National Monuments Service

Custom House

Dublin 1

D01 W6XO

By email to climatechange@housing.gov.ie

29^th July 2025

Re. Public Consultation – Built and Archaeological Heritage Climate Change Sectoral Adaptation Plan 2025

Dear Sir or Madam,

The Irish Georgian Society welcomes this opportunity to comment on the Climate Change Adaptation Sectoral Plan for Built and Archaeological Heritage consultation by the Department of Housing, Local Government and Heritage.

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.

GOAL 1: Improve understanding of the heritage resource and its vulnerability to climate change impacts

The Society notes that the objective of Goal 1 seeks to “Establish a baseline for heritage resources from which change can be measured”. However, it is disappointing that Action a. of the 2019 Plan, which sought to establish a “baseline quantification of the number, nature and location of heritage assets” has been removed from the 2025 Draft. It is unclear how change on heritage resources can be measured in the absence of clear and accurate information on the number, nature and location of heritage assessments.

For example, it is understood that the baseline risk assessment of the Draft Plan seeks to rely on the National Inventory of Architectural Heritage (NIAH), the Draft Plan does not reference that a number of the surveys are incomplete (e.g. the building surveys of Dublin City and Dun Laoghaire-Rathdown and the NIAH Survey of Historic Gardens and Designed Landscapes). In addition to this, some of the NIAH surveys were carried out as early as 1997 and, almost thirty years later, are in considerable need of review. It is also notable

that the NIAH website describes a number of the county surveys as a “representative sample of the architectural heritage” and it is, therefore, questionable whether the survey is sufficient to provide the baseline required for the Adaptation Plan.

Moreover, Action 2 (ii) of the National Landscape Strategy states: “A National Landscape Character Map will be prepared using the evidence base to describe and assess distinct landscape character areas at the national scale, ensuring consistency within and between public authority areas and functions. The database and associated maps, incorporating linked, open and online data, will use Landscape Character Assessment methodology along with other assessment methodologies and will incorporate an outline Historic Landscape Characterisation.” The preparation of a National Landscape Character Map is also the subject of National Policy Objective 91 of the National Planning Framework – First Revision. The completion of the National Landscape Character Map forms an essential part of establishing a baseline for heritage resources from which change can be measured. It is, therefore, respectfully submitted that the completion of the National Landscape Character Map in the short term should be an action of the Climate Change Adaptation Sectoral Plan for Built and Archaeological Heritage.

Having regard to the issues outlined above, the Society suggests that the Climate Change Adaptation Sectoral Plan for Built and Archaeological Heritage should include an action for the completion and review of relevant surveys including the preparation of the National Landscape Character Map and the completion and ongoing review of the National Inventory of Architectural Heritage.

GOAL 2. Develop and mainstream sustainable policies and plans for climate change adaptation of built and archaeological heritage

The Society welcomes Action c. under Goal 5, which seeks to “continue grant schemes and explore other additional financial incentives for conservation and repair of heritage assets supported by guidance documents and informed by post project monitoring”.

While funding for conservation grants has increased significantly, the IGS believes that further supports will always be needed to assist owners of protected structures, of all scales, in safeguarding their buildings. Attendees of the IGS conference Taken for Granted: Spending to save Ireland's architectural heritage (2018) passed resolutions that called for additional assistance, a greater flexibility in spending of funds, and a more structured approach to the allocation of these. In reflecting these resolutions, consideration may be given to:

1. A continued improvement and expansion of grant schemes for the protection and management of the national architectural heritage resource, particularly in response to the threat posed by climate change impacts but also to support essential maintenance works.
2. The further development of the much-needed BHIS Historic Thatched Buildings Stream
3. with the goal of maximising support for thatched building owners and also securing a means of providing adequate insurance cover for their homes.

GOAL 4. Communicate and transfer knowledge

The Society supports Action d. under Goal 4, which seeks to “support increased resourcing of heritage sector”. However, the Society submits that this Action should be strengthened to require that consenting authorities and authorities with forward planning function (e.g. planning authorities, An Coimisiún Pleanála, the Department of Housing, Local Government and Heritage etc.) be adequately resourced with suitably qualified conservation professionals.

In particular, it is essential that sufficient expertise in conservation be made available at a local level. While progress has been made in the recruitment of Architectural Conservation Officers, there are still a number of local authorities that have yet to make such an appointment or do not have adequate staff resources in terms of suitably qualified conservation professionals. This is likely to act as a significant barrier to the effective implementation of any Climate Change Adaptation Sectoral Plan for Built and Archaeological Heritage for many reasons, including:

• Insufficient resources in local authorities can be an impediment to developing planning policy at local level (i.e. in the statutory plan) to a sufficient standard in order to provide adequate direction and certainty in relation to measures for climate change adaptation within or in proximity to the historic environment or within historic landscapes; and

• In the absence of the expertise of a suitably qualified conservation professional, assets of architectural, archaeological and cultural heritage significance can go unidentified.

Conclusion

The Irish Georgian Society welcomes the preparation of the Draft Climate Change Adaptation Sectoral Plan for Built and Archaeological Heritage. If we can be of any further assistance to this important initiative, please not hesitate to contact us.

Yours faithfully,

Donough Cahill

Executive Director IGS