Planning and Development Directorate

Cork City Council

City Hall

Anglesea Street

Cork

2^nd September 2019

Re. Redevelopment of the Custom House site at North Custom House Quay and South Custom House Quay, Custom House Street, Cork City to provide a 240-bedroom hotel, 25 no. hotel serviced suites, and a range of commercial uses including retail, office, food and beverage, distillery, tourism and leisure.

Ref. 1938589

The Irish Georgian Society is a membership organisation that promotes an awareness and the protection of Ireland’s built heritage through educational programmes, supporting conservation projects, and campaigning for the protection of buildings at risk. The Society has considerable concerns about the very significant impact this planning application could have on Cork’s built heritage given the proposals to demolish the Revenue Building, a protected structure of regional architectural interest that lies within sensitive complex of national heritage interest, and the plans to construct a 34-storey building in its place.

Proposed demolition of the Revenue Building

The Custom House and the Revenue Building (PS818) are identified as protected structures in the Cork City Development Plan 2015-21 (the City Development Plan) and, together with the Bonded Warehouses (also protected), are considered by the Plan (Section 8.18) as being “particularly emblematic of Cork’s maritime heritage”. This also notes that “along with Haulbowline Island, [it] is one of the two most important Georgian dock complexes outside Dublin and one of three surviving Georgian docks complexes in Ireland”. The South Docks Local Area Plan, 2008 (SDLAP) describes them as “unquestionably the most important surviving port related structures to survive in the upper harbour area”.

The National Inventory of Architectural Heritage designates the Custom House (identified as the Harbour Commissioner's Office ref. 20506372) as a structure of National importance and the Revenue Building (identified as Customs Offices ref. 20506373) as being of Regional importance. It states that the Revenue Building forms “part of an important complex of buildings located behind the Harbour Commissioner's Office, [that it] displays a fine use of building materials traditional to the area [and that it] also retains timber sash windows and has been well maintained”.

The City Development Plan and the Architectural Heritage Protection Guidelines for Planning Authorities (2004) (the Guidelines) give consideration to proposals for the demolition of protected structures. The City Development Plan (Objective 9.24) states that “Proposals for demolition of a Protected Structure shall not be permitted except in exceptional circumstances and where it can be showed that a greater public interest will be served which outweighs the loss to the architectural heritage”. The Guidelines also states that “the Act provides that permission may only be granted for the demolition of a protected structure or proposed protected structure in exceptional circumstances”.

The Irish Georgian Society has grave concerns about the current proposal to largely demolish the Revenue Building given that it forms an integral part of the Georgian Custom House Docks area, that it is a designated protected structure, and that its individual significance has been recognised by the NIAH. The proposal to construct a 34-storey structure in place of it, though presumably to fund works to other protected structures on the site, should not be considered to comprise the “exceptional circumstances” suggested by legislation and the City Development Plan to justify its demolition. Our architectural heritage is an irreplaceable resource which once lost is gone forever. The Architectural Heritage Protection Guidelines for Planning Authorities states:

“Our architectural heritage is a unique resource, an irreplaceable expression of the richness and diversity of our past. Structures and places can, over time, acquire character and special interest through their intrinsic quality, continued existence and familiarity. The built heritage consists not only of great artistic achievements, but also of the everyday works of craftsmen. In a changing world, these structures have a cultural significance which we may recognise for the first time only when individual structures are lost or threatened. As we enjoy this inheritance, we should ensure it is conserved in order to pass it on to our successors.”

Proposed construction of a Tall Landmark Building

In considering the South Docks Local Area Plan the Planning Supporting Statement accompanying the application states that “until such time as a new LAP is adapted… the SDLAP remains valid and weight can therefore be applied to this policy document” (section 5.5).

The SDLAP identifies five sites within the South Docks as being suitable for Tall Landmark Buildings and in doing so does not list the Custom House Docks area as one of these. On the contrary, in recognising the heritage importance of the area, it specifically states that “focal landmark buildings in sensitive locations (e.g. Customs House/Bonded Warehouses) should be modest in height due to the architectural, historical and cultural significance of the site” (4.8.2.2). It also states that “due to the heritage sensitivity of the Harbour Commissioners’ Office and distinctive Bonded Warehouse, the scope for redevelopment may be limited” (5.2.1).

In considering building heights, the City Development Plan aims to “Ensure that development reflects and is sensitive to the historical importance and character of the city, in particular the street layout and pattern, plot sizes, building heights and scales” (Objective 9.1, Built Heritage and Archaeology). It also states that development proposals “should respect the height, mass and scale of surrounding buildings, should not compromise protected views and prospects and should draw upon positive characteristics of the surrounding environment to create a sense of place, security and vitality” (Objective 13.21 City Centre Design Quality and Context). It is respectively suggested that the construction of a 34-storey tower in the centre of a complex of buildings that constitute one of the most important Georgian dock complexes in the country would not be “sensitive to its historical importance and character” nor “draw upon positive characteristics of the surrounding environment”.

The Irish Georgian Society is of the view that the construction of a Tall Landmark Building on the Custom House Docks site would be contrary to the provisions of the South Docks Local Area Plan and the Cork City Development Plan and should not be granted planning permission.

Summary

In conclusion, the Irish Georgian Society is of the view that this development proposal does not present the “exceptional circumstances” required by legislation and the City Development Plan for the demolition of the Revenue Building, a protected structure of Regional importance. Granting permission for its demolition on these grounds could set a very worrying precedent for similar proposals that could undermine the effectiveness of protected structure designations. Furthermore, the Tall Landmark Building proposed in its place would quite clearly not be consistent with the provisions of the SDLAP and the City Development Plan. For these reasons the Irish Georgian Society urges Cork City Council to refuse permission for this planning application.

Yours sincerely,

Donough Cahill

Executive Director IGS