Re: Dublin City Development Plan 2022-2028
I am writing to you in connection with the on-going public consultation on the draft Dublin City Development Plan 2022-2028.
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.
Importance of retention and reuse of heritage buildings for climate change mitigation and adaptation
The Irish Georgian Society strongly supports Policy CA5: Retrofitting and Reuse of Existing Buildings and changes included at Section 11.5.4: Retrofitting, Sustainability Measures and Addressing Climate Change in the Draft Dublin Development Plan 2022-2028, which emphasise the importance of retention of existing buildings (including existing historic building stock) for climate change mitigation and adaptation. As outlined in the Preservation Green Lab’s (a part of the National Trust for Historic Preservation) 2011 publication The Greenest Building: Quantifying the Environmental Value of Building Reuse “reuse of buildings with an average level of energy performance consistently offers immediate climate-change impact reductions compared to more energy-efficient new construction”. The document goes on to state that: “Most climate scientists agree that action in the immediate timeframe is crucial to stave off the worst
impacts of climate change. Reusing existing buildings can offer an important means of avoiding unnecessary carbon outlays and help communities achieve their carbon reduction goals in the near term”. The Society further welcomes the emphasis in Section 11.5.4 on low impact interventions for improving energy performance. Given that occupation of historic buildings is the key factor to ensuring their continued survival, it is essential that every effort is made to encourage members of the public, investors and developers to see the potential advantages associated with the retention and re-use of historic buildings. The Society supports the Planning Authority in this endeavour.
City Heritage Plan
The Society welcomes Section 11.5.6, including Policy BHA27, which states that it is the policy of Dublin City Council “to implement the current Dublin City Heritage Plan and to support the preparation and implementation of the Dublin City Heritage Plan 2022-2026”. This provides a strong basis for the management and protection of Dublin’s heritage assets and historic built environment and will ensure a consistent approach between both plans.
The Society supports Objective BHAO1: Buildings-at-Risk Register, which states that it is an objective of the Planning Authority “to continue to maintain and proactively manage the Buildings-at-Risk Register of Protected Structures that are considered to be endangered or have the potential to become endangered through neglect, decay, damage and harm”. In the United Kingdom, Buildings-at-Risk registers have proven to be successful in bringing attention to historic buildings requiring intervention and spurring landowners and local community to take action to save those buildings. For example, the Ulster Architectural Heritage Society reports that almost 200 buildings were saved and removed from Northern Ireland’s Heritage at Risk Register during the period between 2006-2016, while Historic England notes that 233 historic buildings and places were saved and removed from the register in 2021 alone. In addition to this, these registers can provide an invaluable source of information on what buildings are likely to become at risk and could help to identify targeted measures that would allow for quicker intervention or even address problems before they begin. For these reasons, the Society would welcome Dublin City Council’s Buildings-at-Risk Register being made available to the public.
Relaxation of Zoning Objectives / development plan standards for buildings of architectural heritage merit
As noted above, the Society welcomes the inclusion of policies for the retention and re-use of historic buildings, including buildings of heritage importance, which are not protected. In this regard, the Society notes that the Draft Development Plan does not include a section regarding the potential for relaxation of development plan standards in the case of protected structures and other historic buildings (e.g. such as Section 14.5: ‘Relaxation of Zoning Objectives for Protected Structures’ in the current development plan). The Society requests that a similar section be included in Chapter 11 or Chapter 16 of the draft plan to help support those wishing to pursue the conservation and sustainable reuse of historic buildings as part of appropriate projects. For example, it may not be appropriate for the planning authority to seek to impose modern standards related to such things as a historic building’s access to sunlight or daylight where certain areas of historic buildings may not meet modern sunlight or daylight access standards (e.g. basements), but nonetheless can provide a good standard of residential or commercial accommodation.
Development of Protected Structures
It is suggested that the wording of Policy BHA2(c) be changed to “(c) Ensure that works are carried out in line with best conservation practice as advised by a suitably qualified person with expertise in architectural conservation”. Members have reported that as the word “supervision” implies that conservation professionals should be present on site at all times when works are being carried out, this has resulted in concerns regarding compliance with planning permission.
Large and tall buildings in the historic core
The Society understands that one of the key challenges for the city is achieving the balance between providing for compact growth, appropriate densification and placemaking while ensuring innovative and sensitive development that respects the city’s unique character and enhances its natural and heritage assets. The Society recognises the need for a more compact urban form and notes the requirement to ensure consistency with the Urban Development and Building Heights Guidelines for Planning Authorities (December 2018) and the SPPR’s contained therein. However, it is crucial that Development Plan policies in support of higher densities and taller buildings be appropriately couched in terms of ensuring the reasonable protection of visual and residential amenities as well as Dublin’s built heritage.
The policies SC14 to SC18 of the Draft Development Plan address the issue of building height yet make no reference whatsoever to built heritage or conservation considerations. Policy SC16 of the draft Development Plan states that it is the policy of Dublin City Council “To recognise the predominantly low rise character of Dublin City whilst also recognising the potential and need for increased height in appropriate locations including the city centre, Strategic Development Zones, Strategic Development Regeneration Areas, Key Urban Villages and other locations as identified in Appendix 3, provided that proposals ensure a balance between the reasonable protection of existing amenities and environmental sensitivities, protection of residential amenity and the established character of the area.” The Society respectfully encourages the Council to include ‘built heritage’ among the list of considerations to be afforded reasonable protection in the consideration of proposals for increased height.
In addition, Appendix 3 to the Draft Plan concerns ‘Achieving Sustainable Compact Growth Policy for Density and Building Height in the City’. The Society welcomes the acknowledgements at Section 3.1 of Appendix 3 that “Dublin City has an intrinsic quality as a predominantly low rise city” and that “there is a recognised need to protect conservation areas and the architectural character of existing buildings, streets and spaces of artistic, civic or historic importance”. Further to that, we are fully supportive of the policy requirement that “In particular, development proposals must be sensitive to the historic city centre, the River Liffey and quays, Trinity College, Dublin Castle and medieval quarter, the historic squares and the canals.” However, we would suggest that reference to “Conservation Areas in the outer city and inner suburbs, and the setting of Protected Structures in general” should be added to this list sensitive receptors.
Section 4.1 of Appendix 3 refers to the Building Height Guidelines and the recommendation that it would be appropriate to support the consideration of building heights of at least 6 storeys within the canal ring as the default objective. While the Guidelines make clear that it is inappropriate for a Development Plan to include generic height limits across their functional areas due to the position that such blanket limitations can hinder architectural innovation and urban design. The Society respectfully submits that it is equally important for Development Plans to not set out blanket minimum numeric building heights across large swathes of their functional areas to ensure that the appropriateness of building hight can be assessed on a case-by-case basis in light of the impact on built heritage and residential amenities.
The Building Height Guidelines set out locational classifications where varying ranges of building heights are considered appropriate. These include the reference at para 1.10 to ‘city and town centre areas’ (“within the canal ring in Dublin and analogous areas in Cork, Limerick, Galway and Waterford…”) where building heights of at least 6 storeys are the default objective. Paras 3.4 - 3.8 concern building height at ‘Suburban/Edge locations (City Town)’ where development should include “an effective mix of 2, 3 and 4-storey development which integrates well into existing and historic neighbourhoods”. While the Glossary to the Draft Plan carries over definitions for ‘inner city’, ‘inner suburbs’ and ‘Outer City’, the terms do not map on directly to locational categories set out in the Building Height Guidelines, this ambiguity creates the potential for conflict between the Development Plan and the Guidelines. The Society suggests that the Glossary of the Development Plan be amended or updated to provide definitions of these terms, and to ensure consistent application of the terms used in both the Guidelines and the Development Plan. This would provide assurance as to the Council’s interpretation of the terms used in the Guidelines, which would bring greater clarity and certainty for developers and the public alike.
Removal of bus parking / bus cages from Dublin’s Georgian core
It is disappointing that the Development Plan does not include an objective in relation to bus parking in the historic core. The failure to include an objective to remove Dublin Bus termini and bus cages from Dublin’s Georgian core in the Draft Development Plan is at odds with Measure BUS 11 of the National Transport Authority’s draft Transport Strategy for the Greater Dublin Area, which provides that:
“The Authority will seek:
- The progressive reduction in the use of scarce street space for out-of-service bus fleet in Dublin city centre and other town centres; and
- Alternative terminus facilities elsewhere, as required, to facilitate efficient bus management.”
Moreover, the focus on private coach parking fails to reflect the findings of Dublin City Council’s own Merrion Square Conservation Management Plan, which, at Section 5.0: Defining Issues & Assessing Vulnerability states: “The use of the streets that form the square as a daytime terminus by Dublin Bus detracts from the setting of the square and park. Double-decker buses parked along the south side of the park restrict views through the gates, out of the park towards the terraces. Walking along the footpath between buses and railings is unpleasant and they present not only a visual, but also an aural and odorous intrusion into this architecturally sensitive area.”
For some years, the Irish Georgian Society has been engaging with Dublin City Council and Dublin Bus, amongst others, in an effort to have the Dublin Bus “bus cage” reduced or removed from the southern side of Merrion Square. However, consequent to meetings and discussions with Dublin Bus, the Irish Georgian Society has become very much aware of the difficulties facing Dublin Bus in finding appropriate sites for bus lines to terminate with Dublin Bus having had to move many termini and bus cages in recent years due to impacts on residential amenity, etc. The location of major bus infrastructure (such as termini or bus cages) is not provided for in the Dublin City Development Plan 2016-22 or in the new Draft Plan and it seems clear that a piecemeal and case-by-case approach to the location of major bus infrastructure for a city the size of Dublin is, at best, inefficient and, at worst, unworkable. For example, in the specific instance of Merrion Square, there is considerable concern that a bus cage moved from Merrion Square could be located in an equally vulnerable area.
A DIT Community Links Study, on behalf of the Irish Georgian Society, demonstrates that there are viable alternatives to bus termination and bus layover in Dublin’s historic core. The study recommends, in the case of the Merrion Square services, that terminus and layover operations be relocated to the most proximate garage, in this case Ringsend Depot on Ringsend Road. This can best be achieved by rerouting the end-of-service from Merrion Square to Docklands, via Pearse Street.
The Study suggests that, in addition to the mitigation of negative impacts on Dublin’s historic core, it is likely that the removal of bus and layover operations from the City Centre in favour of layover at garage would yield a range of net benefits, including:
- Fuel savings;
- Making proper rest facilities available to drivers;
- Significant increased patronage;
- Reduction of congestion through the College Green Bus Gate, which would in turn improve LUAS Cross-City operations; and
- Improved connectivity between Maynooth / the western suburbs and the Docklands, a significant centre of employment.
The use of Dublin’s Georgian Squares for bus layover is inappropriate, untenable and should be considered bad practice, without comparison in other heritage cities. A viable alternative exists which can increase revenue, improve operations and lead to a more efficient overall public transport network. For the reasons outlined above, the Irish Georgian Society suggests that the Draft Dublin City Development Plan 2022-2028 must go further to prioritise the removal of bus termination and bus layover from Dublin City Centre (to include the Georgian Core) and include an objective formulation of an integrated plan for the management of major bus infrastructure for all of Dublin City.
SDRA 10 – North East Inner City
The Society has concerns for the proposed designation of an area to the south of Charles Street Great as a ‘Potential Development Site’ as it is not clear why this site in particular has been chosen or what criteria would be used to guide its development. It is noted that the site lies within a Z2 Conservation Area and that it includes a number of protected structures within its boundaries as well as the rear gardens of other protected structures. Should this designation remain it is suggested that greater clarity is provided as to any permissible forms of development to ensure that such works would pay due regard to zoning and heritage requirements.
The Irish Georgian Society supports Policy CA5: Retrofitting and Reuse of Existing Buildings and the plan to proactively manage the Buildings-at-Risk Register of Protected Structures (Objective BHAO1). It is suggested that consideration be given to permitting a relaxation of development plan standards in the case of protected structures and other historic buildings to help support those wishing to pursue the conservation and sustainable reuse of historic buildings. It is also suggested that the wording of Policy BHA2(c) be changed so as to clarify requirements for the engagement of architectural conservation advisors for projects.
In considering large and tall buildings in the historic core, the Society notes the challenges of achieving the balance between providing for compact growth, appropriate densification and placemaking while ensuring innovative and sensitive development. However, it is crucial that such Development Plan policies are appropriately couched in terms of ensuring the protection of Dublin’s built heritage. In this regard it is recommended that the Development Plan does not set a blanket minimum numeric building height. It is also suggested that policies SC14 to SC18 be amended to address built heritage or conservation considerations and that Section 3.1 of Appendix 3 be amended to include Conservation Areas in the outer city and inner suburbs, as well as the setting of protected structures in general
The Society has noted its disappointment that the Development Plan does not include an objective to remove Dublin Bus termini and bus cages from Dublin’s Georgian core. Viable alternatives have been identified and the Society has recommended that the Draft Dublin City Development Plan 2022-2028 prioritises the relocation of these services as part of an integrated plan for the management of major bus infrastructure for all of Dublin City.