring, habitat management, turbine blade feathering and operational curtailment. The inclusion of species-specific mortality thresholds and defined intervention triggers ensures that any unforeseen impacts can be identified and addressed at an early stage. Table 10.1 below provides a summary review of monitoring, reporting and mitigation to be completed as part of this BMMP, whilst Table 10.2 provides a summary of the adaptive mitigation framework to be implemented as part of the BMMP. Implementation of the measures set out for this BMMP will: • Ensure compliance with planning conditions, current best-practice guidance and relevant wildlife legislation; • Verify the conclusions of the Bat Assessment and facilitate robust assessment of operational impacts on bats; • Enable adaptive mitigation where required; • Support the protection and conservation of bat populations within the wider landscape. RECEIVED: 04/09/2026 Clones SWT 26 Overall, this BMMP has been developed in accordance with current best practice guidance and incorporates appropriate review mechanisms to ensure that monitoring and mitigation remain proportionate and effective throughout the operational monitoring period for the Proposed Development and ensures that appropriate mechanisms are in place to maintain a low level of risk to bats throughout the project’s operational life. Following the grant of planning permission for the Proposed Development this BMMP shall be updated to incorporate any associated planning conditions and or informatives related to bats. Table 10.1: Summary of BMMP Requirements BMMP Element Year 1 Year 2 Year 3 Year 4 Year 5 Static detector surveys ✓ ✓ ✓ ✓ ✓ Carcass searches ✓ ✓ ✓ ✓ ✓ Searcher efficiency trials ✓ ✓ Review Review Review Carcass persistence trials ✓ ✓ Review Review Review Annual reporting ✓ ✓ ✓ ✓ ✓ Mitigation review ✓ ✓ ✓ ✓ ✓ RECEIVED: 04/09/2026 Clones SWT 27 Table 10.2: Summary of Adaptive Mitigation Framework Monitoring Outcome Potential Response Elevated bat activity at turbine Increased monitoring and operational review Repeated mortality incidents Introduction of turbine curtailment Mortality of high conservation concern species Immediate consultation and enhanced mitigation Seasonal mortality trends identified Seasonal curtailment regime Ineffective mitigation identified Review and revision of mitigation measures RECEIVED: 04/09/2026 Clones SWT 28 APPENDIX 1: FATALITY THRESHOLD CALCULATION TOOL RECEIVED: 04/09/2026 Clones SWT 29 Table 1: Fatality Threshold Calculation Tool Output Recovery Factor (based on IUCN Status) Bat Demographic Inputs for Rmax Project Area and Bat Density Inputs for Estimating Nmin Bat Species IUCN Status Adult Survival Rate Age at First Breeding Rmax F Project Area (km2)* Minimum Bat Density (bat/km2)# Maximum Bat Density (bat/km2) Scaling Factor Nmin PBR Fatality Threshold per Facility Pipistrellus pipistrellus LC (Stable or Increasing) 0.9 1.5 0.24 1 3.14 5.5 18.2 2 32 4 Myotis Species LC (Stable or Increasing) 0.9 1.5 0.24 1 3.14 1 1.8 2 6 1 Plecotus auritus LC (Stable or Increasing) 0.9 1.5 0.24 1 7 1.4 1.66 2 20 2 Nyctalus leisleri LC (Stable or Increasing) 0.9 1.5 0.24 1 7 1.6 2.9 2 22 3 *Note: for this calculation, the Project Area is based on the extent of the core sustenance zone for each species, assuming that the proposed turbine location represents the centre point of the local population’s core sustenance zone #Note: the minimum and Maximum Bat Densities are based on the minimum and maximum density values provided by Table S2 of Frick et al. (2026) and as per Section 5.4 above for Leisler's bats RECEIVED: 04/09/2026