AnBP ref: 312298-21

DCC ref: 3617/21

PROTECTED STRUCTURE: For development at 77-80 King Street North, Smithfield, Dublin 7, D07 TP22.

Date: 24th January 2022

Dear Sir or Madam,

The Irish Georgian Society wishes to submit this observation on the first party appeal to An Bord Pleanala against the decision by Dublin City Council to refuse permission for the proposed development of a site at nos. 77-80 King Street North, Smithfield, Dublin 7.

The Irish Georgian Society wishes to reiterate its continued strong objections to the original proposal and to the revisions now being proposed by the applicant to address the reasons for refusal issued by Dublin City Council. The Society is of the opinion that the revised proposals suggest major changes to the development in plan form only with no detail provided and appear to differ to such an extent from the original proposal that they should be rejected by the board and referred back to the applicant to be submitted as a new planning application. The revised proposals, in any event, still have significant conservation and urban design implications that have simply not been addressed at all.

In its original objection submitted to Dublin City Council, the Society expressed the opinion that the proposed development was over-scaled, poorly designed and ill-judged in responding to its historic urban context. Furthermore, it would totally undermine the integrity, authenticity and legibility of historic buildings that have been designated by Dublin City Council as protected structures.

The heritage impact assessment report submitted with the original application described only the impact of the proposed development on the buildings on the subject site and failed to address the wider historic urban context, the character of North King Street and other protected structures on the street at nos. 86, 88 & 89, or the very significant impact of the proposed development on no. 81, the protected structure directly adjoining the site.

No further heritage assessment has been submitted with the revised proposal to address any of these issues.

The original report described the existing buildings on the site at 77-80 North King Street as being of ‘architectural, historic and social interest’ but justified their scant regard in the proposed development (facadism at best) by saying that their current condition made their future uncertain. This is not a valid argument. Their current condition is due to owner neglect over a very long period and including a period when Dublin City Council’s own Dangerous Buildings Section had to intervene to prop the facades of nos. 78 & 79. In any event no structural survey or proper building analysis was included to give credibility to this statement.

The heritage impact assessment report failed completely to mention no. 81, a carefully restored and maintained eighteenth-century house and protected structure, which directly adjoins the existing buildings, and whose character would clearly be seriously impacted by the proposed development.

The urban design statement submitted with the original proposal failed to take into account the architecture and character of North King Street which should have been the reference and starting point for considering the redevelopment of this key site. Building heights should respect the existing street context and be in keeping with the heights established by no. 81 and the Red Mill building on Red Cow Lane. While this subject site terminates the view from Smithfield looking north, the building plots of 77-80A relate directly to North King Street, a busy urban traffic route. In this regard the site is very different to the sites that have been redeveloped on the east and west sides of Smithfield and the same criteria in terms of acceptable building height, proportion and scale cannot be considered to be the same or appropriate on the subject site.

In conclusion the Society is of the opinion that the scheme proposed disregards the historic context and constitutes overdevelopment in terms of its proposed height and scale. Dublin City Council Development Plan objectives are supported by very clear legislation on the position that, in dealing with protected structures, any new development proposed is required to have due regard to their special architectural character and to be carefully and appropriately designed in this context.

This important site, which terminates the view north from Smithfield, offers great potential for sensitive contemporary development in a manner where the historic context and building fabric are respected and where these are the motivators in developing the site design strategy. Neither the original proposal, nor the scheme revised as suggested, are acceptable in this regard and the Society recommends an outright refusal of this appeal.

Yours sincerely,

Donough Cahill

Executive Director IGS