Georgian Society and Dublin City Development Plan

My views differ from the Georgian Society. I agree with them about the Georgian Squares including Mountjoy, Nth Great Georges St and the other squares. But I believe that we cannot and should not live in the past. I support higher buildings at Georges Quay, at Heuston Kings Bridge and near the Docks and also the redevelopment of Liberty Hall by SIPTU. I disagree about Phibsboro which needs rejuvenation and is staid and run down aesthetically. But any height, irrespective of magnitude, would need to be well designed and integrated into the local area. I guess the local Labour duo will object to everything! Nothing much will happen for years due to the economy. I have no doubt that the next five years will be fallow in Phibsboro due to absense of money and demand.

I am opposed to one off high buildings in areas such as Whitehall but where Metro North, DART or Luas lines serve, it is important to intensify the population density and provide appropriate exercise and community facilities also which may be in the opposite direction.

But I would like to take each proposal as it comes with an open mind provided the proposal is away from the georgian core. I think that Ireland is visually impaired architecturally and compares badly with Europe in general.

The other issue which I think is important is definition of low, middle and high rise. These should be consistent internationally to ensure people are talking an intelligible language. It is up to the planning process to refine the exact parameters on each occasion when a project comes for approval. Low rise may mean a height from x to Y metres. Medium rise similarly.

COPY OF Irish Georgian Society SUBMISSION

Planning & Economic Development
Dublin City Council
Civic Offices
Wood Quay
Dublin 2


11th Mach 2010

Dear Sir/Madam

The Irish Georgian Society would like to make a submission on the draft Dublin City Council Development Plan 2011-2017.

Whilst the Society warmly welcomes the inclusion of many of the built heritage objectives to foster Dublin’s character and cultural heritage contained in the draft Dublin City Council Development Plan 2011-2017, we also have a number of serious reservations about other aspects of the draft plan which we consider will jeopardise the implementation of those built heritage objectives.

The Society strongly supports Dublin City Council’s declaration to protect and enhance the city’s built heritage, particularly ‘to support the designation of Dublin as a World Heritage Site’ (FC55). The designation of Dublin as a World Heritage Site is something that the Society strongly advocates. During 2008 the Society made formal submissions to the Minister for the Environment, Heritage and Local Government supporting Georgian Dublin’s nomination to the tentative list of potential sites for World Heritage Site nomination.

Inscribing Dublin’s Georgian core onto the World Heritage Site list would represent a full, proper and overdue acknowledgment of the city’s Outstanding Universal Value. Correspondingly the Society considers that Dublin City Council declaration contained in the current draft development plan, would signify a strong commitment to ensure that the integrity and authenticity of that outstanding universal value would be safeguarded for the future.

The Society is also encouraged to see that the draft development plan contains commitments to designate for protection areas including the Georgian Core area, city quays, rivers, canals and specific streets and sites, in recognition of Dublin’s international importance as a Georgian City’. As such the Society welcomes Dublin City Council’s initiative ‘to continue to prioritise the assessment and consideration of appropriate historic streets and squares for designation as Architectural Conservation Areas and include policies to protect and enhance their architectural characteristics’ (FC40), as well as the commitment ‘to assess and, where appropriate, re-designate existing non-statutory Conservation Areas as Architectural Conservation Areas’ (FC41). In particular the Society considers that the designation of Mountjoy Square and its environs as a statutory Architectural Conservation Area should be prioritised. Despite the valiant efforts of many of the residence of Mountjoy Square, it has suffered much degradation of its historic fabric and character and designation as a statutory Architectural Conservation Area would greatly assist in reversing this neglect.

However, Dublin City Council’s aforementioned commitment to foster Dublin’s rich built heritage and support the designation of Dublin as a World Heritage Site appears incompatible with provisions contained in the draft development plan regarding height, density and scale of developments allowed in the city.

The Society takes issue with the draft development plan’s definition of ‘low-rise’, ‘medium rise’ and ‘high rise’ and the indications of where certain heights of building will be permitted within the city.

In the draft development plan the definition of ‘low-rise’ has risen from 15 metres to 25 meters for the inner city area, which approximately corresponds to the historic heart of Dublin city, the area located between the canals. 25 meters is the equivalent of an 8 storey residential building. The Society considers that the original Dublin City Council definition of ‘low rise’ as being 15 meters, which is the equivalent of a typical 4-storey over basement Georgian building is a much more appropriate definition. The draft development plan’s new definition of an 8-storey or 25 meter building as being ‘low-rise’ is misleading. The Society asks that the new definition of ‘low-rise’ be revised back to a 15 meter definition, in order to ensure that Dublin City Council can deliver on respecting the intrinsic quality of Dublin as a low rise city and preserve its historic character.

Similarly when you consider a building such as Liberty Hall, which at 58 meters would be considered a tall building by anyone’s definition, it seems misleading to define ‘mid-rise’ buildings as comprising a building of up to 50 meters in height, which is just 8 meters short of the height of Liberty Hall. Again the Society has grave concerns about the areas indicated in the draft development plan where the erection of these ‘mid-rise’ buildings are going to be permitted, in particular Phibsborough with its fine Victorian building stock and the ‘Digital Hub’, in the city’s Liberties adjacent to such important Georgian buildings as St. Catherine’s Church.

Of equal concern is the identification of the areas within the development plan where high-rise buildings of over 50 meters in height will be permitted, of particular concern is the identification of Heuston, Georges Quay and Connolly as areas suitable for high rise. Not only would the erection of high rise buildings compromise the historic buildings in the area but they would also have a detrimental impact on the city’s historic skyline and negate Dublin City Council’s ability to ensure that the skyline of the inner city is protected and enhanced.

Critically the Society considers that the definitions and locations identified for ‘low rise’, ‘medium rise’ and ‘high rise’ within the draft development plan are inconsistent with the declared commitment to foster Dublin’s rich built heritage and support the designation of Dublin as a World Heritage Site.

The policies contained in the draft development plan with regard to tall buildings present threats both to the viability of nominating and retaining Dublin as a World Heritage Site, as they would be at variance with the Guidelines for Urban Development contained in the Vienna Memorandum on ‘World Heritage and Contemporary Architecture – Managing the Historic Urban Landscape’ (2005).

The Vienna Memorandum states that ‘architecture of quality in historic areas should give proper consideration to the given scales, particularly with reference to building volumes and heights’ and continues by noting ‘that it is important for new development to minimize direct impacts on important historic elements’ (Guidelines for Urban Development: 22) and that ‘townscapes, roofscapes, main visual axes, building plots serve as the basis for planning and design. With regard to renewal, the historic roofscape and the original building plots serve as the basis for planning and design’
(Guidelines for Urban Development: 25) and that ‘as a general principle, proportion and design must fit into the particular type of historic pattern and architecture ……. Special care should be taken to ensure that the development of contemporary architecture in World Heritage cities is complementary to values of the historic urban landscape and remains within limits in order not to compromise the historic nature of the city’.
(Guidelines for Urban Development: 26)

The Society is of the opinion that the draft Dublin City Development Plan
2011-2017 will ultimately encourage the erection of tall buildings in the
city: tall buildings that will negatively impact on the city’s historic building stock and irreversibly and detrimentally alter Dublin’s historic skyline and potentially jeopardise the city’s capabilities of designation as a World Heritage Site.

As such the Society respectfully asked Dublin City Council to redefine downwards the definitions of tall buildings and reconsider and limit the areas designated appropriate for both ‘medium rise’ and ‘high rise’ within the city.

Yours sincerely

Emmeline Henderson
IGS Assistant Director &
Conservation Manager