Tim Goodwin was brought in by Christopher Katkowski QC to replace the existing ecologists to deal with key issues upon which the refusal notice centred. The site was a mixed plantation woodland with a range of ecological and biodiversity quality. Bats were an important consideration particularly given the presence of the specialist woodland bat, the Barbastelle. Objectors to the scheme included Natural England, Norfolk Wildlife Trust and the Local Planning Authority. A significant programme of survey and assessment was undertaken in order to refute the points raised by objectors including detailed bat work using triple height mist nets. Tim Goodwin gave oral evidence at the Inquiry on behalf of the Appellant and the Inspector subsequently granted consent with conditions.