Dublin City Council
Planning Department
Civic Offices
Block 4, Ground Floor
Wood Quay
Dublin 8

26 October 2018

Re: Application by Newydd Ltd for planning permission for the extension and alteration of the existing four storey over basement building at Nos. 3-4 Fownes Street, Temple Bar, Dublin 2 (a Protected Structure) for use as 6 no. apartments. The proposal also includes repair and refurbishment works and all other ancillary works necessary to facilitate the development.

Dublin City Council Planning Reg. Ref.: 4006/18

Date of Lodgement of application: 24 September 2018

Dear Sir or Madam,

The Irish Georgian Society (of City Assembly House, 58 South William Street, Dublin 2) wishes to make an observation on the application by Newydd Ltd for the extension and alteration of the existing building at Nos. 3-4 Fownes Street, Temple Bar, Dublin 2 (a protected structure) to facilitate the development of 6 no. apartments, plus roof terrace. To that end, we enclose payment, in accordance with the provisions of the Planning and Development Regulations, 2001, as amended, in the sum of €20.00, as payment of the submission fee.

The buildings at Nos. 3-4 Fownes Street are of very considerable architectural heritage importance and are described by Christine Casey in her 2005 publication, Dublin: The Buildings of Ireland, as being “the only surviving example in Dublin of this early C18 house type”. The entries for No. 3 Fownes Street (Reg. No. 50020150) and No. 4 Fownes Street (Reg. No. 50020149) in the National Inventory of Architectural Heritage refer to the buildings as being “significant mid-eighteenth-century” houses retaining features that are considered rare survivors in the city. Both houses are described as contributing “positively to the early architectural heritage of the area”. The buildings are located in an area designated as a Conservation Area under the Dublin City Development Plan 2016-2022.

Having regard to the architectural heritage importance of the buildings to which this application relates and to the national and international heritage importance of Dublin’s Georgian Core, the Irish Georgian Society has significant concerns about the scale, bulk, height and intensity of development proposed at Nos. 3-4 Fownes Street, protected structures. The proposed addition of a fourth floor (with roof terrace on top) will necessitate the destruction of the surviving historic roof profile, by removing the rear / western pitch of the roof and by concealing the surviving chimney stacks of the protected structures. The proposed extension (i.e. addition of a fourth floor and boundary treatments for the roof terrace) will rise to a height something of the order of 4 m above the ridge height of the existing protected structures. The proposal will also rise above the roofs of the adjoining protected structures. While works to the rear of the ridge of a pitched roof in a dense urban area would often not be visible from street level due to the angle of view, this will not be the case for the proposed development. The location of the application site relative to the public plaza to the front of the former Central Bank will offer open views of the proposed extension above the roof of the protected from areas of the plaza and from Dame Street, as illustrated by the photomontages submitted with the application.

The Architectural Heritage Protection Guidelines advise that “the character of a roof relates to its profile and pitch, whether gabled or hipped; the cladding materials; use or not of dormers; the style, materials, siting and number of stacks; the use of decorative bargeboards or rainwater goods; and the way all of these together contribute to the overall character of the structure or area”. The Guidelines go on to state that “Architectural details are important features of the roofscape and their removal should rarely be permitted where they are in good condition or are capable of repair. The removal of details of interest will have implications for the special interest of the structure, as they contribute to the quality and character of a roof. Where the structure forms part of a unified terrace, the alteration or removal of roof details from one structure will affect the character of the entire group and this should be borne in mind when considering a proposal for planning permission.” With regard to extensions, the Guidelines state that "If planning permission is to be granted for an extension, the new work should involve the smallest possible loss of historic fabric and ensure that important features are not obscured, damaged or destroyed. In general, principal elevations of a protected structure (not necessarily just the façade) should not be adversely affected by new extensions… In urban areas, careful consideration needs to be given to proposals for the construction of rear extensions to protected structures and buildings within ACAs. Rear elevations sometimes contain fabric that is useful in reading the history of the structure, for example surviving older windows or doors. The effect of extensions may have considerable impact on the appearance of buildings or on the setting of neighbouring buildings, or indeed on the appearance of the structure when viewed from a distance (or a set of similar structures such as in a terrace)." The subject application, which proposes to change the profile of and remove the rear pitch of the original roof, conceal chimney stacks and create a new roof profile, will result in a profound and negative change to the character of the roof of the protected structures at Nos. 3-4 Fownes Street. Moreover, as suggested by the Guidelines, the proposed development will result in negative impacts on the character of the group of protected structures at Nos. 2, 3, 4, 5 and 5a Fownes Street when viewed from Fownes Street, Dame Street and the public plaza to the front of the former Central Bank.

The Society is also concerned by the extent of intervention proposed within the buildings. The Architectural Heritage Protection Guidelines provide that: "Many old buildings suffer from minor structural defects but will continue to perform satisfactorily providing they are not subject to major disturbance. Alterations such as the creation of new openings, changes to the interior spaces or the installation of new services and equipment could overload an existing structural system and, where this is a possibility, the proposals should be reconsidered." The “removal of … partition walls, breaking new openings in external walls” are referenced in the Guidelines as interventions, which may result in the endangerment of a protected structure. Moreover, the Guidelines are clear that: “The plan-form of a building is one of its most important characteristics. Where the original plan-form remains, or is readily discernible, it should be identified and respected” [Emphasis added]. The removal of existing walls and erection of new internal partitions now proposed will result in a profound change to the plan form of the existing buildings, particularly on the second and third floors. The subject application will also necessitate very significant works arising from the installation of services to facilitate bathroom and kitchen facilities on the upper floors.

While it is evident that the extent of intervention within the protected structures is likely to be very significant, it is also the case that the proposals for the interior of the buildings are not sufficiently detailed in the application documents to facilitate comprehensive assessment of the impact of the development on the protected structures. No architectural heritage impact assessment is included with the application. The Initial Conservation Appraisal submitted with the application is vague. It is unclear whether the report relates to the subject proposal (e.g. the appraisal alternately discusses proposals to provide four and five apartments, whereas the subject development proposes six apartments) or whether the Appraisal is intended as a feasibility assessment of whether it would be possible to convert the buildings into apartments in theory (e.g. the report states that converting the building into four apartments “if carefully considered, can be successfully achieved” [emphasis added]).

In any case, Appendix B of the Architectural Heritage Protection Guidelines would suggest that, in order to adequately assess the impact of a proposal requiring a considerable level of intervention throughout protected structures of rarity and significant architectural heritage value, the following information should be submitted to the Planning Authority:

• a photographic survey of the interior of the buildings;
• a description of the structures, recording features of note or historical significance, architectural or engineering design, building materials, building techniques and craftsmanship. While it is noted that the Initial Conservation Appraisal submitted with the application mentions some original features surviving within the building, the location of these features within the structures is generally not clearly identified. Given that comprehensive works to Nos. 3-4 are proposed (i.e. requiring demolitions), the Guidelines would suggest that this this description would need to be carried out on a floor-by-floor, room-by-room basis;
• a description of the overall development of the structures, noting evidence of successive building phases and supporting this analysis with annotated reference to stylistic elements, documentary sources or scientific dating methods;
• a description of the current physical condition of both the fabric and the structures in order to establish the nature and extent of any apparent damage, including any indications of previous demolition or alteration to the structure;
• a clear description of the extent of intervention within the protected structures, including a schedule of demolitions, highlighting where it is proposed to remove in whole or in part original fabric;
• an impact assessment containing an evaluation of the quality and importance of the structure and a comprehensive assessment of the implications of the development for the character of the structure and the area in which it is located.

It is further noted that the application does not include an engineer’s report or structural assessment of the proposal, notwithstanding that the Initial Conservation Appraisal notes “evidence that significant movement of the building has occurred in the past and there is a significant slope on the floors at first and second floor level” and that “some structural stabilisation works has been undertaken in the past”. It is further not clear from the application if adequate consideration has been given to the extent of intervention required within the buildings to comply with the provisions of the Building Regulations on fire, ventilation and universal access. It is of critical importance that the cumulative impact of all proposed interventions to the protected structures are comprehensively assessed before consideration is given to permitting development within these sensitive buildings.

In conclusion, the Society respectfully submits that the subject application for the development of 6 no. apartments within at Nos. 3-4 Fownes Street, which appears to propose significant removal of original fabric and considerable change to the original plan form of these rare survivors in the city, will result in significant negative impacts on the architectural heritage value of the protected structures. It is further submitted that the design of the proposed fourth floor extension makes no attempt to respect or enhance the character and composition of Nos. 3-4 Fownes Street or any of the other protected structures on Fownes Street having regard to its scale, height, bulk or design. The proposed design of the extension will disrupt the roof profile of this early eighteenth century terrace and will appear jarring, visually obtrusive and grossly out of character with the fine grain facades of Nos. 3-4 Fownes Street at this visually prominent location. The construction of such an unsuitable and discordant addition to these fine houses will result in significant negative impacts on the architectural heritage of the buildings, Fownes Street and Dublin City, and should be refused permission.

Yours faithfully,

Donough Cahill
IGS Executive Director