21st December 2012

Parish churches are treasured places of worship and enduring features of our landscape. Since many churches house bat roosts, churches are also important to bat conservation. Bat populations suffered huge declines in the last century, as important features of our landscape were lost or degraded and consequently all bats and their roosts in Great Britain are protected by law (The Conservation of Habitats and Species Regulations 2010 and the Wildlife and Countryside Act 1981 (as amended)). Churches have been constant features, and the only national survey (Sargent 1995), concluded that at least 60% pre-16th Century churches could have roosting bats. At least 8 species of bat are known to roost in church buildings, including some of our rarer species and some churches have provided sanctuary over many generations. The Bat Conservation Trust (BCT) values the contribution made to society by the many churches that support or tolerate the conservation of bats, and by doing so set a good example of how individuals and communities can help to care for the natural world and reverse biodiversity declines.

The Bat Conservation Trust recognises that in some cases, the presence of bats can be very problematic for those who use or maintain church buildings, and that integrating the protection of bats into the care of church buildings can be challenging, especially for small or under-resourced communities. Although many churches may be unaware of the presence of small numbers of bats, some churches that host large bat roosts experience a range of challenges due to the presence of bats. These include people being discouraged or prevented from using and enjoying the church for worship or community activities because of an unpleasant or unclean environment; difficulty in maintaining their historic buildings and the contents, and cleaning and protecting heritage objects. Although this is very distressing, it is often possible to find solutions to address or alleviate such problems, given the right support, and the willingness to find a solution that helps both people and bats. BCT wants to ensure that all churches that have bat roosts, have the advice and support they need to enable people and bats to thrive together. The Bat Conservation Trust is working with Natural England, Church of England and through several research projects, to improve the guidance, support and options available for churches.

The Bat Conservation Trust is very sympathetic to the congregation of St Hilda's, Ellerburn and we recognise that they have struggled to cope with the impact of a regionally important colony of Natterer's bats over a long period of time. We understand that this case is particularly challenging and that Natural England, North Yorkshire Bat Group and Church of England have devoted considerable time and financial resources to resolving the issues at St Hilda's. In most cases, it is possible to work towards solutions that support both people in the church community and bat populations. In some cases there have been requests to remove bats or prevent bats from roosting, however this can put bats at risk, and damage bat populations. Bats should not be prevented from roosting (excluded) in churches except where all other options have been exhausted and the conservation status of the bats will not be affected. Natural England has a legal responsibility to provide adequate protection to the bats of St Hilda's and to ensure that the continued favourable conservation status is upheld. We urge Natural England to ensure that all options that allow both people and bats to co-exist are adequately explored and that Natural England consults with all relevant stakeholders. The Bat Conservation Trust will contest any proposal that is considered to undermine bat conservation efforts locally or nationally and which does not benefit people and bats.

Natural England's current proposal for work at St. Hilda's is outlined in a tender advertisement in an area viewable by organisations that register online on Natural England's e Sourcing Portal https://naturalengland.bravosolution.co.uk (please contact Natural England for details). We believe the proposal is unlikely to provide an effective solution for the church community or bats, and has the potential to damage bat conservation. We are particularly concerned that Natural England are considering an option to exclude bats (i.e. prevent bats from using their roost), without first exploring all other options, putting an important bat population at risk. North Yorkshire Bat Group has suggested that a false ceiling in the church would allow the bats to remain in their current roosts, and resolve the problems with droppings and urine that the congregation are experiencing. Natural England should ensure that the viability of this option is fully explored. The information to support a licensing decision on exclusion at St Hilda's is incomplete, and the process as outlined does not allow sufficient time to gather the evidence needed to prove exclusions would not harm bat populations. Similarly the process allows little time to explore satisfactory alternatives to excluding bats. Currently the alternative roosting sites constructed around Ellerburn have not been proved to be used by bats. We are concerned that allowing an exclusion in these circumstances will set a precedent that could lead to applications for similar exclusions of bat colonies from other buildings such as developments.

The Bat Conservation Trust strongly urges Natural England to re-evaluate its proposals and the time-frame in which it seeks to apply them. Natural England should ensure that alternative options to exclusion, which might allow the congregation to co-exist with its regionally significant Natterer's bat population, as well as reducing the risk of a failed exclusion, are explored fully.

Natural England should ensure there will be sufficient evidence to support the decision on whether favourable conservation status (FCS) of the Natterer's bat population can be maintained by the licensed action. No evidence of how bats use alternative roosts or the surrounding habitat has been gathered at the church, despite the history of problems. Natural England should study how the bats use the area throughout the active season before making any decisions. The Bat Conservation Trust has seen no clear evidence on the suitability of the alternative artificial roosts in the lych-gate and neighbouring barn. Natural England should seek to ensure that all factors that might impede the use of these alternatives are addressed before any exclusion is licensed. Natural England's own guidelines state that evidence of the use of replacement alternative roosts should be established prior to exclusion. The Bat Conservation Trust has already raised our concerns with Natural England and is prepared to make a formal complaint and explore further options. We have requested that Natural England keep us informed of the basis on which the FCS assessment is made, and the details of any future contractor's proposal, as soon as available.

Previous experience has shown that local volunteers, congregations, church users and conservation groups and ecologists can work together to find solutions that meet the needs of people and bats, we urge all parties involved to strive for a lasting solution that allows bats and people to live together.