Bats in a church roof and the repair programme

Bats in a church roof do not stop repairs. They change the order in which you do things, and they usually add a survey season to the programme. The sequence that works is survey first, licence second, faculty and contract third, and scaffolding last. The sequence that fails is the one where a contractor is appointed in March for summer works and an ecologist is asked in June whether that is acceptable.

The reason is that ecclesiastical exemption does nothing for you here. The Ecclesiastical Exemption (Listed Buildings and Conservation Areas) (England) Order 2010 relieves certain denominations of the need for listed building consent, provided their own internal control system applies, but wildlife law sits entirely outside it. All bat species are protected, and regulation 43 of the Conservation of Habitats and Species Regulations 2017 makes it an offence to damage or destroy a breeding site or resting place or to disturb bats using one.

Why churches hold significant roosts

Medieval and Victorian church roofs are close to ideal bat habitat. Large uninterrupted voids, stable temperatures under lead or slate, deep timber joints and mortices, and gaps at ridge, verge and tower louvre that give access without predation risk. Many are also surrounded by churchyards with mature trees and unimproved grassland, so the foraging habitat is on the doorstep.

The consequence is that some church roosts are maternity roosts, used by breeding females from around mid-May to late August, and those carry the greatest legal and practical weight. Natterer's and brown long-eared bats are frequently recorded in churches, and both are sensitive to disturbance and to light.

Congregations often discover the roost through droppings on ledges, on the altar or across pews, and the conversation starts as a cleaning problem. It is worth reframing it early as a programme question, because the answers are much easier when they are found a year ahead of the works.

Survey requirements before repair

The survey sequence is standardised and season-bound.

1. A preliminary roost assessment, which can be done at any time of year. An ecologist inspects the roof void, tower, porch and external elevations for droppings, staining, feeding remains and potential access points.
2. Emergence and re-entry surveys where the assessment finds evidence or good potential. These run in the active season, broadly May to September, with the most useful results between May and August.
3. Identification of species, from droppings analysis or from the emergence survey, because the licensing route depends on which species and how many.
4. Hibernation checks in winter where the structure offers hibernation potential, which some crypts and thick-walled towers do.

Two or three visits in a single season are typical where a roost is confirmed, and a single visit is rarely enough to establish roost type or population size. That is the requirement that drives the programme, and it is also the one that grant timetables tend to ignore.

A bat survey is work a licensed ecologist must carry out, because both the survey methods and any subsequent mitigation licence sit under the Wildlife and Countryside Act 1981 and the 2017 Regulations. An AI-drafted document can structure the reporting and the method, and it is a starting point for that ecologist rather than a substitute for the fieldwork.

Licensing where a roost is affected

Where the works will damage or obstruct a roost, or disturb bats using it, a mitigation licence from Natural England is needed before anything starts. Re-roofing is the obvious case, because lifting lead or slate removes the access points and exposes the void.

The licence application has to demonstrate three things: that the work serves an overriding purpose in the public interest or falls within another permitted purpose, that there is no satisfactory alternative, and that the favourable conservation status of the species is maintained. For repair of a listed church in active use, the first limb is usually straightforward to argue. The second and third are where the work goes in.

For works with minor effects on small numbers of common species, a low impact class licence held by a registered consultant can be used, which is substantially quicker than a bespoke licence. A maternity roost of a sensitive species will need the bespoke route, and the determination period for that should be built into the programme rather than hoped away.

Timing works around the season

The workable windows are narrow. Avoid the maternity period, avoid hibernation, and you are left with early spring and early autumn in most years, with the exact dates set by the ecologist on the basis of what the surveys found.

That has real consequences for a repair contract. Lead work in October runs into weather risk. Scaffolding standing over winter costs money and needs to be designed for wind loading. Phasing a roof in bays so that part of the void remains available to bats is often the answer, and it changes the tender documents.

Where the licence permits works during the active season with supervision, an ecologist attends at defined hold points: before stripping, at first exposure of the void, and at reinstatement. Write those attendances into the contract as named events rather than leaving them as a general obligation, because a contractor who has not priced an ecologist's day will not stop for one.

Reconciling ecology with fabric repair

The two disciplines conflict less often than people expect, and where they do the conflicts are specific.

Timber treatment is the sharpest one. Some traditional insecticidal treatments are toxic to bats, so a specification has to use products and application methods the ecologist accepts, and the dates of application matter as much as the chemistry. Breathable membranes are another: certain woven membranes trap bats by the claws, and a bat-safe specification is needed where a roost is present.

Then there is access. A reinstated roof has to retain the bats' access points, which means agreed gaps at ridge, verge or louvre rather than the fully sealed detail a roofer would otherwise produce. Lighting a newly floodlit tower can sever a flight line even where the fabric is untouched. And dust and vibration from stonework repairs need managing during sensitive periods.

Record the significance of the building and the effect of the works in a Heritage Statement even where ecclesiastical exemption removes the need for listed building consent, because the internal control system will want the same analysis and the funding bodies will ask for it. Our note on internal alterations that harm significance covers how that assessment is structured.

Funding and programme consequences

Bat work adds cost in three places: the surveys themselves, the licence application and supervision, and the programme extension that arises from the seasonal window. None of it is optional, and all of it is easier to fund when it appears in the first cost plan rather than as a variation.

Grant funders generally accept ecological survey and mitigation as eligible repair costs, and the Listed Places of Worship Grant Scheme has historically allowed VAT on eligible repair works to be reclaimed. That scheme has been extended and revised several times, so check the current rules and the claim limits before relying on it. Our note on heritage at risk, grants, repairs notices and urgent works sets out the wider funding and enforcement picture for buildings in poor condition.

Who to appoint and when

Start with two appointments, eighteen months before you want scaffolding up. A licensed ecologist, engaged in autumn or winter so that the preliminary roost assessment happens before the survey season opens. And the church's own architect or surveyor, whose quinquennial inspection report is the basis of the repair schedule and who will coordinate the faculty or internal consent process.

Bring the contractor in later, with the ecological constraints already written into the specification. That order costs less and produces a better building. Reviewers and specialists who sign off ecological and heritage documents can be found through the professional directory.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.