Protected species licences: when to include a reasoned statement with your application
Source: gov.uk (2025-07-25)

Use the correct form to explain why your application meets the licence criteria and that there’s no satisfactory alternative to your planned activity.

You need a licence to carry out development activity where there is a protected species. To get a licence, your activity must meet these 3 licensing tests.

There is a purpose for the activity – for example, you need to preserve public health and safety, or there’s an overriding public interest (such as providing housing in an area where shortfalls have been identified).

There is not a satisfactory alternative.

The protected species will not be harmed as a result of the proposed activities.

To confirm how you meet the first 2 licensing tests, you may need to complete a reasoned statement. If you do need a reasoned statement, you will submit this as part of your licence application. Use the reasoned statement to explain the purpose of your activity and provide evidence that there is not a satisfactory alternative.

The third test is covered by the method statement.

Check whether you need to complete a reasoned statement

You must always complete a reasoned statement for the following licences:
- natterjack toad mitigation licence (A44) (https://www.gov.uk/government/publications/natterjack-toads-apply-for-a-mitigation-licence)
- otter mitigation licence (A45) (https://www.gov.uk/government/publications/otters-apply-for-a-mitigation-licence)
- smooth snake and lizard mitigation licence (A46) (https://www.gov.uk/government/publications/smooth-snakes-and-sand-lizards-apply-for-a-mitigation-licence)
- European protected species mitigation licence (A12) (https://www.gov.uk/government/publications/european-protected-species-apply-for-a-mitigation-licence)
For some licences, the requirement for a reasoned statement depends on your planned activity. Check the individual species licence guidance to see whether a reasoned statement is needed. You can find out about reasoned statement requirements in the guidance on how to apply for each of these licences:
- bat mitigation licence (A13) (https://www.gov.uk/government/publications/bats-apply-for-a-mitigation-licence)
- great crested newt mitigation licence (A14) (https://www.gov.uk/government/publications/great-crested-newts-apply-for-a-mitigation-licence)
- great crested newt district level licensing scheme (https://www.gov.uk/government/publications/great-crested-newts-district-level-licensing-schemes-for-developers)
- hazel dormouse mitigation licence (A35) (https://www.gov.uk/government/publications/hazel-dormice-apply-for-a-mitigation-licence)
- water vole mitigation licence (A11) (https://www.gov.uk/government/publications/water-voles-apply-for-a-mitigation-licence-a11) – use the separate reasoned statement form specific to water voles
We are also trialling a water vole strategic licence (https://www.gov.uk/government/publications/water-voles-apply-for-a-strategic-licence). If you apply for a strategic licence, check with Natural England whether you need to include a reasoned statement.

You will need to complete a reasoned statement when applying for a protected species mitigation licence (A05a) (https://www.gov.uk/government/publications/protected-species-apply-for-a-mitigation-licence-a05-and-a05a) for overriding public interest. Use the separate reasoned statement form specific to this licence.

Complete the reasoned statement

Use the reasoned statement to explain the purpose of your activity and to provide evidence that there is not a satisfactory alternative.

Include the reasoned statement as part of your licence application pack. The application pack should include:

application form

reasoned statement (if needed)

method statement

any accompanying documents

The reasoned statement form you complete will depend on the species affected and the purpose of your activity.

Check you’re using the correct form

If you need to complete a reasoned statement, use the correct form based on the purpose of your activity and the species affected.

For water vole licence applications, including the water vole strategic licence, use the water vole reasoned statement for overriding public interest (https://www.gov.uk/government/publications/water-voles-apply-for-a-mitigation-licence-a11).

There are 2 types of reasoned statements on this page for European protected species (EPS):

preserving public health and safety

overriding public interest

Use the relevant one of these 2 reasoned statements for EPS, including:

bats

great crested newts

hazel dormice

natterjack toads

otters

smooth snakes and sand lizards

species covered by the A12 licence (https://www.gov.uk/government/publications/european-protected-species-apply-for-a-mitigation-licence)

For A05a licence applications for other protected species, use the A05a reasoned statement for overriding public interest (https://www.gov.uk/government/publications/protected-species-apply-for-a-mitigation-licence-a05-and-a05a).