Planning Statement


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Planning Statement

Rostrevor House, Rostrevor July 2017

CONTENTS

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01 Introduction

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02 Site & Surroundings

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03 Planning History

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04 Planning Policy

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05 The listed building

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06 Consideration

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07 Summary

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Appendix 1: Site Location Plan

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Appendix 2: Listed Buildings

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Appendix 3: BNMAP Extract

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Appendix 4: Listed Building Record and HED Comment

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Appendix 5: General Planning and Environment Critiria

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Contact: Conor Hughes [email protected] Office Address: Hamilton House 3 Joy St Belfast BT2 8LE Telephone: 028 9072 3921 Project Ref: LADB3001 Date of issue: July 2017

Copyright All drawings are Crown Copyright 2017. All rights reserved. Licence number 100020449.

01

Introduction

Turley has been instructed to appraise the development potential of lands at Rostrevor House, Greenpark Road, Rostrevor.

1.1 Our assessment of the development potential of these lands is informed by a site visit and desktop research to understand the context, surroundings and potential constraints, a detailed planning history search using the planning authority online planning portal and an analysis of prevailing local and regional planning policy. 1.2 The statement having considered the above provides commentary on the range of uses that could be permitted on the site and the form and scale of development that might be achieved.

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02

Site & Surroundings

Site 2.1 The site is located at Greenpark Road, Rostrevor and extends to approximately 11.74 hectares in size. A site location plan is attached at Appendix 1. 2.2 The site contains the buildings and curtilage of ‘Rostrevor House’, a former convent of the Sisters of Our Lady of the Apostles and used by Religious Orders of the Roman Catholic Church between 1952 and 2003. 2.3 It is described in historical records of the Diocese of Down and Connor as a ‘Centre of retreats and other spiritual activities’.

2.4 The property was sold in 2004 and is currently vacant. 2.5 The main existing buildings are comprised of the original house constructed in 1894 and a modern extension dating from the early 1960’s and were previously used as living accommodation. 2.6 Living spaces, kitchens and common areas are primarily located on the ground floor and the bedrooms on the first floor. 2.7 Other ancillary single storey outbuildings are located adjacent to a walled garden in the mature landscaped grounds.

2.8 A single storey gate lodge is located at the entrance towards the southeastern corner of the site. 2.9 Parking is provided on hard surfaced areas immediately adjacent to the front of the main buildings and there is a tennis court immediately adjacent. 2.10 The boundaries of the site are defined by a 2.5 metre high random stone wall, pillars and gates along the edge of the Greenpark Road and by mature hedgerows and trees along all other edges.

2.11 The land rises with the site from the edge of the Greenpark Road towards the rear of the site and there is a difference in height between the two ledges of approximately 30 metres. The buildings are located on terraces which have been engineered using earth embankments and retaining walls. 2.12 The site is planted throughout with mature trees in groups of woodland to the south and east of the main buildings.

Surroundings 2.13 The lands to the south and west of the site are primarily residential in character and mainly comprised of detached dwellings in relatively large curtilages. To the southwest are the local GAA pitches and club house. The land beyond to the north and east is predominantly rural in character and mainly in agricultural use.

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03

Planning History

Site

Adjacent Lands

3.1 A search of the local authority online planning portal in June 2017 did not identify any planning history for the site since 01 January 2010.

3.2 A recent application for new stables for the neighbouring equestrian centre (to the northwest of the site) was withdrawn on the grounds that it would be refused planning permission as a consequence of an adverse visual impact and impact on the setting of an area of existing open space. The application reference is LA07/2015/0088/F.

3.3 A recent planning application beyond the equestrian centre and to the north of the site for a change of house type for a small residential development comprised of 15 dwellings and three apartments was approved in March 2017. The application reference is LA07/2016/0799/F.

3.4 Eight of the residential units are to be developed as social housing. An application to not comply with this condition was refused planning permission in October 2016. It had not been demonstrated by the applicant that an unmet social housing need had been delivered elsewhere with the settlement of Rostrevor. The application reference is LA07/2016/0799/F.

3.5 A planning application for a 100 bedroom hotel and health spa was received by the planning authority on 20 June 2017. The application reference is LA07/2017/1030/0. The site is to the north of Rostrevor House. Limited information in provided in support of the proposal but an earlier history of approval for a 50 bedroom hotel which expired on 09 November 2016 is noted. The application reference is P1200811178/0.

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Planning Policy Local Policy 4.1 The site is in part located within the development limit of Rostrevor and is not specifically zoned for any particular use in the Banbridge, Newry & Mourne Area Plan 2015 (BNMAP). The balance of the land is located in the open countryside. 4.2 A map showing the extent of the land inside the development limit is provided at Appendix 3. 4.3 All of the land is identified as part of a Historic Park, Garden and Demesne under Plan Proposal NC 04. 4.4 The site is also within the Rostrevor Local Landscape Policy Area. The features which contribute to the environmental quality, integrity or character of these areas are listed in the Plan as:



Monuments and their surroundings including Ross’s Monument and Rath. These provide local archaeological and historical interest with associated views and setting;



• •

The following listed and locally significant buildings with associated views and settings provide historical interest – Green Park, St. Bronaghs Well, Church ruins and graveyard, the Gate Lodge, Forestbrook, Kilbroney House, Benvenue, Kilbroney Vicarage, Star of the Sea, Fairy Hill, Carpenham, Our Lady of Apostles Missionary Convent and St Bronach’s (C of I) and Drumsesk House;

The Kilbroney, Rostrevor and Ghann river corridors including associated mature vegetation providing local wildlife habitats and nature conservation interest; and

Conservation Area will be assessed in accordance with prevailing regional policy and with the design guidance contained in Rostrevor Conservation Area Guide (DOE (NI)), dated February 1979.

The hills and woodland surrounding the settlement including that inside Kilbroney Park.

4.7 Part 1 of the guide sets out the guidance for Development Control in the Conservation Area. It is stated that development will be controlled with the primary aim of ensuring the retention and importance of the character of the area. Every possible effort is to be made to preserve the individual building and groups of buildings on which the character depends.

4.5 It is stated at policy CVN 3 of the Area Plan that: “within designated LLPAs, planning permission will not be granted to development proposals that would be liable to adversely affect their intrinsic environmental value and character.” 4.6 Part of the site is also inside the Rostrevor Conservation Area and the Plan directs that development proposals within the

4.8 It is further stated at Part 1 of the guide that where permission is sought to demolish or alter a listed building, or demolish any other building, it will be necessary to demonstrate that such works

would in themselves be an enhancement or that they are required for overriding and exceptional reasons. 4.9 The former convent is referred to in Part 2 of the guide where it is stated that “The landscaped grounds of the large individual houses and the Convent along Greenpark Road combine with the Fairy Glen to enhance the overall character of the village.” 4.10 The guidance also sets out that changes of use necessitating a planning application which are likely to have an adverse effect on land or building which contribute significantly to the character of the conservation area will not normally be permitted.

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Regional Policy 4.11 The Planning Act (Northern Ireland) 2011 requires that the determination of proposals must be in accordance with the local development plan unless material considerations indicate otherwise. 4.12 However, while BNMAP advises that proposals within conservation areas will be assessed in accordance with Planning Policy Statement 6 Planning, Archaeology and the Built Heritage (PPS6). It contains no local policy provisions relevant to the Conservation Area. 4.13 The 2015 Strategic Planning Policy Statement for Northern Ireland (SPPS) contains a policy direction reflecting the statutory requirements of Section 104 and 105 of the Planning Act (Northern Ireland) 2011.

4.14 Until councils have adopted a new Plan Strategy any conflicts between the SPPS and existing Planning Policy Statements are to be resolved in favour of the SPPS. 4.15 Policy BH12 deals with new development in a Conservation Area and sets out a series of criteria which must be satisfied. 4.16 The Department will normally only permit development proposals for new buildings, alterations, extensions and changes of use in, or which impact on the setting of a conservation area where all the following criteria are met: (a) the development preserves or enhances the character and appearance of the area (as modified by Section 104 of the Planning (Northern Ireland Act 201) and the SPPS); (b) the development is in sympathy with the characteristic built form of the area;

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(c) the scale, form, materials and detailing of the development respects the characteristics of adjoining buildings in the area; (d) the development does not result in environmental problems such as noise, nuisance or disturbance which would be detrimental to the particular character of the area; (e) important views within, into and out of the area are protected; (f)

trees and other landscape features contributing to the character or appearance of the area are protected; and

(g) the development conforms with the guidance set out in conservation area documents.

4.17 The 2015 Strategic Planning Policy Statement for Northern Ireland (SPPS) contains a policy direction reflecting the statutory requirements of Section 104. Until councils have adopted a new Plan Strategy any conflicts between the SPPS and existing Planning Policy Statements are to be resolved in favour of the SPPS. 4.18 Section 104 of the 2011 Act and the related policy direction of the SPPS take precedence over Criterion (a) of PPS6 Policy BH12 - New Development in a Conservation Area BH12, requires development to preserve or enhance the character and appearance of a conservation area. The remaining criteria (b) to (g) still need to be satisfied in considering a new proposal.

4.19 At paragraph 7.4, PPS6 states that the Department does not wish to stifle development in conservation areas. The emphasis will be on the careful control and positive management of change, to enable the area to remain alive and prosperous, but at the same time to ensure that any new development accords with the area’s special architectural or historic interest. 4.20 Policy BH14 of Planning Policy Statement 6 (PPS6) Planning Archaeology and the Built Heritage specifically deals with the demolition of any building within a Conservation Area.

4.21 It sets out a presumption in favour of retaining any building which makes a material contribution to the character and appearance of the Conservation Area: •



‘The Department will normally only permit the demolition of an unlisted building in a conservation area where the building makes no material contribution to the character or appearance of the area. Where conservation area consent for demolition is granted this will normally be conditional on prior agreement for the redevelopment of the site and appropriate arrangements for recording the building before its demolition.’

4.22 ‘Material’ is defined in the Collins English Dictionary as being of ‘great impact or consequence’ and ‘materially’ used as an adverb, as being ‘to a significant extent; considerably’. 4.23 The justification and amplification text of paragraph 7.17 and subsequent paragraphs state that in assessing the contribution of any building to the character and appearance of the Conservation Area, regard must be had to other material considerations referred to as ‘the same broad criteria outlined for the demolition of listed buildings’. 4.24 Policy BH11 deals with new development affecting the setting of a listed building and sets out a number of criteria to be satisfied.

4.25 The Department will normally only permit development which would not adversely affect the setting of a listed building. Development proposals will normally only be considered appropriate where all the following criteria are met: (a) the detailed design respects the listed building in terms of scale, height, massing and alignment; (b) the works proposed make use of traditional or sympathetic building materials and techniques which respect those found on the building; and (c) the nature of the proposed use respects the character of the setting of the building.

4.26 The criteria set out in policy BH11 is broadly similar to the requirements of the SPPS. 4.27 It is stated at Policy BH 6 (Protection of Parks, Gardens and Demesnes of Special Historic Interest) that the planning authority will not normally permit development which would lead to the loss of, or cause harm to, the character, principal components or setting of parks, gardens and demesnes of special historic interest. 4.28 Where planning permission is granted this will normally be conditional on the recording of any features of interest which will be lost before development commences.

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05

The listed building

Rostrevor House 5.1 It is stated at Section 80 (7) the Planning (Northern Ireland) Act 2011 that: “listed building” means a building which is for the time being included in a list compiled under this section; and, for the purposes of the provisions of this Act relating to listed buildings, the following shall be treated as part of the building: (a) any object or structure within the curtilage of the building and fixed to the building; and

(b) any object or structure within the curtilage of the building which, although not fixed to the building, forms part of the land and has done so since before 1st October 1973. 5.2 Rostrevor House as described in the record is a former dwelling designed and built in ‘Elizabethan Revival’ style from around the mid nineteenth century. The date of the listing is not specified on the record shown on the map at Appendix 2.

(7), it is our assessment that the modern extension and any building within the curtilage constructed before 1973 is an integral part of the listed building and subject to the same legislative and planning policy controls that apply to listed buildings. 5.4 Rostrevor House, the modern extension and the ancillary outbuildings have a Grade B listing. 5.5 This grade of listing is normally attached to buildings

of local importance that are good examples of a particular period or style. A degree of alteration or imperfection of design may be acceptable. 5.6 Since 1987 the Department for Communities has been banding Grade B buildings into two groups B1 and B2. A second survey has not been carried out on Rostrevor House but we would consider the building if resurveyed to fall generally within the B1 grade.

5.7 This grade is for buildings with a relatively wide selection of attributes. Usually these will include interior features or where one or more features are of exceptional quality and/or interest.

5.3 In accordance with other buildings of Section 80

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06

Development Potential

The Use of Rostrevor House 6.1 While the building was last used as a ‘centre of retreats and other spiritual activities’ in 2003 there is no evidence to suggest that the use of the building was changed in the intervening period. 6.2 The building as a consequence falls within Class C3 (Residential institutions) of the Planning (Use Classes) Order (Northern Ireland) 2015.

6.3 The building could continue to be used for any of the categories of development falling within the use class including the provision of residential accommodation and care to people in need of care; as a hospital or nursing home; or as a residential school, college or training centre.

6.4 It is permitted under Class D of the Planning (General Permitted Development) Order (Northern Ireland) 2017 to change of use of a building falling within Class C3 (Residential institutions) to Class C1 (Dwelling house) of the Schedule to the Use Classes Order. 6.5 All other changes of use would require a planning application albeit that said the site is located within the development limit of Rostrevor and is not zoned for any specific use in the Area Plan.

6.6 Subject to meeting normal planning and environmental considerations (described at Appendix 05) it is considered that the building could be used as an hotel or guesthouse, heath spa and gymnasium, as a museum, art gallery, public library or crèche or for a community use including health centre.

6.7 It could also be used as residential accommodation other than a dwelling house and subdivided into apartments. 6.8 As the interior of the building is listed this impacts on the number of units that might be achieved but the size of the building is large enough to accommodate approximately 1 three bedroom, 4 two bedroom and 5 one bedroom apartments.

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The modern extension to Rostrevor House 6.9 The 1960’s modern extension to Rostrevor House is listed by virtue of it being attached to Rostrevor House. 6.10 The modern extension could also continue to be used for any of the categories of development falling within Use Class C3 including for the provision of residential accommodation and care to people in need of care, as a hospital or nursing home; or as a residential school, college or training centre. 6.11 All other changes of Use would require a planning application albeit that said the site is located within the development limit of Rostrevor and is not zoned for any specific use in the Area Plan.

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6.12 Subject to meeting normal planning and environmental considerations (described at Appendix 04) it is considered that the building could be used as an hotel or guesthouse, heath spa and gymnasium, as a museum, art gallery, public library or crèche or for a community use including health centre. 6.13 The modern extension is inside the Conservation Area were there is a general presumption in favour of retaining any building which makes a material contribution to the character and appearance of the Conservation Area. 6.14 It is however large and visually imposing and was added to the original building in the 1960’s. It is elevated above the Greenpark Road in a prominent view on approach to the settlement.

6.15 In consultation with the Historic Environments Division of the Northern Ireland Environment Agency (see Appendix 4) it was stated that: ‘Having reviewed the photographs taken on the recent site visit to Rostrevor House, I would confirm that HBDB is of the opinion that the modern extension does not contribute to the special interest of the main house’ 6.16 The planning authority will normally only permit the demolition of a listed building or part of a building in a conservation area where the building makes no material contribution to the character or appearance of the area. 6.17 Whilst not the express view of the planning authority the comments of NIEA are significant and material to the decision of whether the modern extension should be demolished.

6.18 It is our opinion that it is highly likely, subject to the submission of an application that consent to demolish the modern extension would be approved. 6.19 Conservation area consent for demolition is not applied for at this stage as this is normally conditional on prior agreement for the redevelopment of the site and appropriate arrangements for recording the building before its demolition are made. 6.20 The only circumstance where an unconditional consent could be forthcoming is where the original building is converted to a dwelling house. An application for listed building consent would be required however setting out a full programme of works to repair and make good the former links to the modern extension.

6.21 Should an application for consent to demolish be made to and approved by the planning authority this would open the opportunity for the land comprised of the footprint of the extension, the hard surfaced areas surrounding and the tennis courts to be redeveloped for the same range of uses specified at 6.10 and 6.12. It would also allow the land to be redeveloped for a new build apartment scheme or for family housing. 6.22 The variation in levels across the site means that this part of the land might be better developed for apartments. The bulk, scale and massing of any new building should be no larger than the existing modern extension and it is unlikely that any more than three floors of accommodation would be acceptable. Approximately 25 apartments could be developed on the footprint of the modern extension.

6.23 If family housing is proposed this is more likely to be in the form of three very large detached dwellings two of which would be generally on the footprint of the modern extension and a third on the location of the tennis court. 6.24 Alternatively if a terrace or courtyard of housing is proposed approximately 8 two-storey dwellings could be developed. 6.25 In both circumstances the impact on the setting of Rostrevor House must be carefully considered and the design and layout of the new development should be of high quality and sensitive to the landscape setting.

Modifications to Rostrevor House 6.26 The planning authority will normally only permit in consultation with NIEA development which would not adversely affect the setting of a listed building. 6.27 In bringing forward proposals on the footprint of the modern extension to the listed building the detailed design of any new proposal should respect the listed building. NIEA will expect the scale, height, massing and alignment to be subordinate to the retained building. 6.28 While the works proposed may make use of traditional or sympathetic building materials and techniques that does not mean that a high quality contemporary design is precluded. The link between the two buildings must be sensitively handled.

6.29 The nature of the proposed use must respect the character of the setting of the building. 6.30 It is considered that a proposal for residential development would not conflict with the established setting of the listed building. The treatment of parking and amenity typically associated with dwelling houses needs to be carefully considered.

The Gate Lodge 6.31 The Gate lodge (including its curtilage) is located inside the development limit of Rostrevor. This building can continue to be used as a dwelling. Alternatively, it could be converted and extended as two apartments.

Development within the Historic Garden, Park or Demesne 6.33 It is highly unlikely that the planning authority would permit development in the part of the historic gardens inside the development limit as this could harm the setting of the gardens which are deemed to be of special historic interest. 6.34 Of the balance of the lands outside the development limit but within the curtilage of the listed building it may be possible to sensitively convert the ancillary buildings adjacent to the walled garden to a dwelling; this would require a sensitive design solution.

6.35 There is a provision within policy BH 7 of PPS 6 to change the use of a listed building where this secures its upkeep and survival and the character and architectural or historic interest of the building would be preserved or enhanced. 6.36 A proposal to change the use of the ancillary buildings in the walled garden should incorporate details of all intended alterations to the buildings and the curtilage to demonstrate there is no adverse effect on the appearance, character and setting of the garden.

6.32 The building could also be converted to a range of uses such as guesthouse, health spa, retail unit, café, crèche or doctors surgery.

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Summary

7.1 Rostrevor House was last used as a ‘centre of retreats and other spiritual activities’ in 2003 there is no evidence to suggest that the use of the building was changed in the intervening period. The building as a consequence falls within Class C3 (Residential institutions) of the Planning (Use Classes) Order (Northern Ireland) 2015.

7.2 The building could be continued to be used for any of the categories of development falling within the use class including the provision of residential accommodation and care to people in need of care, as a hospital or nursing home; or as a residential school, college or training centre.

7.3 It is permitted under Class D of the Planning (General Permitted Development) Order (Northern Ireland) 2017 to change of use of a building falling within Class C3 (Residential institutions) to Class C1 (Dwelling house). 7.4 Alternatively, the building could be used for a range of uses including as an hotel or guesthouse, health spa and gymnasium, as a museum, art gallery, public library or crèche or for a community use including health centre.

7.5 It could also be used as residential accommodation other than a dwelling house and subdivided into apartments. Rostrevor House is large enough to accommodate approximately 1 three-bedroom, 4 two-bedroom and 5 onebedroom apartments. 7.6 The modern extension to Rostrevor House makes no material contribution to the listed building or the Conservation Area. Should an application for consent to demolish be approved by the planning authority this would

open the opportunity for the land comprised of the footprint of the extension, the hard surfaced areas surrounding and the tennis courts to be redeveloped for a range of uses including an hotel or guesthouse, health spa and gymnasium, as a museum, art gallery, public library or crèche or for a community use including health centre. 7.7 It would also allow the land to be redeveloped for a new build apartment scheme or for family housing.

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7.8 The change in level across the site means that this part of the land might be better developed for apartments. The bulk, scale and massing of any new building should be no larger than the existing modern extension and it is unlikely that any more than three floors of accommodation would be acceptable. Approximately 25 two-bedroom apartments could be developed on the footprint of the modern extension.

7.10 Alternatively if a terrace or courtyard of housing is proposed approximately 8 two-storey dwellings could be developed.

7.13 The building could also be converted to a range of uses such as a guesthouse, health spa, retail unit, café crèche or doctors surgery.

7.11 In both circumstances the impact on the setting of Rostrevor House must be considered and the design and layout of the new development should be of high quality and sensitive to the wider landscape setting.

7.9 If family housing is proposed this is more likely to be in the form of three very large detached dwellings two of which would be generally on the footprint of the modern extension and a third on the location of the tennis court.

7.12 The Gate lodge (including its curtilage) is located inside the development limit of Rostrevor. This building can continue to be used as a dwelling, or it could be converted and extended into two apartments.

7.14 It is highly unlikely that the planning authority would permit development in the part of the historic gardens inside the development limit as this could harm the setting of the gardens which are deemed to be of special historic interest and important to the evolution of the design of Rostrevor House.

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7.15 Of the balance of the lands outside the development limit but within the curtilage of the listed building it may be possible to sensitively convert the ancillary buildings adjacent to the walled garden to a dwelling/dwellings. 7.16 There is a provision within policy BH 7 of PPS 6 to change the use of a listed building where this secures its upkeep and survival and the character and architectural or historic interest of the building would be preserved or enhanced.

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Appendix 1: Site Location Plan

Appendix 2: Listed Buildings

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318950

GR EEN

318900

KRO AD

318850

318800

Playing Field

Our Lady of Apostles Missionary Convent

COPYRIGHT STATEMENT

Chapel (Private)

318750

11

28

35 36

GR 318650

EE NP AR

2

8

1

12 11

KR OA

15 14

ESCENT GR EENDALE CR 17

16a

12

16

8

20

7

13 318500

Posts

4

St Bronach's Ch (C of I)

8

9a

9

-1 11

9

12a

12

11

318441

318550

13

14

Out Bulidings

St B r Apa onag rtm h's ent s

14a

Gatelodge

15

Terrace

23

Tennis Court

ES GR EENDALE CR

Modern Extension

11

3

Rostrevor House

318600

D

1

28

30 29

9 10

13

318700

34 31 33 32 PARK 'S A IT ST R

'S PARK

17

27 22 23 'S PARK A IT R T S

ST RITA

Except as otherwise permitted under the Copyright Designs and Patents Act 1988 this map may only be reproduced, stored or transmitted in any form or by any means, with the permission of Land & Property Services.

PAR

Playing Field

1

Toilets

28

318450 3

3

3

3

3

3

3

3

3

Appendix 3: BNMAP Extract

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Development Limit Conservation Area Historic Park Garden & Demesne LLPA

Appendix 4: Listed Building record HED and HED Comment

Appendix 5: General Planning and Environmental Criteria

Planning

Flooding

The planning authority will consider the merits of the case against a range of policy criteria which are set out in the main body of the report.

The NI Flood map indicates that the there is no history of fluvial or surface water flooding at the site. The Flood Maps do however indicate that parts of the site may be at risk of surface water flooding.

It is for the applicant to demonstrate that the development can be delivered to a high standard without any adverse impact on existing residents by reason of noise nuisance or overlooking. They must also weigh in the decision making process compliance with published policy and other guidance documents which apply to the type of development proposed. Design should be of a high quality and appropriate in scale and massing to the context within which it will fit. Design and Access Statement

It will also be necessary to prepare a Design and Access Statement which explains how the proposed scheme responds to the site context and employs good design in the preparation of the application.

Given the identified risk, it is likely that Rivers Agency would request a drainage assessment to support any application in accordance with the provisions of policy FLD3 of Planning Policy Statement 15 Planning and Flood Risk. The report should be accompanied by an indicative drainage layout. Community Consultation

Given the size of the site it is likely that any future application on the site will meet the definition of a major application under the Planning (Development Management) Regulations 2015. Should the scale of development constitute a major planning application under the Planning (Development Management) Regulations 2015, the application will be required to comply with the relevant provisions set out under section 27 of the Planning Act (NI) 2011. A Proposal of Application Notice should be served on Newry, Mourne and Down District Council (including any other relevant notice parties) 12 weeks prior to submission of any application. The applicant must also undertake Pre-Application Community Consultation and evidence of this must be collated in a PreApplication Community Consultation Report to inform validation of the application.

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Environmental

The land comprises historic buildings and a significant number of mature trees. It would therefore be prudent to engage a suitably qualified ecologist to conduct an ecological walkover survey and/or a bat roosting potential survey to identify any bat activity. Should any activity be identified a full bat survey would be required. Bat surveys are seasonal and should be factored into the overall development programme should such survey be required. The land should be surveyed by a suitably qualified environmental consultant to confirm that no Japanese Knotweed is present on the land. There is a significant capital outlay associated with the removal of this weed and subsequent remediation of the site. If Japanese Knotweed is present this should be identified as a cost within the development budget. It is likely that the Council will require submission of an Invasive Species Management Plan to set out the proposed methodology for the safe removal of the weed from the site to stop further spread.

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For further information contact Conor Huges [email protected]

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