Image credit: National Library of Ireland

The Secretary

An Bord Pleanála

64 Marlborough Street

Dublin 1

Date:      9^th October 2017

Re:         Application by Reliance Investments Ltd for planning permission for conservation and restoration works and the development of an office development with a total gross floor area of 14,720 sq m on a site of 0.4840 hectares at Aldborough House, Portland Row, Dublin 1, a protected structure.

Dublin City Council Planning Reg. Ref.:                                   3457/17

Date of Notification of Decision to Grant Permission:                12^th September

Dear Sir or Madam,

The Irish Georgian Society (of City Assembly House, 58 South William Street, Dublin 2) wishes to appeal Dublin City Council’s Notification of Decision to Grant Permission on the application by Reliance Investments Ltd for the development for conservation and restoration works and the construction of a new office development at Aldborough House, Portland Road, Dublin 1, a protected structure (DCC Reg. Ref. 3457/17). Dublin City Council’s letter acknowledging receipt of the Irish Georgian Society’s submission / observation on the planning application is attached at Appendix A.  A copy of Dublin City Council's Notification of Decision to Grant Permission is attached at Appendix B. I enclose the €220 fee for the making of this Third Party Appeal on behalf of the Irish Georgian Society.

Aldborough House, a building of national architectural heritage importance, is described in the National Inventory of Architectural Heritage (NIAH) as ‘one of Dublin's great eighteenth-century mansions’. The NIAH entry for Aldborough House goes on to explain the significance of this ‘imposing Palladian mansion’ as follows: ‘The survival of Aldborough House contributes to the sense of continuity, interest and significance of this area of Dublin, which at the time of its construction was the north-eastern fringe of the city, overlooking the newly-opened Royal Canal.’

Aldborough House has suffered from neglect and lack of essential maintenance since falling into vacancy subsequent to the downturn in the property market. However, notwithstanding vandalism and arson attacks, the house remains largely intact, albeit in a poor state of repair. The Society welcomes proposals for the refurbishment and restoration of Aldborough House and acknowledges that some measure of new development must take place on the site in order to ensure the continued viability of the building. However, it is of critical importance that any new development on the site:

• Be informed by a comprehensive, objective and evidence-based assessment of Aldborough House, its character and its architectural and cultural heritage importance; and
• Complement Aldborough House in terms of scale so as not to compromise the character and special interest of this nationally important building.

Conservation Plan does not adequately describe the Significant Architectural Heritage Value of Aldborough House

It is important that the architectural heritage value of Aldborough House is assessed objectively and the elements of the structure which contribute to its ‘special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest’ identified with reference to impartial evidence to ensure that any new development does not undermine the value of this nationally-important protected structure. It is a disappointment that the report entitled ‘Conservation Plan’, which accompanies the planning application, would seem to downplay the significance of the house, but without adducing any objective evidence that would support this position. The Society is concerned that numerous subjective statements throughout the report, when read in conjunction with certain somewhat misleading or unsupported statements, could be misconstrued as meaning that Aldborough House is of considerably lesser importance than it is. This is of particular concern given that the Planning Authority appears to have relied heavily on the information supplied by the Applicant in coming to a decision about the appropriate level of intervention to the house. The report of the Conservation Officer states:

‘In respect of over-arching conservation strategy it is noted that the surrounding built context, use and condition/significance of Aldborough House has evolved and greatly altered from the time of its original construction. Current condition and past record of vandalism and dereliction are noted as a key consideration/justifications in determining an appropriate planning outcome and level of intervention to recover and to sustain the building.’ [Emphasis added.]

The report of the Conservation Officer goes on state that ‘the Applicant has provided exemplary information regarding the surviving significance’, which is not the case for the reasons outlined below.

The author states, on page 3, that ‘It is not the work of an architect of note and is generally thought to have been a collaboration between the Second Earl and a series of tradesmen, with minor inputs from a number of lesser known architects.’ This statement contradicts entries within the Dictionary of Irish Architects (www.dia.ie), an essay by Dr Aidan O’Boyle on the construction history of Aldborough House published in the Irish Georgian Society’s Irish Architectural and Decorative Studies Vol. 4 (2001) and the entry for Aldborough House in the National Inventory of Architectural Heritage. While it is clearly evident that the Earl of Aldborough was actively involved in the design and construction of the house, it is also evident that Richard Johnston was engaged as an architect by Aldborough. Johnston would be regarded by many as a prominent and fashionable architect in his day and was architect for several prominent buildings including Daly’s Clubhouse on College Green and portions of the Rotunda Assembly Rooms. Payments between 1793 and 1796 would suggest a continuing involvement with the house while Daniel Murphy was employed as site architect and stone mason – a relatively common practice at that time. The author does not adduce any evidence, which would refute this comprehensively researched and well-established understanding of the design and construction of Aldborough House.

The author goes on to makes a number of subjective and dismissive statements about Aldborough House, describing it as ‘relatively plain’, ‘mediocre’ and goes so far as to state that it is ‘not a beautiful building’. The author does not explain these statements by referencing relevant evidence or consensus of the architectural community. In the absence of this, it is difficult to understand the basis upon which a building accepted as being a nationally important exemplar of Georgian architecture in Ireland could be considered ‘mediocre’. Moreover, the Society is deeply troubled by the implications that diminishing the value of Aldborough House in a Conservation Plan, the stated aim of which is to ‘assess the cultural significance of the house, and remaining grounds, in the context of Dublin architecture from the late Georgian period’ (emphasis added), could have for the appreciation and long term conservation of other Georgian buildings of lesser significance within Dublin and across the country.

When read in conjunction with certain unsubstantiated statements or statements that fail to reference established practice of the time, there is a risk that such comments could wrongly be interpreted as meaning that Aldborough House is without architectural merit. For example:

(a)  At page 11, the author states: ‘The architectural language of the interior is relatively plain with most of the decoration being well-worked standard catalogue designs, rather than in hand-crafted work unique to the house.’ The author fails to substantiate or reference the charge that the internal decoration was purloined from ‘catalogues’.

(b)  Similarly, the author states at, page 21, that ‘As a work of architecture it is mediocre at best and now stripped of most of its external and internal decorative features, the house has little more than age and scale to commend it.’ While much of the interior has been damaged, many of the principal rooms retain original joinery and plasterwork features, to say nothing of the staircases. As for the exterior of the building, with the exception of the chapel wing and balustrades, the exterior of the building is substantially intact.

(c)  The author goes on to suggest, at page 22, that ‘The decorative elements, be they sculptural or in bas-relief, are all cast elements from standard moulds, rather than hand modelled work of the type that would be found in Russborough or Leinster House.’ The Society questions the purpose of this statement, which appears to completely downplay the surviving decorative elements as merely ‘cast’ elements. The author, however, fails to inform that by the late 18th century casting of decorative details had become the normal practise in most houses, large and small. Similarly, the two houses singled out for comparative purposes, Russborough House and Leinster House, are about 50 years older than Aldborough House. They are in a completely different architectural style and employed hand modelled decoration as casting of the high relief decoration which was fashionable when they were built was not possible. These houses are, therefore, in the Society’s opinion, inappropriate comparisons and their selection does not assist in making a balanced informed assessment of the architectural and decorative significance of Aldborough House.

(d)  The statement, at page 23: ‘Aldborough House is not a beautiful building, nor was it ‘a successful building in terms of its use as a residence.’’ would seem to suggest that the reason for the building not remaining long in use as a residence was on the grounds of its architectural qualities. A similar statement is made on p. 19 and p. 58. However, the Conservation Plan completely ignores the fact that following the Act of Union, and the migration of political magnates and grandees to London, most of these large townhouses were no longer needed as residences. Aldborough House was only one of several large townhouses, including Leinster House, Powerscourt House, Belvedere House and Tyrone House, which fell out of use as residences and were adapted to institutional uses in the years following the Union.

(e)  The Conservation Plan states, on page 58, that ‘Contained within high boundary walls and obscured by subsequent development, the house contributes nothing to its immediate surroundings.’ This is an unhelpful statement as it almost suggests that the house is largely invisible within the urban context. Aldborough House is a dominant feature on Portland Row and is a key historic and cultural landmark in this part of the city. At present, the bulk of at least three sides of the house are clearly visible over its boundary walls from several vantage points within the area. It is noted that the proposed development will largely obscure the two side elevations and will obstruct raking views of the front elevation from along Portland Row and from the North Strand at Five Lamps.

The Society is also concerned by the basis for the rationale for the chosen design approach. Specifically, in justifying the design approach for the new additions to Aldborough House Section 4.1. of the Design Statement states: ‘that there are numerous precedents in Dublin of large historic houses being absorbed into the urban grain.’ These ‘precedents’ and, in particular, that of Charlemont House, are referenced in both the Dublin City Council Planner’s Report and Conservation Officers Report. However, none of the exemplars presented have been absorbed into the urban grain in the manner proposed for Aldborough House. From the outset, both Belvedere House and Charlemont House were always intended to be flanked by tall four-storey over basement town houses. Powerscourt House was built as a free-standing mansion in an existing urban streetscape flanked by smaller scale townhouses. Iveagh House was also a free-standing house flanked by smaller four-storey townhouses before it was extended in the later 19^th century.

Moreover, the Conservation Plan states, on page 43, that the rear and side elevations ‘were not designed to be seen from the public domain’ and that are plain brick facades – and presumably therefore of little significance. When first built, and as is the case today, these elevations are highly visible from the public domain owing to the scale of the house and the surrounding walls and, in the opinion of the Society, it is untrue to suggest that the original architect would not have been aware of this. While the facades are built in brick rather than stone, they have limestone platbands at ground and first-floor level while at roof level there is a full entablature with a moulded cornice and blocking course. Therefore, these facades cannot be regarded as entirely plain. It is also noted that Christine Casey states that the facades were originally plastered and lined and ruled out. It would also appear that these facades, along with the front elevation had an open balustered parapet surmounted by urns and statues. These features are shown on no less than four engravings as follows:

• 1796 engraving by William Skelton of proposed design on page 7 of the conservation plan
• Engraving of the front and rear elevations of the house in 1821 on pages 3 & 10
• 1836 Penny Journal engraving on page 20.

While it is possible that these images were the subject of artistic license, it would be remarkable that three different artists employed the same artistic licence over a forty year period. It should also be noted that the open parapets and urns would to some extent have acted as a counterpoint to the severity of the façades. This should be taken into consideration when considering the architectural merits of the facades. However, it would appear that this has not been done in the Conservation Plan.

Scale of new development on the Aldborough House lands

While the Irish Georgian Society recognises that securing the future of Aldborough House will require compromise, it is essential that the architectural character and significance of the house is protected and maintained as far as possible. The subject application proposes to increase the quantum of floorspace on what little remains of the original setting of Aldborough House by approximately 550% (from 2,679 sq m to 14,720 sq m). The Society has grave concerns about the scale and intensity of new development and the extent of internal alteration proposed for this nationally significant building of architectural heritage significance.

The Society notes that these concerns are shared by the Department of Culture, Heritage and the Gaeltacht, the Department stating in its submission to Dublin City Council of 18^th August 2017, which states:

“In the opinion of the Department of Culture, Heritage and the Gaeltacht, the height and density of new construction currently proposed have the potential to negatively impact on the character and special interest of this nationally significant building. It is believed that the height and location of the new office buildings surrounding Aldborough House would dominate the historic building and could compromise its architectural integrity.”

It is respectfully submitted that consideration should be given to the following:

• The omission of the proposed mezzanines in the first-floor rooms. The scale and height of the first-floor rooms is an essential characteristic of the house and this should not be compromised. The Architectural Heritage Protection 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.’
• The omission of the corridors linking the office blocks to the main house at second-floor level. This would reduce the degree to which the main house is subsumed into the new development and would allow the profile of the original house to be clearly read against the skyline.
• Revision of the design of the new office blocks to reduce the impact of new structures on the character and setting of the protected structure. Having regard to the importance of Aldborough House, any new development on the site should be subsidiary to the protected structure. The original house should be the dominant building in views of the site, particularly in views from Portland Row. At a minimum, no element of the proposal should rise above the parapet of Aldborough House, but consideration should be given to reducing the overall height of each of the office blocks to ensure new elements do not appear overly dominant and overbearing in views to and from the protected structure.

The Irish Georgian Society believes that it is essential that the works and repairs to the original house are undertaken at the earliest opportunity to ensure that the building is secured and that there is no further loss of significance. On this basis, the Society requests An Bord Pleanála make it a condition of any grant of planning permission that the repairs to the main house commence are undertaken to the satisfaction of the council’s conservation officer, conservation office or an appropriate qualified agent prior to the commencement of any other development on the application site.

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

Yours faithfully,

Donough Cahill
Executive Director, Irish Georgian Society

Appendix A:  Dublin City Council’s letter acknowledging receipt of submission / observation on the planning application (DCC Reg. Ref. 3457/17)

Appendix B:  Copy of Dublin City Council’s Notification of Decision to Grant Permission for the proposed development at (DCC Reg. Ref. 3457/17)