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From: Costain, Sophie (DEFA) To: DEFA, Planning; Sinden, Thomas Subject: PA 26/00134/CON - Registered Building Consent for internal and external repair and restoration works -
RB14, St Runius Church, Garth Road, Crosby Date: 31 March 2026 13:27:16
Attachments: image001.png P3310195.JPG P3310194.JPG
Good afternoon
RE: PA 26/00134/CON - Registered Building Consent for internal and external repair and restoration works - RB14, St Runius Church, Garth Road, Crosby
Response on behalf of the Ecosystem Policy Team General Stance Objection due to lack of information Detailed Comments
Please accept the Ecosystem Policy Team’s late response to this application.
A member of the team undertook a site visit to Old St Runius Church this morning to look at the potential for bats, where we identified a small number of a bat droppings in the interior of the church and multiple potential entry points for bats because of the missing mortar around the exterior walls. The proposed work therefore has the potential to damage bats and their roosting spaces or obstruct access to roost spaces, which would be offences under the Wildlife Act 1990.
The Ecosystem Policy Team therefore request that the applicant obtains a preliminary assessment for roosting bats by a suitably qualified ecological consultancy, and submits a report detailing the findings, alongside appropriate avoidance and mitigation measures, to Planning prior to determination of this application. This should be accompanied by at least 2 summer dusk emergence surveys.
Bat surveys are required to identify the species of bat utilising the property, their abundance and whether they are breeding and this will determine the mitigation required. Bat surveys should be undertaken in accordance with the Bat Conservation Trust’s Bat Surveys for Professional Ecologists – Good Practice Guidelines, 4th edition (2024).
Submission of survey reports prior to determination of applications is in line with UK best practice guidelines, as referred to in Section 9.2.4 of the British Standard Biodiversity - Code of Best Practice for Planning and Development (BS 42020:2013), which states:
“The presence or absence of protected species, and the extent to which they could be affected by the proposed development, should be established before planning permission is granted; otherwise all material considerations might not have been considered in making the decision. The use of planning conditions to secure ecological surveys after planning permission has been granted should therefore only be applied in exceptional circumstances, such as where original survey work will need to be repeated because the survey data might be out of date before commencement of development, etc.”
Potential Conditions Should this application be approved without this assessment, we recommend that
a condition is secured for:
No works to commence unless a preliminary assessment for roosting bats, alongside at least 2 summer dusk surveys, have been undertaken by a suitably qualified ecological consultancy and a report/s details the findings have been submitted to Planning and approved in writing. Should bats be found, an ecological mitigation plan must also be provided which details how the recommendations within the preliminary assessment and any additional surveys are to be implemented on site.
Best wishes
Department of Environment, Food & Agriculture, Thie Slieau Whallian, Foxdale Road, St Johns, Isle of Man, IM4 3AS Website: www.gov.im/defa Tel +44 (0)1624 685963 | Mob +44 (0)7624 431301 | Email [email protected] Ecosystem Policy Team Tel +44 (0)1624 651577 | Email [email protected] DEFA - working for a clean, safe, healthy, attractive and vibrant environment which will be enjoyed by present and future generations alike.
Our Island, Our Environment, Our Future.
Working Together for a Sustainable Future Gobbragh Cooidjagh Son Traa Ry-Heet Shassooagh
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