Imperiled Bats in Kentucky
Kentucky is home to four bat species that are federally listed under the Endangered Species Act (ESA), each playing a vital role in the state’s ecosystems. The Indiana bat (Myotis sodalis), northern long-eared bat (Myotis septentrionalis), gray bat (Myotis grisescens), and Virginia big-eared bat (Corynorhinus townsendii virginianus) are all federally listed as endangered. In addition, the tricolored bat (Perimyotis subflavus) was recently proposed for listing as endangered, and the little brown bat (Myotis lucifugus) and hoary bat (Lasiurus cinereus) are included on the most recent U.S. Fish and Wildlife Service (Service) Listing Plan as species to be considered for listing. These species face a range of threats including habitat loss, human disturbance, cave modifications, wind turbine mortality, and the devastating effects of white-nose syndrome—a fungal disease that has caused significant population declines. All species, with the exception of the hoary bat, rely on caves for winter hibernation in Kentucky, though their summer roosting habits vary: Indiana and hoary bats typically use trees; gray and Virginia big-eared bats often remain in caves and cave-like habitats; northern long-eared and tricolored bats use both trees and caves; and little brown bats use trees but are also commonly found roosting in human-made structures. Conservation efforts in Kentucky, led by agencies such as the Service’s Kentucky Field Office (KFO) and the Kentucky Department of Fish and Wildlife Resources, include habitat protection, cave gating, and population monitoring to support the recovery of these imperiled species.
Generally, it is easier for development activities to avoid and minimize effects to cave-obligate species (i.e., Virginia big-eared and gray bats) than it is tree roosting species. As a result, project proponents can typically address potential effects to the gray and Virginia big-eared bats from a proposed project through informal consultation with the KFO. Informal consultation for these species can often be completed through the State-Wide Determination Key on the Service’s Information for Planning and Consultation website.
Potential effects to tree-roosting species are typically more difficult to avoid and minimize due to the frequent need for development activities to remove trees. Variations within the group of tree roosting bats, with some species roosting in foliage of trees (e.g., tricolored and hoary bats), while others roost under exfoliating bark or within cracks and crevices (e.g., Indiana, northern long-eared, and little brown bats), can also influence the risks to bats from development activities. Activities that result in the removal of forested habitat, such as land clearing, utility line construction and maintenance, and road construction and maintenance, can cause the loss, degradation, and fragmentation of natural habitats. Additionally, activities such as surface disturbances related to coal mining operations, forest management, and timber harvest can have similar impacts. Such impacts have the potential to adversely affect federally listed, forest-dwelling bat species, especially the Indiana and northern long-eared bats.
Actions with a federal nexus proposed in areas with: 1) suitable habitat for the Indiana and northern long-eared bats, and 2) either presence or assumed presence of these species require project proponents to determine if adverse effects are likely and, if so, how they can be avoided, minimized, or mitigated.
If avoiding all likely adverse effects to a federally listed bat species isn’t possible, project proponents must take steps to ensure compliance with the ESA and avoid an illegal of the species. “Take” of federally threatened or endangered animals means “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct” and is prohibited under Section 9 of the ESA. Violations of the ESA can lead to civil and/or criminal penalties. In general, project proponents have three primary options to address potential adverse effects to listed bats:
- Surveying.
Federal agencies can consult with the Service under section 7(a)(2) of the ESA.
- When federal agencies are not involved, proponents can pursue an Incidental Take Permit pursuant to section 10(a)(1)(B) of the ESA.
Surveying for the Indiana Bat and/or Northern Long-Eared Bat in Kentucky
Anyone wishing to survey for Indiana and/or northern long-eared bats in Kentucky should follow the current survey guidance and have all necessary permits (see links immediately below). Surveys to determine presence or probable absence of these species may not be conducted within the inner tier of known habitat for that species. Please refer to maps of known habitat for the Indiana bat and northern long-eared bat in Kentucky for additional information (see supporting documents section below).
Range-Wide Indiana Bat and Northern Long-Eared Bat Survey Guidelines
If an approved survey documents the probable absence of Indiana and northern long-eared bats, the project proponent may assume the action is not likely to adversely affect the two species and request concurrence from the Service under ESA or proceed without further work/coordination under ESA Section 10. If presence of Indiana and/or northern long-eared bats is confirmed during the survey or assumed to be present, the project is likely to adversely affect the species and requires additional work/coordination with the Service under ESA Sections 7 or 10 to ensure compliance.
ESA Compliance Options for the Indiana Bat and/or Northern Long-Eared Bat
The KFO provides both traditional and recovery-focused conservation options to proponents seeking ESA compliance for proposed projects resulting in adverse effects to the Indiana and/or northern long-eared bat.
Traditional Compliance Options
Traditional compliance options include formal consultation under Section 7 of the ESA for federal agencies and development of a Habitat Conservation Plan under Section 10 of the ESA for non-federal project proponents.
Formal Consultation under ESA Section 7
Formal consultation only applies when federal agencies are involved and may be best suited for larger federal actions, though this option is applicable to any project that anticipates adverse effects to a listed species or critical habitat. During formal consultation, the federal agency and Service share information about the proposed project and the species or critical habitat likely to be affected. The federal agency makes an effects determination, and the Service prepares a biological opinion that evaluates the consequences of the action as related to any listed species or critical habitat.
For more information on the formal consultation process see: eCFR :: 50 CFR 402.14 -- Formal consultation.
Habitat Conservation Plan under ESA Section 10
A Habitat Conservation Plan (HCP) is best suited for non-federal activities conducted by state or local agencies, non-federal landowners, and private companies. The HCP is a planning document designed to accommodate economic development to the extent possible by authorizing the take of listed species when it occurs incidental to otherwise lawful activities. HCPs can address non-federal activities that cross state lines or involve multi-year projects in areas where listed species occur and may be impacted.
For more information on Habitat Conservation Plans see: Habitat Conservation Plans | U.S. Fish & Wildlife Service
Recovery-Focused Conservation Options
Recovery-Focused Conservation Options (RFCOs) are included in our Revised Conservation Strategy for Forest-Dwelling Bats in the Commonwealth of Kentucky (Strategy) (2025, v3.0; also see supporting documents section below). RFCOs provide tangible conservation benefits that support recovery of the Indiana and northern long-eared bats, while providing flexibility, efficiencies, cost savings, and/or project predictability benefits to the project proponent. Implementation of the RFCOs is supported by the KFO’s programmatic biological opinion, Biological Opinion: Kentucky Field Office’s Revised Conservation Strategy for Forest-Dwelling Bats in the Commonwealth of Kentucky (2025; also see supporting documents section below). The RFCOs are applicable when an action will remove suitable forested habitat for Indiana and/or northern long-eared bats in a manner that is reasonably certain to cause adverse effects.
Election of an RFCO is at the proponent’s discretion based on the specific needs or circumstances of their action. Proponents should coordinate with the KFO when determining which option best fits their needs prior to taking any irreversible action or making a final decision.
Range-Wide Indiana Bat Guidelines for Surface Mining
Coal mining actions in Kentucky are evaluated using the procedures outlined in the Range-Wide Indiana Bat Protection and Enhancement Plan Guidelines (also see supporting documents section below). These guidelines were developed by a team comprised of the Service, Office of Surface Mining, Reclamation, and Enforcement, and a group of Regulatory Authorities representing the Interstate Mining Compact Commission. These guidelines aid coal mining applicants in understanding the options and protocols associated with assuring compliance with the 2020 Biological Opinion (also see supporting documents section below) on implementation of the Surface Mining Control and Reclamation Act (SMCRA). Please refer to Known Indiana Bat Habitat in Kentucky and within 20 miles (also see supporting documents section below).
Until northern long-eared bat–specific protection and enhancement guidelines are developed, the Service recommends applicants address potential adverse effects to the northern long-eared bat using the guidelines for the Indiana bat. While the Service recognizes this will provide a certain level of protection to the northern long-eared bat, applicants should use the definitions of suitable northern long-eared bat habitat to evaluate whether habitat is present within the to minimize the potential for incidental take. Please refer to Appendix A of the Range-Wide Indiana Bat and Northern Long-Eared Bat Survey Guidelines for definitions of habitat and Known Northern Long-eared Bat Habitat in Kentucky and within 20 Miles (also see supporting documents section below).
Coal mining applicants should refer to these guidelines, the Kentucky Department of Natural Resources, and the KFO when addressing the Indiana bat and northern long-eared bat for coal mining actions in Kentucky. Coal mining applicants should also be aware that when Indiana bat and/or northern long-eared bat surveys are proposed, the most current version of the Service’s Range-Wide Indiana Bat and Northern Long-Eared Bat Survey Guidelines must be used for the survey results to be considered valid.
