Date: 7^th October 2019

Re: Application by Hydro Estates Limited for permission for construction of a nursing home, 29 no. detached houses and all ancillary site works. Partial demolition, conservation, refurbishment, alteration and change of use of the remains of the former St. Ann’s Hydropathic Establishment which is a Protected Structure (RPS 00815) on lands at St Ann's Hill, Kilnamucky Tower, Blarney, Co. Cork.

Cork County Council Planning Reg. Ref.: 18/7111
An Bord Pleanala Ref.: PL04 .305373

Dear Sir or Madam,

The Irish Georgian Society of City Assembly House, 58 South William Street, Dublin 2, a non-governmental charity, established in 1958, which works to promote and protect Ireland’s built heritage, wishes to make an observation on the Third Party Appeal of Sir Charles Colthurst against Cork County County Council’s Notification of Decision to Grant Permission (Cork County Council Reg. Ref. 18/7111; An Bord Pleanala Ref. PL04 .305373) for permission for development on lands at St Ann's Hill, Kilnamucky Tower, Blarney, Co. Cork (including the remains of the former St. Ann’s Hydropathic Establishment, a Protected Structure, RPS 00815).

Impact on historic landscapes

Much of Ireland’s most distinguished architectural heritage is to be found in its landscapes, whether it be National Monuments or protected structures, ecclesiastical buildings and ruins or country houses, whether grand or modest in scale. What is distinctive for all of these structures is their siting and setting. Their associated lands and/or demesnes had been designed, elaborated, planted and inhabited to enhance the setting. Rivers, loughs, hills, magnificent valleys and mountains are all engaged and embraced whether as framed views or as elements within the designs.

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.

As noted in the Conservation Plan submitted with the application, St Ann’s Hill is recorded in the Garden Survey of the National Inventory of Architectural Heritage. Neither the Conservation Plan nor the Architectural Heritage Impact Assessment mention that the nearby lands at Blarney Castle are also listed in the Garden Survey of the National Inventory of Architectural Heritage.

Objective HE 4-3: Protection of Non-Structural Elements of Built Heritage of the Cork County Development Plan 2014 provides that it is an objective of the plan to “Protect important non-structural elements of the built heritage. These can include designed gardens/garden features, masonry walls, railings, follies, gates, bridges, and street furniture. The Council will promote awareness and best practice in relation to these elements.”

The Development Plan goes on to state as follows:

• 12.4.10 Many non-structural elements, such as historic gardens, stone walls, ditches and street furniture contribute to our built heritage. Carelessness and a lack of awareness can result in the loss of these elements.
  
  
• 12.4.11 An absence of a tradition in ‘best practice’ for the conservation of historic landscapes and their associated features, means that appraisal and surveying are essential in considering development proposals for sensitive sites. A lack of understanding into the elements that form an integral part of designed landscapes can mean that these features are vulnerable to needless partial or total destruction, as well as poor reconstruction. Raising awareness of the value of landscapes and associated features and promoting standards in relation to repair and conservation of the same will be an important step.
  
  
• 12.4.12 NIAH identified a total of 6,000 designed landscapes around demesnes in the whole of the Country, 1,000 of these occurring within the County of Cork. Many of these demesnes are not included in the RPS, even though they may have important heritage value in their own right. Cork County Council prepared a guidance note; “Guidance Notes for the Appraisal of Historic Gardens, Demesnes, Estates and their Settings” in order to foster a better understanding of designed landscapes and in the case of any development proposals to facilitate the preparation of appraisals of historic gardens and designed landscape and any possible impact on its heritage value. [Emphasis added.]

In addition to this, Special Policy Area Objective X-01 designates “St Ann’s Hydropathetic Establishment” as a Special Policy Area and requires that “the conservation plan shall include a historic landscape appraisal”.

Notwithstanding Objective HE 4-3, Cork County Council’s Guidance Notes for the Appraisal of Historic Gardens, Demesnes, Estates and their Settings, and Special Policy Area Objective X-01 of the Development Plan, the planning application does not include an historic landscape appraisal and it does not appear that a landscape historian was involved in the design or assessment of the proposed development. Specifically, the application does not include an appraisal setting out the following elements (i) an identification and description of the development, history, features and boundaries of the designed landscape; (ii) an evaluation of the historical landscape (i.e. an evaluation of archaeological aspects, horticultural and arboricultural aspects and a statement of significance of the historic landscape, its development and components); (iii) an assessment of the impact of the development proposals on the historic landscape; and (iv) recommendations for mitigation and management of impacts on the historic landscape as described in Cork County Council’s Guidance Notes for the Appraisal of Historic Gardens, Demesnes, Estates and their Settings.

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 St Ann’s Hill and environs. This is particularly the case given that the historic landscape at St Ann’s Hill also forms the setting for the fifteenth century, Blarney Castle (a protected structure, RPS Ref. 00382). The loss of this landscape through the construction of inappropriate new development has the potential to constitute a profound loss in Ireland’s architectural and cultural heritage.

Negative impact on buildings and landscapes of heritage importance

The Architectural Heritage Protection Guidelines for Planning Authorities 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."

The subject application proposes the functional severance of large parts of the curtilage of the former St. Ann’s Hydropathic Establishment from the protected structure. The Society submits that the proposed development will dominate and diminish the value of the historic landscape, which forms the setting for the protected structure complex, resulting in significant negative impacts on the heritage value of the former of St. Ann’s Hydropathic Establishment, its curtilage and attendant grounds. As such, the Society considers that the historic landscape, which forms the setting for the former St. Ann’s Hydropathic Establishment, a property of historic significance, will suffer significant negative impacts as a result of the construction of the proposed development.

Moreover, as illustrated by the Visual Impact Assessment provided with the planning application, the proposed development will be openly visible from Blarney Castle and will result in a considerable change in views towards St Ann’s Hill from the protected structure. The construction of the proposed development at this prominent location will disrupt the interrelationship between the Castle and the historic landscape to the northwest. Given that most visitors to the Castle climb to the top to kiss the Blarney stone and to enjoy the panoramic views of the surrounding countryside, the change in the visual environment likely to take place as a result of the construction of the proposed development is likely to result in particularly negative impacts on views from the protected structure at Blarney Castle and on the wider context in which it is located.

Conclusion

In conclusion, the Irish Georgian Society submits that the proposed development will have a significant negative impact on the architectural heritage of the former St. Ann’s Hydropathic Establishment and on Blarney Castle and will compromise the integrity of the historic and designed landscapes that forms the setting for these protected structures.

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 at St Ann's Hill, Kilnamucky Tower, Blarney, Co. Cork (Cork County Council Planning Reg. Ref.: 18/7111; An Bord Pleanala Ref.: PL04 .305373).

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James Wyatt’s Irish Masterpiece: Castle Coole Study Day

The Irish Georgian Society, in partnership with the National Trust, Northern Ireland, is delivering a study day celebrating the rich architectural heritage, decorative interiors and designed landscape of Ireland’s finest eighteenth-century neo-classical house, Castle Coole, Enniskillen, County Fermanagh.

Castle Coole has been home to the Lowry Corry family since the late seventeenth century. A Queen Anne mansion built by John Curle replaced the earlier defensive castle and at the close of the eighteenth century this in turn was replaced by a house of unparalleld architectural grandeur, built to designs by James Wyatt for Armar Lowry-Corry, the 1^st Earl of Belmore. Castle Coole continues to be home to Lord Belmore and his family.

The keynote speaker will be Dr John Martin Robinson, the acknowledged authority on James Wyatt. Other distinguished speakers include: Frances Bailey; William Laffan; Dr Patricia McCarthy; Dr Edward McParland; Christopher Monkhouse; Terence Reeves-Smyth; Dr William Roulston; and David Skinner. The study day commences at 11am with tea and scones and a welcome from Lord Belmore. In addition to the study day lectures, there will a tour of Castle Coole and lunch.

Tuesday 12 November 2019
Castle Coole, Enniskillen, County Fermanagh

Tickets: €90 to include tea/coffee and lunch
Tickets (with coach): €120 (departing at 8.30am from the Clayton Hotel, Ballsbridge, Dublin, returning to Dublin for 7.45pm)
Click here to download the full programme.

Buy tickets here.

Image: John Preston Neale (1780–1847), A View of Castle Coole (National Library of Ireland

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Desmond Guinness Scholarship 2019

The Desmond Guinness Scholarship is awarded annually by the Irish Georgian Society to an applicant or applicants engaged in research on the visual arts of Ireland including the work of Irish architects, artists and craftsmen at home and abroad, 1600-1900. Preference will be given to work based on original documentary research.

The Scholarship is intended primarily for applicants who are not yet established at an advanced professional level in research or publication of the visual arts.

The Scholarship does not have to be awarded in any one year, and the decision of the assessors, appointed by the Irish Georgian Society, is final. The total value of the scholarship fund available for distribution is in the region of €1,000. The award will be made before the end of November 2019.

Applications must be submitted by 2pm, Monday 28 October 2019.

Please note the following:

• Applications must be made online through this form: http://bit.ly/DGscholarship19
• No additional information or any other accompanying material will be accepted.
• All questions must be answered and incomplete applications will not be considered. Late applications will not be accepted.
• The Scholarship will not cover tuition fees.
• A confidential reference supporting the application must be sent separately by post by the closing date to the following address: Desmond Guinness Scholarship, Irish Georgian Society, City Assembly House, 58 South William Street, Dublin 2

If you have any further queries about the scholarship please contact:

Zoё Coleman (zoe.coleman@igs.ie) or by phoning 01 679 8675.

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The City Assembly House was built for the Society of Artists (1766-70), and restored by the Irish Georgian Society (2013-18). For this year's Culture Night programme, City Assembly House is excited to host a group exhibition by Pallas Studios artists and performances by Irish Baroque Orchestra and Irish Youth Baroque Orchestra in the Knight of Glin Exhibition Room.

Friday 20 September, 7.30pm

Irish Baroque Orchestra launches their 2019-2020 season amidst the inclusive, vibrant backdrop of Culture Night in Dublin. They are joined for this special event by mezzo-soprano Katie Bray, who recently won the Audience Prize at the prestigious Cardiff Singer of the World competition. Join IBO from TIME to hear a selection of items from their upcoming performance of Vivaldi's Griselda with Irish National Opera, as well as selections from their recent CD 'Welcome Home Mr Dubourg'. Brochures for their 2019-2020 season will also be available.

Conductor Peter Whelan; Mezzo-Soprano Katie Bray

Wednesday 18 September - Saturday 22 September

Pallas Studios is an artist-led organisation, dedicated to the facilitation of contemporary artistic production and discourse. They are hosting a group exhibition in the Knight of Glin Exhibition Room featuring contemporary works, on show at these times:

10-3 Wednesday

10-5 Thursday

10-10 Friday

10-6 Saturday

We look forward to welcoming you to the City Assembly House all week long!

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The 18th Annual Historic Houses Conference, 11-13 May 2020

Centre for the Study of Historic Irish Houses and Estates,
History Department, Maynooth University

The theme of the 18th Annual Historic Houses Conference, to be held at Maynooth University on 11-13 May 2020, will be ‘Welcome and Unwelcome Guests: The Visitor and the Country House’.

Download call for papers here.

Country houses have always been a magnet for visitors, rarely have their doors been entirely closed to the outside world. In early days individuals with the correct social credentials could gain entry, while visitors such as royalty were self-invited guests. With the rise of the railway and then the motor-car, houses have become accustomed to mass visits, spawning the heritage industry of today.

However, houses have also attracted less welcome incomers: looters, arsonists, emigrés, revolutionaries, the politically undesirable, carpetbaggers, and even photographers whom one owner described as worse than burglars.

This conference will explore the many kinds of visitors who have crossed the thresholds of country houses and how they have recorded their impressions – whether in sketches, journals, guest-books, works of fiction, photographs, or on the pages of Trip Advisor. Have owners always been hospitable towards their guests, and have visitors respected what was on offer in these houses? How have owners adapted their homes from residences into public attractions? Can private entertainment and commercial activity live side-by-side, satisfying invited guest and paying tourist alike, while generating pleasure and profit for all?

Papers on any aspect of country house visiting in Ireland, the UK, Europe, or the wider world will be considered. Abstracts of no more than 400 words should be sent to Professor Terence Dooley and Professor Christopher Ridgway before 5 January 2020 at the following addresses: terence.a.dooley@mu.ie and cridgway@castlehoward.co.uk

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Planning and Development Directorate

Cork City Council

City Hall

Anglesea Street

Cork

2^nd September 2019

Re. Redevelopment of the Custom House site at North Custom House Quay and South Custom House Quay, Custom House Street, Cork City to provide a 240-bedroom hotel, 25 no. hotel serviced suites, and a range of commercial uses including retail, office, food and beverage, distillery, tourism and leisure.

Ref. 1938589

The Irish Georgian Society is a membership organisation that promotes an awareness and the protection of Ireland’s built heritage through educational programmes, supporting conservation projects, and campaigning for the protection of buildings at risk. The Society has considerable concerns about the very significant impact this planning application could have on Cork’s built heritage given the proposals to demolish the Revenue Building, a protected structure of regional architectural interest that lies within sensitive complex of national heritage interest, and the plans to construct a 34-storey building in its place.

Proposed demolition of the Revenue Building

The Custom House and the Revenue Building (PS818) are identified as protected structures in the Cork City Development Plan 2015-21 (the City Development Plan) and, together with the Bonded Warehouses (also protected), are considered by the Plan (Section 8.18) as being “particularly emblematic of Cork’s maritime heritage”. This also notes that “along with Haulbowline Island, [it] is one of the two most important Georgian dock complexes outside Dublin and one of three surviving Georgian docks complexes in Ireland”. The South Docks Local Area Plan, 2008 (SDLAP) describes them as “unquestionably the most important surviving port related structures to survive in the upper harbour area”.

The National Inventory of Architectural Heritage designates the Custom House (identified as the Harbour Commissioner's Office ref. 20506372) as a structure of National importance and the Revenue Building (identified as Customs Offices ref. 20506373) as being of Regional importance. It states that the Revenue Building forms “part of an important complex of buildings located behind the Harbour Commissioner's Office, [that it] displays a fine use of building materials traditional to the area [and that it] also retains timber sash windows and has been well maintained”.

The City Development Plan and the Architectural Heritage Protection Guidelines for Planning Authorities (2004) (the Guidelines) give consideration to proposals for the demolition of protected structures. The City Development Plan (Objective 9.24) states that “Proposals for demolition of a Protected Structure shall not be permitted except in exceptional circumstances and where it can be showed that a greater public interest will be served which outweighs the loss to the architectural heritage”. The Guidelines also states that “the Act provides that permission may only be granted for the demolition of a protected structure or proposed protected structure in exceptional circumstances”.

The Irish Georgian Society has grave concerns about the current proposal to largely demolish the Revenue Building given that it forms an integral part of the Georgian Custom House Docks area, that it is a designated protected structure, and that its individual significance has been recognised by the NIAH. The proposal to construct a 34-storey structure in place of it, though presumably to fund works to other protected structures on the site, should not be considered to comprise the “exceptional circumstances” suggested by legislation and the City Development Plan to justify its demolition. Our architectural heritage is an irreplaceable resource which once lost is gone forever. 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.”

Proposed construction of a Tall Landmark Building

In considering the South Docks Local Area Plan the Planning Supporting Statement accompanying the application states that “until such time as a new LAP is adapted… the SDLAP remains valid and weight can therefore be applied to this policy document” (section 5.5).

The SDLAP identifies five sites within the South Docks as being suitable for Tall Landmark Buildings and in doing so does not list the Custom House Docks area as one of these. On the contrary, in recognising the heritage importance of the area, it specifically states that “focal landmark buildings in sensitive locations (e.g. Customs House/Bonded Warehouses) should be modest in height due to the architectural, historical and cultural significance of the site” (4.8.2.2). It also states that “due to the heritage sensitivity of the Harbour Commissioners’ Office and distinctive Bonded Warehouse, the scope for redevelopment may be limited” (5.2.1).

In considering building heights, the City Development Plan aims to “Ensure that development reflects and is sensitive to the historical importance and character of the city, in particular the street layout and pattern, plot sizes, building heights and scales” (Objective 9.1, Built Heritage and Archaeology). It also states that development proposals “should respect the height, mass and scale of surrounding buildings, should not compromise protected views and prospects and should draw upon positive characteristics of the surrounding environment to create a sense of place, security and vitality” (Objective 13.21 City Centre Design Quality and Context). It is respectively suggested that the construction of a 34-storey tower in the centre of a complex of buildings that constitute one of the most important Georgian dock complexes in the country would not be “sensitive to its historical importance and character” nor “draw upon positive characteristics of the surrounding environment”.

The Irish Georgian Society is of the view that the construction of a Tall Landmark Building on the Custom House Docks site would be contrary to the provisions of the South Docks Local Area Plan and the Cork City Development Plan and should not be granted planning permission.

Summary

In conclusion, the Irish Georgian Society is of the view that this development proposal does not present the “exceptional circumstances” required by legislation and the City Development Plan for the demolition of the Revenue Building, a protected structure of Regional importance. Granting permission for its demolition on these grounds could set a very worrying precedent for similar proposals that could undermine the effectiveness of protected structure designations. Furthermore, the Tall Landmark Building proposed in its place would quite clearly not be consistent with the provisions of the SDLAP and the City Development Plan. For these reasons the Irish Georgian Society urges Cork City Council to refuse permission for this planning application.

Yours sincerely,

Donough Cahill

Executive Director IGS

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