Planning Department
Dublin City Council
Civic Offices
Wood Quay
Dublin 2

Date: Wednesday 5th April 2017

Location: 2 Grand Parade, Dublin 6

Reference No: 2373/17
Applicant: Grand Parade Property Trading Company.

Proposal: The application site has an area of c. 0.576 hectares and contains the former Carroll's Building which is a Protected Structure (RPS Ref.: 3280) and a number of outbuildings. The application site is located to the north of No. 19A and 19-25 Dartmouth Road, Dublin 6, D06 CV44. Development will consist of refurbishment and alterations to the existing 8 storey Carroll's Building (a protected structure RPS Ref. 3280), to include refurbishment of original features and removal of later building fabric, including a single storey rear extension. The proposed alterations include a change of use from office to cafe / restaurant at basement and ground floor level and a gallery / multi-purpose space at first floor level. External alterations to the protected structure include replacement glazing, the reinstatement of the original undercroft, alterations to the existing plant area at roof level and landscaping to the curtilage of the existing Protected Structure. Demolition of 3 no. existing warehouse / light industrial building to the south of the Protected Structure and other ancillary structures on the site. Provision of a new part 3, part 4, part 5 and part 6 storey, over two levels of basement, new office building to the south of and setback from the Carroll's Building. The proposed office building is connected to the Carroll's Building by a 6 storey glazed atrium and an 8 storey link which provides for new shared circulation / lobby and a services core. A roof terrace is provided at fourth and fifth floor level. The proposed office extension has a total GFA of 10,658 sq.m including basement floorspace. Vehicular access to the office building and basement car park will be from Grand Parade and a secondary controlled vehicular access will be provided from Dartmouth Road. The development includes 30 no. car parking spaces, 126 no. bicycle spaces, changing facilities and plant area, including electrical rooms, substation and swichrooms at basement level - 1. A plant room is also provided at basement level -2. 9 no. surface level car parking spaces are provided. The total floorspace, including existing retained and proposed new floorspace, including basement area, to be provided on site is 15,647 sq.m GFA. The development includes all associated site development works, hard and soft landscaping and all other ancillary works.

 

Dear Planning Officer,

The Irish Georgian Society writes to raise our concerns about the above application which we maintain will have a detrimental impact on the architectural set piece, Dartmouth Square.

Dartmouth Square is designated an Architectural Conservation Area in the Dublin City Development Plan.  It is the last in the tradition of formal Georgian and Victorian squares developed in Dublin. 

Architectural Conservation Area
Dublin City Council’s Architectural Conservation Area statement describes Dartmouth Square as "one of a series of formal Victorian residential squares ... laid out in Dublin in the nineteenth century".  The houses lining the four sides of the rectangular square are described as being "identical in design and ... good examples of Dublin's Victorian residential architecture."  The ACA statement also notes that the ‘relationship of the landscaped central park to the uniform red brick residential Victorian terraces forms an integral component of this architectural set piece.".  It continues by noting that ‘the central [garden] area retains its private, enclosed character, created by dense belts of mature trees, low plinth wall and wrought-iron railings along all four sides of the boundary. The sylvan character of Dartmouth Square gives the area a secluded special character and a welcome peaceful feeling of separation from the urban bustle."

Transitional Zone Areas
While the application site has a Z6 land-use zoning designation, seeking to facilitate enterprise and employment creation, Dartmouth Square has Z2 Residential Conservation Area land-use zoning (in addition to the Architectural Conservation Area designation) which seeks to protect and/or improve the amenities of the residential conservation area.

Section 14.7 of the Dublin City Development Plan 2016-22 relates to development in transitional zones and is relevant to the proposed development at Grand Parade. It states: "The land-use zoning objectives and control standards show the boundaries between zones.  While the zoning objectives and development management standards indicate the different uses permitted in each zone, it is important to avoid abrupt transitions in scale and use zones.  In dealing with development proposals in these contiguous transitional zone areas, it is necessary to avoid developments that would be detrimental to the amenities of the more environmentally sensitive zones.  For instance, in zones abutting residential areas or abutting residential development within predominately mixed-use zones, particular attention must be paid to the use, scale, density and design of development proposals and to landscaping and screening proposals in order to protect the amenities of residential properties."

Dartmouth Square, on account of the good quality period brick residences laid out in a formal square, and the residential use of these properties, is a zone of very high environmental sensitivity. The proposed development to the rear of the Carroll's building, on account of its large scale (including an atrium to the full height of the existing building) and direct proximity to the square would form an abrupt transition in scale between the two zones and would be severely detrimental to the amenities of the more environmentally sensitive zone (Dartmouth Square). As such the proposed development would be in serious conflict with the City Development Plan provision on Transitional Zone Areas as quoted. Note also the provision specifically seeks development sensitivity where sites abut residential areas.

Protected Structures
The site at Grand Parade is not an average commercial site in Dublin as it is surrounded on three sides by streets of period residential houses (protected structures). Of particular sensitivity within these streets is Dartmouth Square West as it lies directly (within metres) to the east of the application site where development is proposed.

The individual houses lining Dartmouth Square are all protected structures. As with the Architectural Conservation Area and Residential Conservation Area (zoning) designations, particular sensitivity is required when developing adjacent to Protect Structures so as to avoid adverse effect and preserve existing amenities.

It is the Policy of Dublin City Council: "To ensure that the special interest of protected structures is protected." (Policy CHC2).  This policy further requires that "Development will conserve and enhance Protected Structures and their curtilage and will ... not cause harm to the curtilage of the structure; therefore, the design, form, scale, height, proportions, siting and materials of new development should relate to and complement the special character of the protected structure"

Section 11.1.5.3 of the Development Plan further states: "The curtilage of a Protected Structure is often an essential part of the structure’s special interest. In certain circumstances, the curtilage may comprise a clearly defined garden or grounds, which may have been laid out to complement the design or function. However, the curtilage of a structure can also be expansive and can be affected by development at some distance away ... Any development which has an adverse impact on the setting of a protected structure will be refused planning permission."

The proposed development at Grand Parade, in view of its excessive scale and close proximity to protected structures at Dartmouth Square West, would severely harm the curtilage of these protected structures, would fail to relate to and complement their special character, would fail to avoid adverse impact on their setting and so is in serious conflict with the City Development Plan policy and provision on protected structures. 

In conclusion, the site at Grand Parade is inappropriate for the type of development proposed due to its close proximity to the many protected structures, in particular those located on Dartmouth Square, which also has Architectural Conservation Area designation. 

In view of the above reasons, the Irish Georgian Society appeals to Dublin City Council to refuse permission for the development.

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We are delighted to partner with the Ulster Architectural Heritage Society for a second cross-border biennial summer school!

Once again, this special event brings together students, experts and enthusiasts to explore, discuss, debate and enjoy issues relating to our shared Irish heritage in the context of Derry City & Strabane and Donegal. The event will focus on conservation and heritage led regeneration in the built environment of North West Ulster.

We are pleased to offer a number of free places for students on this year’s summer school. These places include attendance at the full event, three nights accommodation in Letterkenny, transport to and from venues and all meals during the event. 

If you wish to be considered for a student place, please complete this form by 5.00pm on 1st May 2017. Places will be allocated by mid May 2017 and successful candidates will be notified. Student ID is required. 

2015 Summer School participants.

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23rd March 2017

The Irish Georgian Society welcomes this opportunity to comment on the consultation paper, Review of Section 482 Relief, issued by the Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs, and the Department of Finance, and aims to respond in the context of the Consultation Questions posed in the paper.

1. Is the exchequer’s support of historic buildings and gardens through section 482 relief an efficient use of resources and if so why?

The Irish Georgian Society is of the view that section 482 relief provides an efficient use of resources and wishes to consider this in the context of (i) the legislative obligation of owners to protect their properties, (ii) research into the benefit of fiscal incentives, and (iii) the tourism benefits of section 482.

(i) Supporting legislative obligations

Ireland’s architectural heritage constitutes an essential part of our cultural patrimony and makes an invaluable contribution to the character and appeal of our urban and rural landscapes. Measures to protect this heritage are provided through the Planning Acts which place an obligation on the part of owners to preserve and protect their properties and to prevent their endangerment. Failure to comply with these obligations carries the potential of significant penalties yet fulfilling them can place a financial burden on owners given additional costs involved in undertaking conservation or maintenance works.

Section 482 relief provides important and often vital support in assisting owners of buildings and gardens that are intrinsically of significant scientific, historical, architectural or aesthetic interest in complying with these legislative requirements. Furthermore, its delivery through the tax system presents an efficient means of managing state support through minimising the bureaucracy that is necessarily generated through a grants programme.

(ii) Research on fiscal incentives

In a Heritage Council commissioned report, Ecorys in partnership with Fitzpatrick Associates stated that “there is a strong justification for public intervention and investment in heritage on economic grounds”. They noted this “rationale for public intervention is based on the correction of market failure owing to heritage's public good characteristics”. They also observed that this intervention may take a variety of forms and in doing so cited the role of monetary incentives, including those provided through taxation.

In exploring international comparisons of fiscal mechanisms relating to heritage conservation, Pickard and Pickerill observed that they “offer an effective mechanism to encourage private investment in the repair and maintenance of the architectural heritage by owner-occupiers, owner-investors, developers and investors”. They also noted the benefit of fiscal support for maintenance stating that such works are “the most sustainable and cost effective intervention method in architectural heritage conservation as it negates the necessity for large scale publicly funded repair projects in the long term“.

In considering Section 482 relief, Bacon observed that though “there is not a lot of data in terms of the cost of the incentive, its effectiveness or its efficiency… it continues to be available in respect of a limited number of properties. It is likely that it has made a positive contribution as it helps ensure that eligible properties are open to the public and kept in a good state of repair”.

(iii) Tourism and public benefits of Section 482

Tax relief through Section 482 has provided essential support to historic building and garden owners since its introduction in 1982. The return on investment for the State is most apparent in the requirement for participant properties to open to the public for at least 60 days in one year. With c. 160 properties currently availing of the relief, the number of heritage destinations available to domestic and international tourists is significantly larger than may otherwise be the case.

The scale of the houses, castles and gardens tourism market is indicated through Fáilte Ireland statistics which show that in 2014 nearly three million overseas tourists visited house and castle destinations with 1.9m visiting gardens. Of the domestic tourist market, 26% visited houses and castles and 21% visited gardens whilst, to compare with other activities, 18% took part in water sport activities and 7% in golf5.

In addition to the tourism benefits of Section 482 properties, the access provided to otherwise private properties presents an important resource to scholars of history, architecture, horticulture and other disciplines.

2. Is the current scheme maximising the potential economic benefits in terms of stimulating local economic development and the repair, maintenance or restoration of historic buildings and gardens? If not, why not?

As visitor destinations, Section 482 properties can have a multiplier effect on the local economy. Ecorys and Fitzpatrick Associates6 noted that “where an historic site draws large numbers of visitors…, then local retailers, restaurants/ hotels etc. may also be expected to benefit to a considerable degree from the additional expenditure associated with these visitors”. In the case of smaller section 482 properties, it can be surmised that local economies should also benefit through the employment of workers for conservation and maintenance works, through the need to staff sites during visiting times, and through commercial activity by visitors to the area.

To fully answer this question the Irish Georgian Society suggests that research be undertaken into the local economic benefits of section 482. In the absence of available information, we wish to note the following findings of the Ecorys and Fitzpatrick Associates report7 which highlights the economic, social and community benefits of the historic built environment. These finding could in turn serve as an indicator of the benefits generated through section 482 relief.

• “The historic environment plays a substantial role in supporting skills development. In the case of the construction sector, this is manifested in development and subsequent retention of craft-based skills within Ireland, and which are frequently utilised within higher value elements of construction activity.
• Ireland's built historic environment constitutes an invaluable educational resource, and at all stages of the lifelong learning spectrum. For example, not only are Ireland's flagship heritage sites a major source of school educational visits, they are also a focus for academic research and conference activities.
• Although Ireland has a relatively limited tradition of volunteering, it is sufficiently clear that the built heritage assets have served as a notable focus for community and voluntary activities to support conservation and promotion of the historic environment.
• The maintenance and repair of historic buildings, and particularly clusters of historic buildings, have enhancing the physical fabric of many Irish cities. Positively, this has been beneficial in terms of further supporting the growth of tourism activities in these centres, and in raising public awareness of the economic and social value of built heritage”.

3. Are there economic or other arguments for restricting or terminating the scheme?

The Irish Georgian Society is unaware of reasons for discontinuing the scheme.

4. What possible changes to the existing scheme, if any, should be considered and why?

The Irish Georgian Society is of the view that section 482 can continue to play an essential and worthwhile role in its current form. However, even with the provisions of direct government grant aid, it represents the minimum of what could be provided to support owners’ legislative obligations to protect their properties and also the potential to greater facilitate access and understanding of participant sites. Should the scheme be developed further, consideration could be given to the following measures:

• Generating greater awareness of participating properties for domestic and overseas tourists and other interested parties.
• Removing high earners restriction so that owners can undertake larger projects.
• Requiring local authority approval for works for which relief is claimed e.g. through a Section 57 declaration or planning permission.
• Ensuring works are undertaken by suitably experienced conservation contractors and craftsmen.
• Providing credits towards public access requirements for specially organised events relating to culture, education and leisure.
• Introducing a targeted grant scheme for those approved properties whose owners do not have the income to avail of the tax relief.

5. Do interested parties agree that there is merit in continuing section 482 beyond 2017? If yes, why? If no, why not?

The Irish Georgian Society is strongly of the view that Section 482 be continued beyond 2017 for the following reasons:

• Supports owners’ obligations under the Planning Acts to protect properties of special interest included in the Record of Protected Structures.
• Encourages private investment in the repair and maintenance of buildings.
• Offers a significant national network of heritage destinations for domestic and overseas tourists alike.
• Represents an important resource for scholars through providing public access to otherwise privately owned properties.
• Significant job creating role for conservation contractors and specialist conservators.
• Generates a local multiplier effect that benefits local retailers, restaurants/ hotels etc.

6. Any other input with regard to this scheme?

The Architectural Heritage Protection Guidelines for Planning Authorities states:

“Our architectural heritage is a unique resource, an irreplaceable expression of the richness and diversity of our past. Structures and places can, over time, acquire character and special interest through their intrinsic quality, continued existence and familiarity. The built heritage consists not only of great artistic achievements, but also of the everyday works of craftsmen. In a changing world, these structures have a cultural significance which we may recognise for the first time only when individual structures are lost or threatened. As we enjoy this inheritance, we should ensure it is conserved in order to pass it on to our successors.”

As a signatory to the Granada Convention for the Protection of the Architectural Heritage of Europe, signed at Granada in 1985, and ratified by Ireland in 1997, and through the provisions of the Planning Acts, the State is committed to the protection of our architectural heritage and places an obligation on the owners of protected structures to prevent their endangerment.

With minimal grant aid available to support conservation works and compliance with conservation legislation, Section 482 provides an important incentive to protect our heritage and furthermore allows public access to participating properties.

The Irish Georgian Society is of the view that section 482 relief should be retained and would welcome the opportunity to participate further in this review. 

Donough Cahill
Executive Director, Irish Georgian Society

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The UAHS and IGS Cross-Border Summer School is back for 2017!

Once again, this special event brings together students, experts and enthusiasts to explore, discuss, debate and enjoy issues relating to our shared Irish heritage in the context of Derry City & Strabane and Donegal. The event will focus on conservation and heritage led regeneration in the built environment of North West Ulster.

There will be many opportunities to visit and engage with the history and heritage of the area through talks, site visits to vernacular and civic buildings of architectural interest, demonstrations of traditional building skills and open discussions.

Speakers include: Dr. Brian Lacey, Paddy Matthews, Dr. Andrew McClelland, Dr. Edward McParland, Dr. Fidelma Mullane, Ronan O' Donnell, Dr. Barry O'Reilly Dr. Greg Stevenson and Prof. Alistair Rowan.

Student scholarships will be made available, please email info@igs.ie for information.
Members and non-members are welcome to attend.

Download the programme here, and book your place via this link. Tickets for the event cost €70 (1 day) and €240 for the full duration (3 days).

If you are making a booking through the UAHS, please book through this link.

The ticket price includes transport between venues, and a pick up in the morning and evening on Friday, Saturday and Sunday. For more information contact summerschool@uahs.org.uk 

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Newly published Abbey Leix: An Irish Home And Its Demense by William Laffan has just arrived in our bookshop, with a special offer for IGS members. Retailing at €45, upon presentation of your membership card you will get 20% off the marked price (instore only).

The book can also be purchased online: http://www.igs.ie/…/abbey-leix-an-irish-home-and-its-demesne

This offer for members will run for a limited time only.

This offer expired on 31st March 2017.

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Section 482 of the Taxes Consolidation Act 1997 was introduced to assist with the preservation of buildings or gardens determined to be ‘intrinsically of significant architectural, historical, scientific, horticultural or aesthetic interest’ by giving tax relief for their repair, maintenance, or restoration. A review of the relief is currently underway by the Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs, and the Department of Finance. As part of this process  a consultation paper has been issued on which comments must be submitted by 24th March 2017.

The Irish Georgian Society will be making a submission which will encourage the continuation and enhancement of the scheme as since its introduction it has facilitated conservation works to historic properties across the country that might otherwise not have been possible. The submission will also emphasise the job creating role of the scheme for conservation contractors and specialist conservators and will highlight the benefits of access to these properties for locals, tourists, scholars and the plain curious.

As a signatory to the Granada Convention and through the provisions of the Planning Acts, the State is  committed to the protection of our architectural heritage and places an obligation on the owners of protected structures to prevent their endangerment. With minimal grant aid available to support conservation works and compliance with conservation legislation, Section 482 provides an important incentive to protect our heritage and furthermore allows public access to participating properties.

Submission on the Consultation paper are open to all with information available on the following link: http://www.ahrrga.gov.ie/minister-humphreys-announces-that-her-department-is-carrying-out-a-review-of-section-482-of-the-taxes-consolidation-act-1997/

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