Marian Coyle
Marlay Park Master Plan
Parks and Landscape Department
Dun Laoghaire-Rathdown County Council
County Hall
Marine Road
Dun Laoghaire
Co. Dublin

[By email to mcoyle@dlrcoco.ie]

Date:       31^st August 2018

Re:         Draft Marlay Park Master Plan

 

Dear Ms Coyle,

The Irish Georgian Society is a membership organisation, which encourages and promotes the conservation of distinguished examples of architecture and the allied arts of all periods in Ireland. These aims are achieved through our education programmes, by supporting and undertaking conservation works, publishing original research, planning participation and fundraising. The Irish Georgian Society is a strong advocate on the subject of the protection of historic landscapes and has held a number of educational events on historic gardens and landscapes, the most relevant to this consultation being the seminars entitled “Dublin’s Victorian and Edwardian Parks” (February 2013) and “Historic Landscape: Loved, lost or in limbo?” (February 2015), which were held in conjunction with the Irish Landscape Institute.

The Irish Georgian Society welcomes the opportunity to comment on the Draft Marlay Park Master Plan as part of the ongoing public consultation.The Society supports Dun Laoghaire-Rathdown County Council in its stated objective of “To conserve and protect the built heritage and provide suitable, sympathetic and sustainable uses for the properties in the setting of the historic landscape” and welcomes the strong conservation focus of the Draft Marlay Park Master Plan. The Society further welcomes the emphasis placed by Dun Laoghaire-Rathdown County Council in the Draft Master Plan on conservation and repair of built features and reinstatement of landscape features, such as woodland, as part of an overall objective to “maintain and restore the original layout of this historic park”.

However, the Society would like to take this opportunity to raise the following queries and concerns in relation to matters, which should be addressed in the final Master Plan.

Historic Landscape Assessment must form the basis for any Master Plan for Marlay Park

It is essential that any Master Plan for Marlay Park be evidence-based. While Section 6.0 of the Draft Master Plan makes reference to the Built Heritage Inventory of Parks in Dun Laoghaire – Marlay Park (still understood to be in draft), there is no reference to an assessment of the historic landscape of Marlay Park undertaken by a suitably qualified historic landscape consultant. It is critical that any development of these lands be informed by a comprehensive assessment of the sensitivities and significance of the historic landscape. Failure to ensure that an analysis of the historic landscape forms the basis for the conservation strategy for Marlay Park would seem to be at odds with the objective of the Draft Master Plan to restore the “original layout of this historic park”. It is particularly unclear how a plan to reinstate landscape features (such as woodland) could be formulated in the absence of that information.

The Society is concerned that anything other than an integrated and evidence-based approach to the management of the historic parks will lead to the loss of historic landscape features of significance. In the absence of advice from a suitably qualified historic landscape consultant, well-meaning interventions could also undermine the integrity of the historic landscape. In other words, it is respectfully submitted that, unless a comprehensive survey and assessment of the historic landscape is carried out, key landscape features within Marlay Park are likely to slip through the cracks.

In this regard, the Society is of the strong opinion that the drafting of proposals for new structures or landscape interventions within the Park are premature pending a comprehensive assessment of the historic landscape. Specifically, the Society has grave concerns regarding proposals for the construction of a new bridge over the central pond. Constructing a bridge in the location indicated on page 13 of the Draft Master Plan undermines the whole concept of the pond and has the potential to result in significant negative impacts on the integrity of the historic landscape. The design of any such intervention must be informed by an appropriate assessment of the historic landscape.

Need for Conservation Management Plan for reinstatement of lost features

The Society is given to understand that over the course of the twentieth and into the twenty-first century, Marlay Park has suffered a continuous iterative loss of structures and landscape features of heritage importance, including the demolition of a bell tower / dove cote; the demolition of gate lodges; the substantial removal of very considerable lengths of cast iron railing; and removal of historic landscape features. As part of any comprehensive assessment of the structures and landscape of Marlay Park (i.e. that would form the basis of a Master Plan), features that were wrongly demolished or removed in recent years should be identified and consideration given to their reinstatement. This is a critical step in restoring the “original layout of this historic park”.

Given this and given the large number of historic structures within the park, it is essential that a conservation management plan be developed by a suitably qualified professional or team of professionals to outline a long-term conservation strategy in more detail. This detail could be included within the Master Plan or it could form part of a separate document to which the Master Plan refers.

Insufficient protection framework in place

While Objective 3 of the Draft Master Plan seeks to “conserve and protect the built heritage” of Marlay Park, there is no reference within the Draft Master Plan to designating structures as protected structures or making use of other statutory designations to ensure the long-term protection of structures and features within the park. Indeed, the Draft Master Plan does not even go so far as to identify which structures within the park are already listed in the Dun Laoghaire-Rathdown Record of Protected Structures (i.e. Marlay House and stable yard, RPS Ref. 1518; Laurelmere, RPS Ref. 1592). While it is acknowledged that all structures within the park and within the designed landscape fall within the curtilage and attendant grounds of the protected structure at Marlay House, the Society notes that failure to implement a robust legal protection framework can lead to confusion and endanger structures of value. The Society urges Dun Laoghaire-Rathdown County Council to commit to adding the other structures of architectural heritage importance within the Park to the Record of Protected Structures, and, in particular, those identified by the National Inventory of Architectural Heritage, including:

• NIAH Ref. 6022013: Walled Garden
• NIAH Ref. 60220014: Worker’s house
• NIAH Ref. 60220016: Farmyard complex
• NIAH Ref. 60220017: Gates / railings / walls
• NIAH Ref. 60220019: Gates / railings / walls
• NIAH Ref. 60220020: Gate lodge
• NIAH Ref. 60220021: Gates / railings / walls

More than this, having regard to the Florence Charter on Historic Gardens, which “defines historic gardens as architectural compositions and recommends their preservation as living monuments”, the Society suggests that consideration be given to designating Marlay Park as an Architectural Conservation Area. The Architectural Heritage Protection Guidelines for Planning Authorities provide:   

“ACA legislation may be used to protect … designed landscapes where these contain groups of structures as in, for example, urban parks, the former demesnes of country houses and groupings of archaeological or industrial remains…

The contribution of setting to the character of the architectural heritage should not be underestimated. A building in a rural setting may have a different, but equally noteworthy, relationship with its surroundings from that of a building in an urban place. The location of a structure may have been designed to relate to a particular landscape feature, as, for example, in the way that Powerscourt House relates to the Sugarloaf Mountain. Follies, eyecatchers, gazebos and towers were all usually positioned and designed to enhance their setting or the designed landscape in which they are situated. The attendant grounds around a country house were often moulded into a coherent landscaped entity in accordance with current aesthetic and economic ideas.”

The Guidelines go on to state that an ACA can “set out the requirements for the conservation of the living components of designed landscapes that form part of the ACA, such as trees and other planting”. Given that the Planning and Development Acts do not yet include a dedicated mechanism for the protection of historic or designed landscapes, strong consideration should be given to designating Marlay Park as an Architectural Conservation Area to protect the integrity of the historic designed landscape as both the setting for Marlay House and as an asset of significant heritage value in its own right.

Insufficient detail on event management

The Draft Master Plan does not detail any proposals for management of major events within the park. This is considered to be a significant omission having regard, in particular, to the scale of music events held in the park, such as the annual three-day Longitude music festival (with an attendance of approximately 40,000 people per day), and the pressure that these events put on the park. For example, it is understood that the most intensive elements of the Longitude music festival are held in the most sensitive area of the park: the area identified as the Designed Landscape – specifically, the Longitude main stage is located in the area identified in the Draft Master Plan as the Ha-Ha Field. The Society is given to understand that, while the event coordinator is required to make good any damage caused by the event, sensitive historic landscape features are inevitably damaged as a result of the festival. It is further understood that living elements of the landscape have had to be removed to facilitate access by large vehicles. Given the scale of the park, it is unclear why such an intensive activity would be directed to the area of the park where it can cause the most damage to features of heritage importance. The Draft Master Plan does not indicate if this practice will continue or if it is intended that this practice will change “in order to reduce pressure on the area designated as ‘The Designed Landscape’” (page 9). Given the potential for large events to conflict with and undermine the key objectives of the Plan, it is essential that this matter be clearly outlined within the Master Plan to ensure that the key objectives of the plan remain implementable.

In addition to this, while the Draft Master Plan does not outline the rationale or necessity for a new pedestrian bridge over the central pond, it is noted that a temporary bridge is typically erected over the central pond as part of the Longitude music festival. As outlined above, the erection of a new bridge at the location indicated in the Draft Master Plan is likely to result in significant negative impacts on the integrity of the historic designed landscape of Marlay Park. It is critically important that any permanent physical intervention within the landscape, particularly those that might be proposed in contemplation of or to facilitate major events, are thoroughly justified and the rationale fully explained as part of an Master Plan.

Conclusion

The Society congratulates Dun Laoghaire-Rathdown County Council on the considerable conservation work already carried out on certain structures within Marlay Park and welcomes the strong conservation focus of the Draft Marlay Park Master Plan. The Society further welcomes the emphasis placed by Dun Laoghaire-Rathdown County Council in the Draft Master Plan on conservation and repair of built features and reinstatement of landscape features, such as woodland, as part of an overall objective to “maintain and restore the original layout of this historic park”.

However, practically speaking, a Master Plan for Marlay Park as a significant asset of heritage value is rendered meaningless in the absence of the preparation of an historic landscape assessment and a conservation management plan undertaken by suitably qualified professionals. Without this information, well-intentioned decisions will continue to be made as part of the day-to-day management of Marlay Park, which result in the loss of historic fabric and features and undermine the overall integrity of historic gardens, as has repeatedly already happened throughout the park.

Please do not hesitate to contact us if we can be of any further assistance.

Yours faithfully,

Donough Cahill
Executive Director
Irish Georgian Society

 
(Image of Marlay Park via Curious Ireland)