The Irish Georgian Society has reacted to proposals by Dublin City Council's Environment and Transportation Department to massively increase bus traffic on Dublin's Parliament Street, one of the first streets laid out by the Wide Street Commissioners in 1762 as part of their remodeling of the city's streets. Please find the submission in full below:

The Irish Georgian Society welcomes this opportunity to comment on the College Green Traffic Management Measures Public Consultation Document. 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 Society has had a marked and widely acknowledged impact on the conservation of built heritage in the state and has wide experience of the problems associated with the restoration, repair and maintenance of the fabric of historic property.

The Society is in strong support of Dublin City Council policy to “develop the city’s character by cherishing and enhancing Dublin’s renowned streets, civic spaces and squares; to create further new streets as part of the public realm when the opportunities arise; to protect the grain, scale and vitality of city streets; to revitalise the north Georgian squares and their environs; and to upgrade Dame Street/College Green as part of the grand civic spine” (Policy SC2 of the Dublin City Development Plan 2011-2017). The Society further supports, in principle, proposals for the creation of a new civic plaza area at College Green, which has the “potential to transform this area and to reimagine the space and the use of it for the benefit of the citizens of Dublin and also visitors to Dublin”.

However, the Society is gravely concerned by proposals outlined in the College Green Traffic Management Measures Public Consultation Document, which indicate that it is the intention of Dublin City Council to merely re-route a large proportion of the very high volumes of bus and taxi traffic away from the College Green and on to the significantly more vulnerable Parliament Street. Any positive impact on the civic character and quality of the overall historic environment is likely to be negated by this piecemeal and haphazard approach to traffic management in the Georgian Core of the City.

Outstanding architectural and cultural heritage significance of Parliament Street
Parliament Street is described in detail by Christine Casey in her 2005 publication The Buildings of Ireland: Dublin as follows:

“The grandest street in Temple Bar is Parliament Street, opened in 1762 by the Wide Street Commissioners. It is the first instance of formal axial planning in mid C18 Dublin. The notion of a grand new approach to the Castle originated in the rebuilding of Essex Bridge (1753-5) by George Semple, who in 1753 published the plan of a new street equal in width to the bridge (51 ft, 15.5 metres) and terminating in a piazza on Cork Hill. In 1757 an acts was finally passed appointing the first Wide Streets Commissions to make ‘a wide and convenient way, street or passage, from Essex-bridge to the Castle of Dublin’. The opening of Parliament Street was this the catalyst to the dramatic reshaping of the city by the Commissioners during the following half-century.” [Emphasis added.]

In Dublin · A Grand Tour, Jacqueline O’Brien and Desmond Guinness set out:

“At the top of the newly created Parliament Street was the former site of Cork House, erected in 1600 for the Great Earl of Cork and later used by Cromwell’s hated government as its headquarters. In the 1760s a scheme for building a Chapel Royal with a cupola here was abandoned as was another plan for a square to be named Bedford Square after the viceroy. The merchants exerted pressure through their allies in parliament and Dublin Corporation and, in spite of their opposition of the Wide Street Commissioners, they succeeded in purchasing the site in May 1768 for £4,000…

The foundation stone of the Royal Exchange was laid by the Viceroy, Lord Townshend, on 2 August 1769, on which occasion the bells rang out, the sailing vessels unfurled their flags … The government provided funds and the merchants organized lotteries to pay for the building, which took ten years to complete…

The Royal Exchange makes a handsome climax for the vista at the top of Parliament Street and was remarkable in its day for the refinement of the carved ornament executed by Simon Vierpyl. It was the earliest of Dublin’s green-domed buildings and is the only one to survive intact from the time that it was built.”

The view of the former Royal Exchange (now City Hall) along the axis of Capel Street, Essex Bridge and Parliament Street, as depicted in James Malton’s View from Capel Street overlooking Essex Bridge Dublin of 1797, is one of the most significant vistas within the Georgian Core of Dublin. Indeed, this vista is designated for protection under Figure 4: Key Views and Prospects of the Dublin City Development Plan 2011-2017.

A number of the buildings originally constructed under the auspices of the Wide Street Commissioners survive largely intact on Parliament Street, including the former Read’s Cutlers at Nos. 3-4 Parliament Street wherein it is understood that the original eighteenth century shop interiors remain. While many of the buildings on Parliament Street were remodelled during the nineteenth and twentieth centuries, the buildings of Parliament Street continue to be of significant architectural heritage importance, both individually and as an assemblage. Almost all buildings on Parliament Street (either wholly or in part) have been listed as protected structures in the Dublin City Council Record of Protected Structures and the Street has been designated as a Conservation Area under the Dublin City Development Plan 2011-2017. The Draft Development Plan includes provision for the designation of Temple Bar as an Architectural Conservation Area.

The Development Plan notes that “the Georgian core is unique, yet, in places, undervalued and fragile”. It would appear that Parliament Street is especially undervalued by Dublin City Council. Notwithstanding its extraordinary importance within the architectural and cultural heritage of Dublin, it is barely mentioned in statutory planning policy for Dublin. No rationale (evidence-based or otherwise) is given in any Dublin City Council plan or document as to why Parliament Street, the first Wide Streets Commission street is to be considered of lesser architectural heritage importance, or, indeed, civic importance, that the later spaces at College Green and Westmoreland Street, which are to be the focus of the subject initiative by Dublin City Council. Dublin City Council appears to be proposing a selective and piecemeal approach to the management of Dublin’s historic core, where certain historic streets of major and international heritage importance will be actively damaged to facilitate the conservation and improvement of other apparently more worthy streets. Such an approach to the current proposals and, indeed, future development of Dublin’s public realm will seriously undermine the integrity of the Historic City of Dublin, identified on the UNESCO World Heritage Tentative List for Ireland, and will result in major and potentially irreversible impacts on the architectural and cultural heritage of the city.

Figure 1: View from Capel Street overlooking Essex Bridge Dublin by James Malton (1797) reproduced with the kind permission of the National Library of Ireland

Significant negative impact of the proposal on Parliament Street and Dublin as a whole
Dublin City Council have accepted that the volume and extent of bus traffic currently passing through College Green results in significant negative impacts on the public realm and the experience of residents of and visitors to the City, on business owners and on the architectural heritage and civic quality of Dublin. The impacts of significant volumes of traffic of large vehicles are well known:

• Noise
• Vibration
• Pollution and impacts on air quality
• Visual impacts
• Creation of hostile environment for pedestrians and cyclists
• Impacts on residents
• Impacts on the operation of businesses

The impacts of bus traffic on the historic core of Dublin are especially significant due to the use of double decker buses and the additional impacts that the scale of those buses cause. The use of double decker buses is not the norm in most historic cities and many cities have taken steps to ban double decker buses or control the size of vehicles entering sensitive historic areas (e.g. French Quarter, New Orleans; Alamo Square, San Francisco; Savannah).

There are numerous direct and indirect references to this in the current and draft Development Plans, in the Dublin City Centre Transport Study Consultation Document (June 2015) and the College Green Traffic Management Measures Public Consultation Document, which is the subject of this letter. For example, the Dublin City Centre Transport Study Consultation Document states:

“The new design will provide an attractive pedestrian route for Dubliners and tourists to move from the north of the city from O’Connell Street through the College Green area to St. Stephen’s Green in a pleasant, safe and pedestrian friendly environment. Specifically, the new design will enable pedestrians to move between Grafton Street and the Quays by negotiating only one short pedestrian crossing.

The introduction of the proposed transport changes facilitating an improved public realm, will allow people to enjoy some of the best of Dublin’s architectural heritage in comfort and space, and will significantly raise the profile and attractiveness of the large retail premises facing onto College Green. The new open space will provide opportunities to anchor the ‘Civic Spine’ of the City at the front of Trinity College, creating a natural people gathering location.” [Emphasis added.]

If it is the case that civic character of College Green will be significantly improved for both pedestrians and business owners by the reduction of bus traffic, the corollary must also be true: Parliament Street will be significantly disimproved as a result of the proposed massive increase in bus traffic.

These negative impacts on the public realm of Parliament Street result in both short-term and long-term implications for the conservation and architectural integrity of Parliament Street:

• Parliament Street is significantly narrower than much of Dame Street and College Green and, as such, has a lower capacity. In order to accommodate the very considerable increase in bus trips now proposed under the College Green Traffic Management Measures Public Consultation Document, including right and left turns from Dame Street, it seems likely that physical alterations to the street will have to be carried out (e.g. such as the narrowing of footpaths, the removal of historic kerbing; the widening of the junction with Dame Street). This will result in a permanent and negative change to the character of the street;
• The Society is given to understand that, as a result of the subject proposals, bus movements on Parliament Street will increase from 85 movements per day to something of the order of 1,700 movements per day. The scale of the double decker buses traversing and queuing on Grattan Bridge and Parliament Street will form a significant element in the key view/prospect of City Hall from locations along Capel Street, Grattan Bridge and Parliament Street for much of the time.
• The considerable increase in noise and vibration and loss of air quality, in combination with the reduction in safety and amenity for pedestrians and cyclists, is likely to significantly impact upon the viability of occupancy of residences and businesses on Parliament Street. As outlined in the Architectural Heritage Protection Guidelines for Planning Authorities, “it is generally recognised that the best method of conserving a historic building is to keep it in active use”. Parliament Street is a thriving commercial street at ground level throughout the day and into the night, with many people living on the upper floors of buildings. Long-term occupancy on Parliament Street is likely to trigger the rapid decline and loss of buildings of architectural heritage importance.

What is perhaps most alarming about the proposals outlined in the College Green Traffic Management Measures Public Consultation Document is the lack of any policy basis for the decision, the lack of any evidence-based rationale for the choice of Parliament Street as a bus relief route, the consideration of any alternatives or indeed any impact assessment of any kind. Specifically:

• While the carrying out of “environmental improvements” to College Green has long been a policy of Dublin City Council, there are no policies set out in the Dublin City Development Plan 2011-2017 or the Draft Dublin City Development Plan 2016-2022 for significant changes to the character of Parliament Street or for the bisecting of Temple Bar (“the key cultural/creative quarter of the city”) by a bus corridor. As such, these major policy changes as regards both Parliament Street and Temple Bar have neither been subject to the democratic rigours of the development plan process, nor to Strategic Environmental Assessment.
• A Strategic Environmental Assessment was not carried out on the Dublin City Centre Transport Study Consultation Document or on the College Green Traffic Management Measures Public Consultation Document. Indeed, no assessment of the potential impacts of the proposals outlined in either document appears to have ever been carried out.
• No evidence of the continued need for the operation of the bus routes in question has been provided to support the proposals in the College Green Traffic Management Measures Public Consultation Document or to indicate that the routes along Parliament Street are appropriate in the context of the needs of the users of those services.
• No alternatives appear to have been considered.

Having regard to the potential for the subject proposals to result in permanent and irrevocable damage to Parliament Street, the first Wide Streets Commission Street and the foundation stone of the Georgian core of Dublin, the Society considers it to be grossly premature to proceed with the creation of a major two way bus corridor on Parliament Street until all potential impacts and alternatives have been considered.

Alternatives and the need for outstanding public transport
While the Society has major concerns about the detail of the subject proposals for Parliament street under the College Green Traffic Management Measures Public Consultation Document, the Society strongly supports national, regional and local policy for modal shift from the private car to more sustainable methods of transport such as walking, cycling and public transport. Aside from the obvious environmental concerns, traffic congestion, and the resulting negative impacts of noise, vibration and pollution, is also, of itself, a major threat to historic environments. Conversely, accessibility is key to the continued viability, occupancy and, therefore, survival of historic cores. A strong and efficient public transport system is, therefore, of critical importance to the management and conservation of a city of architectural heritage importance.

There are numerous international examples of high quality bus networks operating successfully in historic centres (e.g. Nantes, Zurich, Frankfurt). However, it is critical that any public transport proposals for the core of Dublin City Centre are developed in a comprehensive way and on a citywide basis in order to ensure efficiencies, to ensure maximum accessibility, to minimise impacts and to ensure the maximum exploitation of the advantages (e.g. the College Green civic space).

The attached exercise, illustrates a proposed High Quality Network for Dublin City Centre, prepared by David O’Connor (DIT Environment & Planning).

The High Quality Network is based on the Dublin Frequent Transport Network, a schematic transit diagram, created by Colin Broderick, BSc Spatial Planning (DIT), of the existing high frequency public transport network in Dublin (in this case defined as routes which operate on at least a 15 minute daytime frequency).  The Dublin Frequent Transport Map is available at: http://cbroderick.me/dublin/

The purpose of the High Quality Network for Dublin City Centre is to demonstrate how the city could viably be planned into a series of walkable cells well served by a high quality public transport network.  There are numerous international examples of such high quality bus networks operating successfully in historic centres (e.g. Barcelona, Frankfurt, Nantes, Oxford, Stockholm, Zurich).

Cities like Barcelona and Zurich (which has the highest public transport quotient in the world) use the principle of 300m walkable cells, to which the attached proposal accords.  In all such cases, the cells are protected by a high level of traffic management and well served by a High Quality Network of bus and light rail corridors. 

For the network to be successful, there must be a consistently high level of service and also a high level of transferability.  Importantly, all points within the Dublin High Quality Network (with the exception of the Dame Street spur) are accessible within a single transfer.  The design of attractive, legible and amenable high quality transfer points would be entirely essential in this regard. 

The proposal does not purport to be a final planned network layout for the city centre, given the insufficient access to data and resources necessary for such a strategic and sensitive project.  Its main purpose is to demonstrate that viable alternatives exist which merit consideration.

However, it is most critical that any public transport proposals for the core of Dublin City Centre are developed in a comprehensive way and on a citywide basis in order to ensure efficiencies, to ensure maximum accessibility, to minimise impacts and to ensure the maximum exploitation of the cities advantages (e.g. the College Green civic space).

The proposals are predicated on a significant reduction in traffic levels induced by the elimination of through trips, as proposed in the City Council’s Transport Study, and also a significant increase in public transport level of service.  Currently, 21% of people in Dublin City and Suburbs use public transport for their main commute.  To compete economically with comparable European cities, levels of 30-50% are required.  This is only achievable with a well-planned High Quality Network for the city centre.  A wider perspective is also required, including orbital routes and high quality interchanges in suburban centres. 

The Society is pleased to submit this proposal for a Dublin High Quality Network by way of an example of an alternative approach.  The Society urges Dublin City Council to take a more strategic approach to traffic management measures in relation to both College Green and the wider City as a whole. It is essential that any such strategic approach be developed in agreement with planning, architectural, conservation, landscape and transport professionals and all other relevant stakeholders (including residents and business owners).

The piecemeal and sectoral approach whereby small incremental changes are made to certain bus routes causing damage to the public realm (as has happened at College Green and is now proposed at Parliament Street) cannot be sustained.  Dublin City Council and the National Transport Authority must invest the necessary resources to plan a sustainable and viable city to serve all its inhabitants and protect its environment for future generations.

Figure 2: Paradeplatz, Zurich is one of five major interchanges surrounding Zurich city centre, itself a largely pedestrian environment.  Zurich is one of the wealthiest cities in the world and boasts the highest public transport mode share, achieved largely through traffic management and high quality services.

Figure 3: A BRT / LRT Interchange, adjacent to Nantes medieval centre (photo taken from Chateau de Ducs) shows how well design public transport can be part of an attractive public realm

Figure 4: St Aldates Bus Interchange outside Tom Tower, Christchurch College in Oxford demonstrates how a well planned high frequency bus network can complement an attractive accessible and sensitively conserved heritage environment

Conclusion
The Irish Georgian Society welcomes, in principle, proposals for environmental improvements to College Green and the creation of a new civic space outlined in the College Green Traffic Management Measures Public Consultation Document. However, the Society is gravely concerned by Dublin City Council proposals to improve the public realm at College Green through the diversion of problematic bus traffic to Parliament Street, which, as the first Wide Street Commissioners’ street was the first step in the layout of the Georgian City of Dublin. Merely moving the problematic traffic elsewhere within the Georgian core to the detriment of a vulnerable area of architectural heritage importance will negate any benefit to the civic character of Dublin to be gained through the development of the new College Green civic space. For the reasons outlined above, the Irish Georgian Society suggests that traffic management measures for College Green must must go further and include the formulation of an integrated plan for bus transport for all of Dublin City.