Re: Application by Stillorgan RFC for the construction of a new club facility. The development will consist of: 2 storey clubhouse including changing rooms, meetings room, storage and ancillary facilities (gross floor area 463 sqm) and an outdoor viewing terrace; 3 no. playing pitches; floodlights for pitches
1+2; associated car park with coach and cycle parking; on site waste water treatment system and all associated site and development work on lands at Lands (c 4.1 ha) at Tibradden Road, Kilmashogue, Dublin 16.
Dear Sir or Madam,
The Irish Georgian Society of City Assembly House, 58 South William Street, Dublin 2 wishes to make a submission on the application by Stillorgan RFC for the construction of a new club facility on lands at Tibradden Road, Kilmashogue, Dublin 16 (DLRCC Reg. Ref. D16A/0955). The €20 fee has been paid online.
The proposed development lies within the combined demesnes of Cloragh and Tibradden. Tibradden House, a protected structure, was rebuilt and aggrandised in 1860 to the designs of Joseph Maguire, commissioned by Charles Davis of Cloragh. These designs transformed the modest 18th century farmhouse into an imposing villa. Its setting, as part of the design, was transformed by the planting of a sensitive combination of native broadleaves and exotic evergreens along the river valley to the east, establishing a sheltering plantation to the north-west, and the addition of clumps of trees to the parkland. The field boundaries of the home farm were also reinforced with timber trees. The end result of this designed landscape, essentially intact today, was to frame the house seen from below and from a distance and to frame views from the principal rooms of the house. The vista from the house is split by the surviving lime tree (possible one of an original clump of three) giving two framed views – one centred on Lambay Island seen across the Liffey estuary and the second a distant view of the Mourne Mountains seen beyond Rathfarnham and Georgian Dublin.
The importance to the Nation of the house and its landscape is attested by its “Section 482” status whose citation records that: “The surrounding estate with its vestiges of the original landscape elements, contribute to the history of its development and provide a beautiful and important setting to the assemblage of buildings”. It is considered that Tibradden House and its context are of considerable architectural and social historic significance.
The demesne of Tibradden is conspicuous in the most recent aerial photographs as a near unique survivor of a working agricultural landscape where its fields are still bounded not only by hedgerows or stonewalls but still retain their trees. It has been run as an environmentally sustainable farm under the REPS scheme, and its successor, GLAS. The total west boundary of the proposed development site and its southern edge abut the REPS farm. To the east, a single field slopes down to the Glin River, which becomes Whitechurch Stream, a tributary of the Dodder. This river valley forms a wooded ecological corridor from above Tibradden House down past Marlay Park and onto St Enda’s, where it becomes a prominent component of that designed landscape.
This piece of landscape, with its REPS / GLAS designation that embraces the site of the proposed development, makes a significant contribution to maintaining biodiversity within a zone under great stress from the burgeoning expansion of Dublin and all the more important for that.
The original farmhouse at Tibradden was approached from the southwest possibly along the axial road (still extant). This axial avenue appears to be aligned with, and would have focused one’s view towards, the prominent landscape feature of the site of a collection of cairns on Piperstown Hill (currently obscured by commercial forestry). Such was the design of the 18th and 19th century Tibradden House and its attendant landscape to engage with and elaborate its context. This landscape is part of a conspicuous backdrop to the city of Dublin leading up to the Dublin Mountains. It has been given its characteristic appearance by a collection of small demesnes, villas and attendant designed landscape, planting and farming (e.g. Tibradden, Cloragh, Mount Venus, Larch Hill, Killakee etc.). Each of these houses, including the earlier more modest farm house at Tibradden, made a virtue of its siting giving the principal rooms a prospect of Dublin city and bay and beyond. The nineteenth century saw considerable elaboration of these landscapes with planting which framed views from and to these places.
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.
It is worth remembering that Ireland has ratified the European Landscape Convention. The convention notes “that the landscape has an important public interest role in the cultural, ecological, environmental and social fields, and constitutes a resource favourable to economic activity and whose protection, management and planning can contribute to job creation”. It acknowledges “that the landscape is an important part of the quality of life for people everywhere: in urban areas and in the countryside, in degraded areas as well as in areas of high quality, in areas recognised as being of outstanding beauty as well as everyday areas”. Furthermore, it puts forward the belief “that the landscape is a key element of individual and social well-being and that its protection, management and planning entail rights and responsibilities for everyone”. The spirit of this Convention is embedded in Ireland’s National Landscape Strategy.
The Architectural Heritage Protection Guidelines for Planning Authorities further provide that proposals for new development within the curtilage of a building of architectural heritage significance should be carefully scrutinised by the planning authority, as "inappropriate development will be detrimental to the character of the structure". The Guidelines go on to state that, where there is a formal relationship between the heritage building and features within the curtilage, "new construction which interrupts that relationship should rarely be permitted". The Guidelines note that, within the curtilage of a building of heritage importance, there "may be planted features which are important to the character and special interest of the structure and which contribute to its setting. These could include tree-lined avenues, decorative tree-clumps, woodlands, species plants or plant collections."
It is the policy of Dun Laoghaire-Rathdown County Council “that historic demesnes and gardens should be identified and protected to reflect and acknowledge their significance as part of the National Heritage” (Policy LHB32). Moreover, Policy LHB5: Historic Landscape Character Areas of the Dun Laoghaire-Rathdown Development Plan 2016-2022 provides that: “In assessing development proposals and in the preparation of plans it is Council policy to have regard to the recommendations and findings of the Historic Landscape Character Assessments (HLCA) already undertaken for a number of the urban-rural fringe areas of the County most likely to come under development pressure.” The application site is located in Landscape Character Area 1: Kilmashogue Valley. Appendix 7 of the Development Plan states as follows:
“Kilmashogue Valley is currently one of the County’s finest unspoilt valley landscapes, which is currently not protected by any particular status. Any development in this valley should be carefully considered and be in sympathy with the existing landscape. The upper portion of the valley has not been affected by large-scale afforestation.” [Emphasis added.]
The Irish Georgian Society understands that during pre-planning consultation, the Applicant was asked to retain all hedgerows and trees as part of the proposed development and to provide a tree survey as part of the application. This has not been done. There is no record of tree species as far as can be ascertained from the documentation. The location of some trees is shown on the general site survey drawing in a form which, one must assume, is meant to represent the extent of the canopy of the trees. However, there are many omissions in this drawing, and the sizes of the canopies are woefully inaccurate and inadequate. The proposed development requires substantial excavation under the canopies of the trees along the western boundary and fill over the root plate along the eastern boundary. Both operations are seriously detrimental to the health and stability of these trees. In addition, the drainage proposals will require excavation under the canopy of a number of trees. The nature of the hedgerows is not recorded in the application. It appears that the middle hedgerow crossing the site is to be removed. In summary, the application does not propose to retain all trees and hedgerows, and the Applicant has declined to provide a tree survey as requested by the Planning Authority. Moreover, notwithstanding the recommendations of Appendix 7 of the Development Plan with regard to the Kilmashogue Valley Landscape Character Area with regard to the sensitivity of the landscape, the application does not include any assessment of the impact of the proposed development on the historic landscape of the Cloragh / Tibradden demense undertaken by a suitably qualified historic landscape consultant. The application does not include any assessment of the visual impact of proposed new development on views from the protected structure(s), between the protected structure complex or from key locations within the historic landscape.
It is critical that any development of these lands be informed by a comprehensive assessment of the sensitivities and significance of the historic landscape at Cloragh/Tibradden. The proposed development, which represents overdevelopment of this highly constrained site, will diminish the value of this fragile and important cultural landscape and damage its contribution to ecological capital. As a result, the proposal will result in a significant and material change to the setting of Tibradden House and its designed landscape. As such, it is considered that the proposed development contravenes the policies for the protection of architectural heritage set out in the Dun Laoghaire-Rathdown County Development Plan 2016-2022 and the recommendations of the Architectural Heritage Protection Guidelines for Planning Authorities.
Having regard to the issues set out above, the Irish Georgian Society respectfully requests that the Planning Authority refuse permission for the proposed development on lands at Tibradden Road, Kilmashogue, Dublin 16 (DLRCC Reg. Ref. D16A/0955).
Please do not hesitate to contact us if we can be of any further assistance.
Yours sincerely,
Donough Cahill
Executive Director
Irish Georgian Society
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