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.
Executive Director, Irish Georgian Society