Date: 7^th October 2019

Re: Application by Hydro Estates Limited for permission for construction of a nursing home, 29 no. detached houses and all ancillary site works. Partial demolition, conservation, refurbishment, alteration and change of use of the remains of the former St. Ann’s Hydropathic Establishment which is a Protected Structure (RPS 00815) on lands at St Ann's Hill, Kilnamucky Tower, Blarney, Co. Cork.

Cork County Council Planning Reg. Ref.: 18/7111
An Bord Pleanala Ref.: PL04 .305373

Dear Sir or Madam,

The Irish Georgian Society of City Assembly House, 58 South William Street, Dublin 2, a non-governmental charity, established in 1958, which works to promote and protect Ireland’s built heritage, wishes to make an observation on the Third Party Appeal of Sir Charles Colthurst against Cork County County Council’s Notification of Decision to Grant Permission (Cork County Council Reg. Ref. 18/7111; An Bord Pleanala Ref. PL04 .305373) for permission for development on lands at St Ann's Hill, Kilnamucky Tower, Blarney, Co. Cork (including the remains of the former St. Ann’s Hydropathic Establishment, a Protected Structure, RPS 00815).

Impact on historic landscapes

Much of Ireland’s most distinguished architectural heritage is to be found in its landscapes, whether it be National Monuments or protected structures, ecclesiastical buildings and ruins or country houses, whether grand or modest in scale. What is distinctive for all of these structures is their siting and setting. Their associated lands and/or demesnes had been designed, elaborated, planted and inhabited to enhance the setting. Rivers, loughs, hills, magnificent valleys and mountains are all engaged and embraced whether as framed views or as elements within the designs.

The gardens and designed landscapes of the 17th through to the 19th century were extensions of the plan of the house, to be experienced through all the senses as one inhabited outside spaces or moved along walks or rides. House and landscape were often a single coherent design. Ancient monuments and sacred places along with ruins and churches have been engaged in a visual dialogue across the land with country houses and their designed landscapes, each renewing their importance and redefining their significance.

In the attendant landscapes of country houses, ancient woodlands have been greatly valued. Individual groups of trees, avenues, boundary zones and new woodlands have been planted for both utility and amenity value. They have created microclimates, providing shelter for buildings and productive land. They have heightened the experience of the setting, and they have composed views, framing significant natural and manmade features. Natural watercourses and features were augmented with man made versions for utility and beauty and water was managed for supply and productivity in a way that contributed to the landscape. These landscapes, large and small, along with the fields enclosed with walls or banks and planted with hedgerows that now contain mature trees, all coalesce to make collective creations of singular importance.

As noted in the Conservation Plan submitted with the application, St Ann’s Hill is recorded in the Garden Survey of the National Inventory of Architectural Heritage. Neither the Conservation Plan nor the Architectural Heritage Impact Assessment mention that the nearby lands at Blarney Castle are also listed in the Garden Survey of the National Inventory of Architectural Heritage.

Objective HE 4-3: Protection of Non-Structural Elements of Built Heritage of the Cork County Development Plan 2014 provides that it is an objective of the plan to “Protect important non-structural elements of the built heritage. These can include designed gardens/garden features, masonry walls, railings, follies, gates, bridges, and street furniture. The Council will promote awareness and best practice in relation to these elements.”

The Development Plan goes on to state as follows:

• 12.4.10 Many non-structural elements, such as historic gardens, stone walls, ditches and street furniture contribute to our built heritage. Carelessness and a lack of awareness can result in the loss of these elements.
  
  
• 12.4.11 An absence of a tradition in ‘best practice’ for the conservation of historic landscapes and their associated features, means that appraisal and surveying are essential in considering development proposals for sensitive sites. A lack of understanding into the elements that form an integral part of designed landscapes can mean that these features are vulnerable to needless partial or total destruction, as well as poor reconstruction. Raising awareness of the value of landscapes and associated features and promoting standards in relation to repair and conservation of the same will be an important step.
  
  
• 12.4.12 NIAH identified a total of 6,000 designed landscapes around demesnes in the whole of the Country, 1,000 of these occurring within the County of Cork. Many of these demesnes are not included in the RPS, even though they may have important heritage value in their own right. Cork County Council prepared a guidance note; “Guidance Notes for the Appraisal of Historic Gardens, Demesnes, Estates and their Settings” in order to foster a better understanding of designed landscapes and in the case of any development proposals to facilitate the preparation of appraisals of historic gardens and designed landscape and any possible impact on its heritage value. [Emphasis added.]

In addition to this, Special Policy Area Objective X-01 designates “St Ann’s Hydropathetic Establishment” as a Special Policy Area and requires that “the conservation plan shall include a historic landscape appraisal”.

Notwithstanding Objective HE 4-3, Cork County Council’s Guidance Notes for the Appraisal of Historic Gardens, Demesnes, Estates and their Settings, and Special Policy Area Objective X-01 of the Development Plan, the planning application does not include an historic landscape appraisal and it does not appear that a landscape historian was involved in the design or assessment of the proposed development. Specifically, the application does not include an appraisal setting out the following elements (i) an identification and description of the development, history, features and boundaries of the designed landscape; (ii) an evaluation of the historical landscape (i.e. an evaluation of archaeological aspects, horticultural and arboricultural aspects and a statement of significance of the historic landscape, its development and components); (iii) an assessment of the impact of the development proposals on the historic landscape; and (iv) recommendations for mitigation and management of impacts on the historic landscape as described in Cork County Council’s Guidance Notes for the Appraisal of Historic Gardens, Demesnes, Estates and their Settings.

It is critical that any development of these lands be informed by a comprehensive assessment of the sensitivities and significance of the historic landscape at St Ann’s Hill and environs. This is particularly the case given that the historic landscape at St Ann’s Hill also forms the setting for the fifteenth century, Blarney Castle (a protected structure, RPS Ref. 00382). The loss of this landscape through the construction of inappropriate new development has the potential to constitute a profound loss in Ireland’s architectural and cultural heritage.

Negative impact on buildings and landscapes of heritage importance

The Architectural Heritage Protection Guidelines for Planning Authorities provide that proposals for new development within the curtilage of a building of architectural heritage significance should be carefully scrutinised by the planning authority, as "inappropriate development will be detrimental to the character of the structure". The Guidelines go on to state that, where there is a formal relationship between the heritage building and features within the curtilage, "new construction which interrupts that relationship should rarely be permitted". The Guidelines note that, within the curtilage of a building of heritage importance, there "may be planted features which are important to the character and special interest of the structure and which contribute to its setting. These could include tree-lined avenues, decorative tree-clumps, woodlands, species plants or plant collections."

The subject application proposes the functional severance of large parts of the curtilage of the former St. Ann’s Hydropathic Establishment from the protected structure. The Society submits that the proposed development will dominate and diminish the value of the historic landscape, which forms the setting for the protected structure complex, resulting in significant negative impacts on the heritage value of the former of St. Ann’s Hydropathic Establishment, its curtilage and attendant grounds. As such, the Society considers that the historic landscape, which forms the setting for the former St. Ann’s Hydropathic Establishment, a property of historic significance, will suffer significant negative impacts as a result of the construction of the proposed development.

Moreover, as illustrated by the Visual Impact Assessment provided with the planning application, the proposed development will be openly visible from Blarney Castle and will result in a considerable change in views towards St Ann’s Hill from the protected structure. The construction of the proposed development at this prominent location will disrupt the interrelationship between the Castle and the historic landscape to the northwest. Given that most visitors to the Castle climb to the top to kiss the Blarney stone and to enjoy the panoramic views of the surrounding countryside, the change in the visual environment likely to take place as a result of the construction of the proposed development is likely to result in particularly negative impacts on views from the protected structure at Blarney Castle and on the wider context in which it is located.

Conclusion

In conclusion, the Irish Georgian Society submits that the proposed development will have a significant negative impact on the architectural heritage of the former St. Ann’s Hydropathic Establishment and on Blarney Castle and will compromise the integrity of the historic and designed landscapes that forms the setting for these protected structures.

Having regard to the issues set out above, the Irish Georgian Society respectfully requests that the Planning Authority refuse permission for the proposed development on lands at at St Ann's Hill, Kilnamucky Tower, Blarney, Co. Cork (Cork County Council Planning Reg. Ref.: 18/7111; An Bord Pleanala Ref.: PL04 .305373).