The IGS has called for a public acquisition of the ‘Armada Table’ which the Knight of Glin and James Peil describe as “one of the most important and earliest pieces of ‘Irish’ furniture” (Irish Furniture, 2007). In a letter to Josepha Madigan TD, Minister for Culture, Heritage & the Gaeltacht, the Society wrote the following:

The sale of the ‘Armada Table’ is most regrettable given its centuries-long ownership by the O’Brien family and its association with the great castles of Co. Clare they once resided' in: Lemenagh, Dromoland and Bunratty. Their custodianship of the table has ensured the survival of an item of furniture of national importance to our decorative arts heritage, and which represents one of the very few examples of woodcarving from the Early Modern Period in Ireland. Furthermore, their loan of the table to Bunratty Castle since the 1960s has presented an opportunity for countless visitors to see it within an old O’Brien home.

The significance of the table to Ireland’s cultural patrimony and to that of Co. Clare provides every reason for public intervention to ensure it not only remains in the country but continues to be on public view. An opportunity to finance such a public acquisition could be presented through the provisions of the Heritage Fund Act 2001 and if not, other public-private solutions should be sought as a matter of urgency with the auction scheduled for mid-October.

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Building Height Guidelines 2018 Consultation
Department of the Housing, Planning and Local Government
Custom House
Dublin 1
D01 W6X0

[by email to forwardplanning@housing.gov.ie]

Date:    24^th September 2018

Re:       Public Consultation on DRAFT Urban Development and Building Heights Guidelines for Planning Authorities

Dear Sir or Madam,

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 considers that the Draft Urban Development and Building Heights Guidelines for Planning Authorities, in their current form, fail to address the clear objectives of the National Planning Framework for the conservation and management of our built heritage “which has intrinsic value in defining the character of urban and rural areas and adding to their attractiveness and sense of place.” Given that the European cities with the greatest population density are low rise cities and given that the existing historic built environment (e.g. Georgian Dublin) provides some of the highest residential densities in the country, a clear evidence basis for the need to drive “a general increase in building heights” must be articulated before any new policy for building heights is adopted.

Inconsistency of the Draft Guidelines with the National Planning Framework

The National Planning Framework (NPF) makes numerous references to the importance of built heritage in defining the character of our cities, towns and villages; in preserving our shared cultural identity; and for tourism, particularly in rural areas. Built heritage is placed at the core of the NPF and one of ten National Strategic Outcomes states that the Government “will conserve, manage and present our heritage for its intrinsic value and as a support to economic renewal and sustainable employment.”

Under Section 1.3: Shared Goals – Our National Strategic Outcomes, the NPF describes the intention behind National Strategic Outcome 7: Enhanced Amenities and Heritage as follows:

“This will ensure that our cities, towns and villages are attractive and can offer a good quality of life. It will require investment in well-designed public realm, which includes public spaces, parks and streets, as well as recreational infrastructure. It also includes amenities in rural areas, such as national and forest parks, activity-based tourism and trails such as greenways, blueways and peatways. This is linked to and must integrate with our built, cultural and natural heritage, which has intrinsic value in defining the character of urban and rural areas and adding to their attractiveness and sense of place.” [Emphasis added.]

Notwithstanding this, the Draft Urban Development and Building Heights Guidelines for Planning Authorities make no meaningful reference to heritage or to the historic built environment. Failure to explicitly address the issue of building height in historic environments, in combination with pejorative reference to “traditional building heights”, would seem to imply that protection of Ireland’s historic built environment is a secondary matter and, indeed, an obstacle to the sustainable development. This is factually incorrect as historic built environments provide a model for high amenity and attractive, high density residential development with a strong sense of place. For example, Paul Keogh Architect's conference presentation to the Maximising the City's Potential - Creating Sustainable Communities conference on 22nd April 2008 identified the density of Georgian Dublin as 165 dwellings per hectare. This is more than three times the minimum density for brownfield sites within city or town centres (50 units per hectare) set out in the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas.

The Society considers the failure to address the issue of building heights in historic areas is particularly troubling given that the objective of the Draft Guidelines and how the Guidelines are to be implemented is very unclear. Specifically, the Draft Guidelines do not clarify what is meant by “driving general increases in building heights”, an obligation imposed on Planning Authorities under Specific Planning Policy Requirement 2. The wording of this mandatory requirement raises a considerable number of questions, including:

• Is it the Department’s intention that building heights must be increased throughout urban areas irrespective of context or only at suitable locations with urban areas should be identified for increased height?
• Did a survey of densities correlated to building heights in urban areas identify that appropriate densities cannot be achieved in development conforming to “traditional building heights”? If so, when will this data should be made available to the public?
• Is the objective of the Draft Guidelines to ensure that new development achieves sustainable use of land by meeting a certain density? If so, this is not clear from the Consultation Draft, which appears to conflate the issues of density and height. As noted above, research carried out in Ireland and abroad (e.g. by the UK Urban Task Force) has shown that high densities can be achieved at relatively low building heights. However, the wording of SPPR 2 appears to suggest that new development must not only be high density, but also high in height. No evidence basis for this new requirement is provided.

National Policy Objective 13 of the National Planning Framework provides that “In urban areas, planning and related standards, including in particular building height and car parking will be based on performance criteria that seek to achieve well-designed high quality outcomes in order to achieve targeted growth. These standards will be subject to a range of tolerance that enables alternative solutions to be proposed to achieve stated outcomes, provided public safety is not compromised and the environment is suitably protected.” [Emphasis added]. As noted above, the historic built environment is clearly identified in the NPF as an element of the environment that will be protected. Given this, the Society respectfully submits that failure to comprehensively address how increased building height will be achieved in the historic built environment in a manner that does not undermine the character of our historic villages, towns and cities renders the Draft Guidelines inconsistent with the National Planning Framework.

Legal implications of SPPR 1 on heritage designations

The Society notes the contents of SPPR 1 of the Draft Guidelines, which states that “statutory plans … shall not provide for blanket numerical limitation on building heights”. The Society further notes that, under section 32 of the Planning and Development (Amendment) Act 2018, which has yet to be commenced, any provision of a statutory plan, which is inconsistent with a SPPR, will be deemed to have been deleted. 

The Planning and Development Act 2000, as amended, sets out a process for the designation of Architectural Conservation Areas under the development plan “to preserve the character of a place, area, group of structures or townscape, taking account of building lines and heights” [Emphasis added.] Given this, the provisions of many ACAs limit the height of new development to existing building heights (e.g. this is particularly the case in historic built environments of uniform character like Georgian squares).

The Society supports the removal of arbitrary height standards (e.g. minimum or maximum heights) from local area plans and development plans. For example, the historic core of Dublin has a widely varied character, ranging from fine grain single storey worker’s cottages to large and tall buildings such as the former Jervis Street hospital). The appropriateness of any large or tall building in an urban location must primarily be assessed on the basis of the response of the proposed development to its context in terms of scale, bulk, height, massing and design by the planning authority.

However, the objective of an Architectural Conservation Area designation is the protection of a group of structures or townscape. Given this and having regard to the fact that height is often an integral element of the character of historic townscape, deletion of sections relating to height and preservation of existing building heights from provisions within a development plan relating to architectural conservation areas has the potential to undermine the purpose and efficacy of existing designations for heritage areas. Any guidelines on building height must clearly state that provisions contained therein will not undermine or alter the controls in place for areas designated as Architectural Conservation Areas or Areas of Special Planning Control under Planning and Development Act 2000, as amended.

Inadequate Development Management Criteria will lead to negative impacts on heritage

The Society respectfully submits that the application of the Development Management Criteria outlined in the Draft Guidelines will not provide an adequate level of protection against significant negative impacts on architectural heritage and the historic built environment. Protection of architectural heritage and preservation of character of historic built environments must be identified explicitly as Development Management Criteria. Having regard to the interactions between visual impacts on the built environment and impacts on cultural heritage (e.g. as referenced in the 2014 EIA Directive), if the Draft Guidelines propose to list which “suitably qualified professionals” should prepare reports, it is important that conservation professionals be listed in this section as well.

It is considered that the Development Management Criteria give a misleading impression as to the capacity of historic centres to absorb high buildings, which is likely to give rise to uncertainty and delay for investors and developers. For example, the Guidelines state: “City centre development in several UK and EU cities have successfully managed to both consolidate development through increased building heights, working sensitively and imaginatively with existing sensitive architectural building contexts – e.g. central London through the London Plan.” The Society questions the basis for this assertion. The development of tall buildings in London has and continues to the be the subject of very considerable opposition, with a 2016 survey finding that 60% of Londoners supporting the imposition of restrictions on tall buildings[1]. It is also notable that the cities with the highest population density in Europe (Paris and Athens) also impose stringent height restrictions on building heights with the historic core. Moreover, given that the ‘History City of Dublin’ is on the UNESCO Tentative World Heritage List, it is considered significant that UNESCO is sharply critical of the impact of tall buildings on the integrity and value of World Heritage Sites (e.g. issues arose in respect of the construction of the Torre Seville in Seville, Spain; the proposed construction of a 120 m skyscraper in Budapest, Hungary; proposals for a hotel at the Old Royal High School, Edinburgh, Scotland (subsequently refused permission); various plans for tall buildings in Paris, France, notwithstanding the location of these buildings outside the historic core). In Dublin, numerous applications for tall buildings in proximity to the Georgian core have been refused permission as a result of the likely negative impact on the historic built environment (e.g. proposals for tall buildings at Tara Street, Liberty Hall and the new Children’s Hospital of Ireland at the Mater Hospital). Any guidelines on building height must be realistic and implementable. It is, therefore, of critical importance that the constraints on building height (rather than density) in new development in or near historic centres are clearly articulated.

Conclusion

In conclusion, the Irish Georgian Society wishes to express its concern that heritage and the protection of the historic urban environment would not appear to have been considered in the preparation of the Draft Urban Development and Building Heights Guidelines. Given the value of preservation of the historic environment in terms of sustainability, the economy and our cultural and social heritage, it is of critical importance, therefore, that the historic built environment is placed at the heart of an integrated vision for the delivery of sustainable communities and consolidation of urban areas in order to avoid uncertainty and delay for all stakeholders within the planning process.

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

Yours faithfully,

Donough Cahill
Executive Director
Irish Georgian Society

[1] Londoners back limit on skyscrapers as fears for capital’s skyline grow. The Guardian. 27th August 2016.

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The John Nankivell exhibition will be closed on Saturday 29 September for a private event. The exhibition will reopen at 2pm that afternoon.

We apologise for any inconvenience caused.

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For Culture Night 2018 (Friday 21 September), the City Assembly House is open late to the public, from 6pm until 9pm, giving visitors the opportunity to see our autumn exhibition Vain Transitory Splendours': The Irish Country House and the Art of John Nankivell.

We are delighted to partner with DIT Conservatory of Music and Drama to host a series of short musical performances every half hour by students of DIT Conservatory of Music and Drama

Musical programme for Culture Night 2018 at the City Assembly House

6.00pm       Tomas Pujol Owens (Violin), Anna Szombathy (Harp)
6.30pm       Préachán – Irish Traditional Music: Fionn ÓhAlmhain (Uilleann Pipes) Jack Hennessy (Flute) 
7.00pm       Tomas Pujol Owens (Violin), Anna Szombathy (Harp)
7.30pm       Maria Matthews (soprano) Meadhbh McKenna (Harp)
8.00pm       Préachán – Irish Traditional Music: Fionn ÓhAlmhain (Uilleann Pipes) Jack Hennessy (Flute)
8.30pm       Incantato String Quartet – Inana Garis, Anna McKenna (Violins), Dionne Tims (Viola), Peadar O’Loinisgh (Cello)

See the full list of events in Dublin and nationwide on www.culturenight.ie 

(Images: Stokestown Park House, Co. Roscommon)

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The Irish Georgian Society is seeking two part-time employees (Shop & Events Assistants) to work in its bookshop and assist with running events at its premises, City Assembly House, 58 South William Street, Dublin 2. 

Candidates should have an enthusiasm for Ireland’s cultural heritage, art and architecture, and have retail experience. They will need to be available to work a minimum of two days a week and have flexibility with hours. The salary is €11 per hour.

Applicants should email their CV along with a cover letter to Donough Cahill, Executive Director, Irish Georgian Society - recruitment@igs.ie. 

Deadline for applications is by 5pm on Wednesday 26th September 2018.

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Eoghan Murphy TD
Minister for Housing, Planning, Community and Local Government
Department of Housing, Planning, Community and Local Government
Custom House
Dublin D01 W6X0

17 September 2018

Re. Urgent need to complete National Landscape Character Assessment to facilitate development of renewable energy infrastructure

Dear Minister Murphy,

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 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 Society advocates for sustainable development, as defined in Our Common Future (or the Brundtland Report) published by the United Nations World Commission on Environment and Development in 1987. As set out in the 2005 UNESCO publication UNESCO and Sustainable Development: “Culture is increasingly recognized as an essential dimension of sustainable development, particularly since the 2002 Johannesburg Summit”. The work of the Society in encouraging and promoting the conservation of distinguished examples of architecture, the allied arts and historic landscape in Ireland is, therefore, inextricably linked with the concept sustainable development. The Society has made numerous submissions to the Department in the past as part of policy consultations highlighting the sustainable reuse and regeneration of historic building stock as a key pillar of sustainable development. It should go without saying that the Society further supports the shift away from reliance on fossil fuels towards renewable energy for obvious reasons, but it is also worth noting that embracing renewable energy technologies can facilitate the protection of large rural demesnes of very significant heritage importance into the future. In this regard, the Society welcomes the pioneering approach to seek to support the long-term viability of the Beaulieu House and lands in Co. Louth with the sensitive development of a solar farm at an appropriate location within the demesne.

The Society, however, is gravely concerned by the haphazard approach to locating regional and national level renewable energy projects. Specifically, there is nothing in statutory planning policy, which would help to direct those renewable energy projects likely to result in significant changes to the landscape to areas of less sensitivity.

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.  Furthermore, 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.

Woodlands, wooded valleys, boundary planting and hedge rows form important ecological corridors and networks, so important not only to maintain biodiversity but also in their contribution to carbon sequestering.

The Society notes that numerous applications for strategic renewable energy developments (and, in particular, wind energy developments) have been wholly or partly refused permission due to potential impacts on cultural heritage, including impacts on sensitive landscapes of heritage significance. Wind energy developments have been proposed in close proximity to some of Ireland’s most valued historic landscapes, such as the great landscape of the Blackwater in Waterford and the designed landscapes at Headfort, Co. Meath and Whitewood, Co. Meath.

There is no specific reference to the potential impacts of wind energy developments on built heritage, the historic environment or landscapes of heritage importance in the Wind Energy Guidelines 2006, or the subsequent draft revisions to those guidelines.  Indeed, the original 2006 Guidelines go so far as to highlight that heritage designations do not preclude wind energy development.  Having regard to the stronger position on heritage expressed in policy documents in other jurisdictions, such as in Wind Energy and the Historic Environment (revised by English Heritage in 2012) and the UK Planning Policy Statement 22: Renewable Energy (PPS 22), this is considered to be confusing. Aside from endangering our shared historic environment, failure to set out a clear policy for the protection of sensitive landscapes leads to uncertainty for communities, planning authorities, An Bord Pleanála, developers and investors.

National Policy Objective 61 of the National Planning Framework states that the Government will “facilitate landscape protection, management and change through the preparation of a National Landscape Character Map and development of guidance on local landscape character assessments, (including historic landscape characterisation) to ensure a consistent approach to landscape character assessment, particularly across planning and administrative boundaries.” Having regard for the potential for development, and, in particular, the development of renewable energy projects, to result in impacts and cumulative impacts on sensitive landscapes, it is essential that a detailed analysis of Ireland’s landscape is carried as a matter of urgency in order to ensure that development is directed towards appropriate locations. The completion of the NIAH Survey of Historic Gardens and Designed Landscapes will also be of significant importance in determining preferred locations for major renewable energy and energy infrastructure development.

Having regard to the matters raised above, the Society calls on the Government to take swift action to complete the National Landscape Character Assessment. The publication of a National Landscape Character Map will help to ensure the protection and management of landscape as one of Ireland’s most important and most valuable physical assets, while at the same time providing much needed certainty to developers and investors seeking appropriate locations for major new renewable energy projects as we move towards achieving a carbon-free society by 2050.

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

Yours faithfully,

Donough Cahill
Executive Director IGS

c.c. Josepha Madigan TD, Minister for Culture, Heritage and the Gaeltacht

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