NIEA: Historic Monuments Unit Waterman House 5-33 Hill Street Belfast BT1 2LA

Planning Service Ref: E/2007/0075/F NIEA: HMU Ref.: SM 11/1 Ant 3, 29, 58 Site: At junction of Whitepark Road & Causeway Road, townlands of Ballytaylor, Dooey, Ballylinney, Bushmills Date: 15/4/2011 Please refer to our previous joint response of Natural Heritage and Built Heritage directorates of NIEA issued on 31/10/07. The application site is located in an archaeologically sensitive landscape at the mouth of the River Bush and consists of a sensitive dune system, improved agricultural fields and demesne lands associated with the former Ballytaylor House and Dundarave Demesne. There are a substantial number of recorded archaeological sites and monuments located in the surrounding area, including the State Care Lissanduff prehistoric earthworks located at Portballintrae to the west, and several recorded archaeological sites located within the application site itself. Dundarave Demesne, a site on the Departments Register of Historic Parks, Gardens and Demesnes, adjoins the application site to the east and associated features extend into the application site. The Dundarave LLPA has been designated in the draft Northern Area Plan 2016 recognising the contribution Dundarave Demesne makes to the landscape setting of Bushmills. The application site lies within the Bushfoot LLPA, also designated in the above draft Plan. The Bushfoot LLPA is seen as a combination of the distinctive landscape of the River Bush, dunes and historic monuments sites of considerable significance contributing to the environmental quality, integrity and character of the area. The application site also lies on an important tourist route along the north coast which links a number of monuments in State Care, including the Lisanduff earthworks, increasing the sensitivity of this area in terms of tourist amenity. NIEA: Historic Monuments Unit have now reviewed the plans submitted for this application. Whilst we still have concerns regarding this development proposal, we are content that the applicant has taken into consideration our previous reasons for refusal and submitted an application that we consider to be archaeologically acceptable as per Policies BH1, BH 2 & BH 6 of PPS 6.

The Lissanduff prehistoric earthworks The Lisanduff earthworks consist of a pair of large concentric embanked enclosures, one with a central dry area and one with a central spring-fed pool. The earthworks are considered to have had a major ritual/religious significance in the prehistoric period, and are regionally significant for the whole of Northern Ireland. The earthworks are monuments in State Care and PPS 6 Policy BH1 applies. The earthworks are located on a prominent headland, overlooking the sea, the River Bush, the Dooey dune system and Bushfoot strand. They were carefully placed to be seen from the surrounding landscape and in a position to look out on the surrounding landscape. The earthworks setting and their relationship with the surrounding landscape within which that would have acted as a focal point for prehistoric communities, is important to our understanding of their original function. The most attractive visitor views available from the earthworks today are those to the east and north-east across the River Bush valley, Bushfoot strand and the Dooey dune system, towards the headland at the Giants Causeway. Interpretation panels at the earthworks guide visitors towards these views. The application site encompasses a substantial portion of the most attractive vistas available to visitors to the earthworks today. The importance of these views to visitor amenity is increased by the fact that much of the area surrounding the earthworks to the north, west and south has been encroached upon by modern development. NIEA: HMU have now reviewed the photomontages submitted with this application. Whilst we acknowledge that the proposed development will have an adverse visual impact upon public views from the Lissanduff earthworks, we accept the photomontages and do not consider the adverse visual impact will be substantial enough to warrant refusal of planning permission as per Policy BH 1 of PPS 6 Known archaeological remains within the application site Sand dune systems along the north coast, and elsewhere in Ireland and Britain, are known to be rich in buried archaeological remains. Remains of human settlement dating from the Mesolithic period, up to 9000 years ago, through to the Medieval period have previously been recorded with the Dooey dune system. These remains, along with those other sites in the surrounding area, indicate that the application site is likely to be rich in buried archaeological remains dating from the Mesolithic period onwards. The Dooey dune system in particular is likely to contain extensive buried archaeological remains in a good state of preservation. This dune system, and consequently the preservation of archaeological remains within it, is particularly sensitive to change. The majority of recorded archaeological sites in the surrounding area relate to burial and/or ritual activities, with remains of recorded prehistoric settlement currently being relatively rare. For these reasons, and as the remains within the application site should be considered within the context of other recorded sites nearby, the known archaeological remains within the application site should be considered as at least of local importance, hence Policy BH 2 of PPS 6 applies.

We have now reviewed our records and note that known archaeological remains within the application site have been partially excavated and damaged in the past. Should the Department consider the importance of the proposed development or other material considerations outweigh the value of the remains in question, NIEA: HMU would have no objection to this development providing it is conditional on archaeological mitigation as per Policy BH 4 of PPS 6 (please see conditions attached). Dundarave Demesne and associated landscape features The Registered area of Dundarave Demesne is located immediately to the east of the application boundary; however features historically associated with the Demesne, including McKinleys Hill and Estherfield tree plantations, boundary planting and Listed railings along the Whitepark Road all fall within the development area. The demesne lands are situated on the northern outskirts of Bushmills within a rural setting and, as noted in the proposed Dundarave LLPA designation, greatly enchancing the landscape setting of the town. The tree plantations in the application site are read in combination with the Registered area of Dundarave as a homogenous unit within the local landscape. This historic tree planting contributes significantly to the visual amenity of the local landscape, with attractive vistas afforded on approach to and from Bushmills, and from across the Bush valley to the west. The Department will not normally permit development which would lead to the loss of, or cause harm to, the character, principal components or setting of demesnes of special historic interest. However, NIEA: HMU have reviewed the submitted plans and consider that the proposed planting scheme included with the development proposal is sufficient to be archaeologically acceptable as per Policy BH 6 of PPS 6.

Issued on behalf of NIEA: Historic Monuments Unit

NORTHERN IRELAND ENVIRONMENT AGENCY

BUILT HERITAGE
5 - 33 Hill Street Belfast BT1 2LA Tel: (028) 9023 5000 Fax: (028) 9054 3111 For the attention of: Tony McCoey Planning Ref: E/2007/0075/F Location: At junction of Whitepark Road & Causeway Road, townlands of Ballytaylor, Dooey,
Ballylinney, Bushmills

Our Ref: SM 11/1 Ant 3,29,58

Date: 15/4/2011 No site works of any nature or development shall take place until a programme of archaeological work, has been implemented, in accordance with a written scheme and programme prepared by a qualified archaeologist, submitted by the applicant and approved by the Department. The programme should provide for the identification and evaluation of archaeological remains within the site, for mitigation of the impacts of development, through excavation recording or by preservation of remains, and for preparation of an archaeological report. Reason: to ensure that archaeological remains within the application site are properly identified, and protected or appropriately recorded. Access shall be afforded to the site at all reasonable times to any archaeologist nominated by the Department to observe the operations and to monitor the implementation of archaeological requirements. Reason: to monitor programmed works in order to ensure that identification, evaluation and appropriate recording of any archaeological remains, or any other specific work required by condition, or agreement is satisfactorily completed. Advice :
For guidance on the preparation of the Written Scheme and Programme of Archaeological Work, which should be submitted for approval at least 4 weeks before work is due to begin, contact: Northern Ireland Environment Agency - Historic Monuments Unit 5 - 33 Hill St, Belfast BT1 2LA tel: 028 905 43000 ext 43171 Quote reference: SM 11/1 Ant 3,29,58 Application for the excavation licence, required under the Historic Monuments and Archaeological Objects (NI) Order 1995, should be submitted at least 3 weeks before work is due to begin, by a qualified archaeologist responsible for the project, to: Northern Ireland Environment Agency Historic Monuments Unit 5 - 33 Hill St, Belfast BT1 2LA tel: 028 905 43000 ext 43138