Dublin City Council

Dublin City Council

Planning Department

Civic Offices

Block 4, Ground Floor

Wood Quay

Dublin 8

15th August 2014

Re: Application by ESB Commercial Properties Ltd for planning permission for the demolition of all the Twentieth Century office buildings and atrium structure in their entirety (c.36,208 sq m) and their replacement with a new mixed-use development (c.45,767 sq m gross floor area) comprising office, cafe/ retail/ event space/ restaurant and ancillary uses, ranging in height from 4 to 7 storeys over a 2 level basement on a site of c. 1.2 hectares at Nos 13-30 Fitzwilliam Street Lower, Dublin 2 (which currently accommodates ESB's Headquarters and associated structures). The application also includes proposals for eleven Protected Structures located at Nos. 12, 29 and 30 Fitzwilliam Street Lower and Nos. 55-62 Mount Street Upper.

Dublin City Council Planning Reg. Ref.: 3052/14

Date of Lodgement of Planning Application: 14th July 2014

Dear Sir or Madam,

The Irish Georgian Society (of City Assembly House, 58 South William Street, Dublin 2) wishes to make an observation on the application by ESB Commercial Properties Ltd for planning permission for the demolition of all the Twentieth Century office buildings and atrium structure in their entirety (c.36,208 sq m) and their replacement with a new mixed-use development (c.45,767 sq m gross floor area) comprising office, cafe/ retail/ event space/ restaurant and ancillary uses, ranging in height from 4 to 7 storeys over a 2 level basement at Nos 13-30 Fitzwilliam Street Lower, Dublin 2. To that end, we enclose a cheque, in accordance with the provisions of the Planning and Development Regulations, 2001, as amended, in the sum of €20.00, as payment of the submission fee.

Having regard to the national and international heritage importance of Dublin’s South Georgian Core, the Irish Georgian Society has concerns about the scale, bulk and height of any redevelopment of the block bounded by Fitzwilliam Street Lower, Mount Street Upper, James's Street East and Baggot Street Lower. However, it is respectfully submitted that the information included in the environmental impact assessment (prepared under Directive 2011/92/EU, as amended by Directive 2014/52/EU of 16 April 2014) is such that it is not possible to determine the extent to which the scale, bulk and height of the proposal is likely to impact upon the Historic City of Dublin, as listed on Ireland’s World Heritage Tentative List (Ref. 5523).

Specifically, it is noted that the existing assessments of impacts on architectural and cultural heritage and on the visual environment focus on the likely impacts of the proposal on the Georgian streetscape and public realm. Assessing the impact of a development on architectural heritage by sole reference to the visual impact of the development when viewed from street level suggests that only the front façade of a protected structure is of value and in need of protection. This approach is contrary to the Architectural Heritage Protection Guidelines for Planning Authorities, which, at section 13.7.2, poses the following questions:

“h) Even where the proposed development is at a distance from the protected structure, could it still have an impact? This could include tall or bulky buildings interrupting views of or from the protected structure and other features of the designed landscape;

i) Where the new works would not be directly visible from the protected structure, would they be visible from the approaches to the structure or from other important sites or features within the attendant grounds? If so, would this be acceptable?” [Emphasis added]

The environmental impact assessment does not detail the results of analysis of likely impacts on the individual protected structures (or a representative sample thereof) within the zone of visual influence of the development. For example, the application does not include details of site visits or include any photographs or photomontages produced from within the curtilage of any such protected structure. It is respectfully submitted that, having regard to the particular character of the Georgian City, this information is an essential part of a complete assessment of the likely impact of the proposed development on Ireland’s architectural heritage.

Impact on the Principal Rooms of Protected Structures

In the four storey, over basement, houses in Dublin’s South Georgian Core, the piano nobile or principal floor is generally located at first floor level. The houses built in and around Merrion Square, Fitzwilliam Square and Fitzwilliam Street were designed around the activities expected to take place on the piano nobile. Windows serving the front and rear-facing rooms on the piano nobile are the largest windows in their respective facades – the most important views from a Georgian building will be those from the piano nobile. That the principal living quarters of Georgian buildings were located at first floor level will be relevant in determining the visual sensitivities of the Georgian City and must colour an assessment of the impact of any proposal on the character of the Georgian City.

The angle of view available to pedestrians walking at street level means that lower development at the perimeter of a block will be visible, while taller elements which are set back away from the street will be less or not visible (see, for example, View 35). The Irish Georgian Society is concerned that, due to its elevated location, the piano nobile in certain protected structures will offer more open views of the tallest elements of the proposal, thereby negatively impacting on the character of those individual protected structures, but also on the overall character of the South Georgian Core within the zone of visual influence of the proposal.

The environmental impact assessment does not include details of the analysis of the potential impact of the proposal on the principal rooms of each of the protected structures (or a representative sample thereof) within the zone of visual influence. Specifically, the impact of the proposed development when viewed from the piano nobile is not discussed in the EIS. A desktop mapping analysis exercise indicated that the proposed development has the potential for visual impacts when viewed from the principal rooms of protected structures in the following areas:

·  Merrion Square North: the upper levels of the proposed development have the potential to be visible above and through gaps in intervening trees on Merrion Square from south-facing rooms at first floor level from a number of protected structures on Merrion Square. This is likely to be particularly the case in winter.

·  Merrion Square South: having regard to the relatively modest height of intervening buildings on Fitzwilliam Street Lower, there is a potential for the proposed development to be visible from south-facing rooms at first floor level (and east-facing rooms in returns).

·  Mount Street Upper: it is likely that the proposal will result in a change to the visual environment when viewed from most, if not all, south-facing rooms at first floor level on the southern side of Mount Street Upper. The proposal is also likely to be visible from the principal rooms of protected structures at the western end of the northern side of Mount Street Upper.

·  Mount Street Lower: there is potential for the upper levels of the proposal to be visible above the ridges of Georgian buildings on Mount Street Upper when viewed from the principal rooms to the rear of protected structures on the southern side of Mount Street Lower.

·  Fitzwilliam Street Upper: the proposed development is likely to be visible from the piano nobile of east-facing protected structures on the sections of Fitzwilliam Street Upper closest to Baggot Street Lower.

·  Baggot Street Lower: there is potential for the proposed development to be visible from northeast-facing rooms at first floor level on Baggot Street Lower.

·  Fitzwilliam Square South: mapping analysis would seem to suggest that there is a potential for the proposal to be visible from northeast-facing rooms at first floor level on Fitzwilliam Square South. Any such views are likely to be of the tallest elements of the proposal and are likely to be worst in winter when intervening deciduous trees in Fitzwilliam Square are leafless.

It is further noted that the Dublin City Council initiative ‘The Future of the South Georgian Core’ was considering proposals for the re-introduction of residential uses into the Georgian Core, including suggestions for the subdivision of Georgian buildings into three apartments: (i) the Georgian City Garden Duplex (at basement and ground level); (ii) the Georgian Piano Nobile Duplex (at ground to first floor level); and (iii) the Georgian Penthouse Duplex (at second to third level). Therefore, notwithstanding concerns about the visual impact of the proposal on the piano nobile for architectural heritage reasons, the Planning Authority may further wish to query the likely impact of the proposal on the visual amenity when viewed from the second and third floors of relevant protected structures.

Impact on the curtilages of Protected Structures

The environmental impact assessment does not include details of the analysis of the potential impact of the proposal on the context and setting of each of the protected structures (or a representative sample thereof) within the zone of visual influence as viewed from within the curtilage of that protected structure. Specifically, the impact of the proposed development on the rear gardens of protected structures in the vicinity of the site is not discussed in the EIS. A desktop mapping analysis exercise indicated that the proposed development has the potential for visual impacts when viewed from the rear gardens of protected structures in the following areas:

·  Merrion Square South and Baggot Street Lower – View 11 of the photomontages prepared on behalf of the Applicant, which is taken from Merrion Street upper opposite Fitzwilliam Lane, suggests that the proposal, which is higher than the existing complex, has the potential to be openly visible above the ridges of the Georgian buildings of Fitzwilliam Street Lower viewed from the rear gardens of Merrion Square South and Baggot Street Lower.

·  Mount Street Upper – View 29, in particular, illustrates that there is a potential for the proposal to be visible in west-facing views from the rear gardens of the south side of Mount Street Upper.

·  Fitzwilliam Street Upper – it is noted that the buildings on the corner of Baggot Street Lower where it meets Fitzwilliam Street Upper are of a relatively modest height and are, therefore, unlikely to obstruct views of the tallest elements of the proposal. It is further noted that application does not include a photomontage from Lad Lane (i.e. between Cumberland Road and Baggot Street Lower), but only a considerably more distant view from Wilton Terrace (View 13).

Notwithstanding concerns about the impact of the proposal on architectural heritage, it is noted that it is a stated policy of the Dublin City Development Plan 2011-2017 to encourage the reintroduction of residential uses into the Georgian Core. Given the importance of visual amenity and privacy from overlooking in the overall amenity value of private open space, it is suggested that information regarding the likely impact of the proposal on the rear gardens of Georgian buildings in the surrounding area will be of interest to the Planning Authority in determining whether the proposal is likely to impact upon the long term objective of returning the historic core to residential use.

Yours faithfully,

______

Donough Cahill

IGS Executive Director