Chapter 11: Built heritage and archaeology

11.1    Introduction

It is recognised that the city’s heritage contributes significantly to the collective memory of its communities and to the richness and diversity of its urban fabric. It is key to the city’s character, identity and authenticity and is a vital social, cultural, and economic asset for the development of the city.

The City’s historic buildings, streetscapes villages, Georgian terraces and squares, Victorian and Edwardian architecture, industrial heritage, institutional landmarks, modernist buildings of the 20th century, urban core and the Medieval City, together with its upstanding monuments and buried archaeology contribute to its local distinctiveness and help create a strong sense of place for citizens and visitors to the city and its neighbourhoods.

The development plan plays a key role in valuing and safeguarding built heritage and archaeology for future generations. The plan guides decision-making through policies and objectives and the implementation of national legislation to conserve, protect and enhance our built heritage and archaeology.

11.2    Achievements

The Council continually strives to protect, enhance and preserve our heritage assets. The Record of Protected Structures (RPS) comprises in excess of 8,400 structures. Since October 2016, there have been 51 additions, 10 amendments/clarifications and 129 deletions from the RPS. Work in this area is constantly in progress with ongoing assessments of structures for addition to the record.

There are presently 24 Architectural Conservation Areas (ACAs) in the city. In the period since the 2016-2022 Dublin City Development Plan was adopted, three additional ACAs have been designated at Haddon Road/Victoria Road, Hollybrook Road and North Great Georges Street.

Between 2016 and 2020, Dublin City Council administered 192 projects under the Built Heritage Investment Scheme and 15 projects under the Historic Structures Fund (previously called Structures at Risk fund) with a combined funding of over €2.2 million.

The Conservation Section promotes awareness of Architectural Conservation and Heritage by presenting a number of conservation lectures as part of the annual ‘Conserving Your Dublin Townhouse’ conservation course offered by the Georgian Society (in association with the Heritage Section of Dublin City Council).

The Dublin City Heritage Plan has been implemented since 2002 in association with the Heritage Council. Under the Plan, new projects are developed in the areas of heritage research, improving heritage management and raising awareness amongst a broad audience. A number of pioneering Heritage Plan projects have been undertaken since 2016, all supported by the Heritage Council. These projects include:

• 14 Henrietta Street, conservation/adaptive reuse and museum development project, winning awards from the RIAI in 2018 for ‘Best Conservation Project’ and more recently the ‘Silletto’ Prize at the European Museum of the Year 2020 awards.
• Original social and architectural history research into the processes of modernisation in Dublin during the 20th Century including ‘More than Concrete Blocks, Vol II 1940-1972’ and ‘Dublin Through the Ages: The City Walls.’

Notable achievements in the protection and promotion of our archaeological resource in the city include:

• Raising awareness of Viking Dublin through international engagement with the Viking urban network and diaspora including the establishment of the Annual ‘Festival of History International Viking’ Seminar with National University of Ireland.
• Preservation and presentation in situ of medieval and later structures in commercial developments at Aungier Street, Ship Street, Little Green Street and Thomas Street.
• Implementation of the Dublin City Walls and Defences Conservation Plan, including the installation of a permanent exhibit about the City Wall in the Wood Quay Venue; monitoring and conservation repair works to the City Wall at the Wood Quay Venue.

11.3    Challenges

There are a number of key issues facing the city in terms of its built heritage and archaeology.

• An over-arching issue is the on-going need to balance the often competing demands of a modern city in terms of consolidation and future growth with the need to protect its intrinsic character. There is a need to ensure that Dublin City is a real and vibrant city where people live and work, not merely a tourist destination. Dublin’s citizens will be encouraged to live in the historic core and the challenge will be to provide sensitive and environmentally sustainable restoration of historic properties, suitable for modern living.
• It is acknowledged that the ‘greenest building is one…. that is already built[1]’, and the continued, albeit appropriate use of an existing building is necessary for its survival. It is recognised that various historic buildings in the city remain underutilised and vacant. Identifying suitable and viable uses for certain heritage buildings, particularly the upper floors can be difficult. The challenge is to continuously facilitate and sensitively manage the changes required to adapt, reuse, upgrade and protect our rich architectural heritage whilst retaining its authenticity, integrity and special interests.
• Dublin’s built heritage and archaeology is a distinguishing feature in an increasingly homogenised world. It is a unique asset, which forms part of our cultural identity. There is a need to promote a deeper understanding of our built heritage and archaeology as an authentic, unique and finite resource. Increasing public awareness of the cultural value and social and economic significance of the city’s built heritage will be required. The widening appreciation of our heritage, culture and creativity also presents significant potential for collaboration with community, professional and institutional stakeholders across the various cultural spheres.
• The direct effects of climate change on heritage may be immediate or cumulative. Of the many potential impacts, those identified as priorities for adaptation planning are flooding, storm damage, coastal erosion, soil movement, changing burial-preservation conditions, pest and mould and maladaptation. In addition, there will be indirect impacts related to societal responses to climate change in terms of both adaptation (e.g. changes of land use) and mitigation (e.g. renovation or upgrading of historic buildings to reduce energy consumption). The challenge will be to conserve Dublin’s heritage for future generations and to develop sustainable policies and plans for climate change adaptation of built and archaeological heritage.

11.4    The Strategic Approach

The National Planning Framework (NPF) (particularly NPO 17 and NPO 60) highlights how our built, cultural and natural heritage has intrinsic value in defining the character of urban and rural areas and adding to their liveability, attractiveness and sense of place. It also emphasises how Ireland’s built heritage assets are a non-renewable resource that merit being nurtured in a manner appropriate to their significance as an aid to understanding the past, contributing to community well-being and quality of life as well as regional economic development.

The Regional Spatial and Economic Strategy (RSES) states that cultural heritage is the fabric of our lives and societies, that it surrounds us in the buildings of our towns and cities, our landscapes, natural sites, monuments and archaeological sites and that it brings communities together and builds shared understandings of the places we live.

The overarching strategic policy approach in both plans supports quality place-making and exemplar urban design. This has a clear synergy with the sense of place and character created by built heritage and archaeology.

In order to ensure the protection and enhancement of the city’s built heritage, the following strategic approach will be pursued:

• The preservation of the built heritage and archaeology of the city that makes a positive contribution to the character, appearance and quality of local streetscapes and the sustainable development of the city.

• Enhance, integrate and protect the special physical, social, economic and cultural value of built heritage assets through appropriate and sensitive development to ensure their preservation for existing and future generations.
• Ensure buildings of architectural and historic interest are protected and include those structures that are considered in the opinion of the Planning Authority to be of special architectural, historical, archaeological, artistic, cultural, scientific, technical or social interest in the Record of Protected Structures.
• Identify and designate Architectural Conservation Areas and Areas of Special Planning Control.
• Safeguard zones of archaeological interest.
• Implement and build on the success of the Dublin City Heritage Plan 2002-2006 along with the outcomes of the current City Heritage Plan Review 2021 and promote the role of heritage in fostering creative places that meet local needs and aspirations.
• Promote the reuse of redundant and underused heritage buildings and continue to promote active land measures such as the Living City Initiative and the Living-Over-the Shop scheme to encourage the sensitive reuse and adaptation of such buildings.
• Implement policies that support high quality architecture which respects cultural identity and past traditions of building settlement.
• Promote the environmental benefits of heritage conservation as a crucial contributor to sustainability as it fulfils the interrelated economic, cultural, social, and environmental principles of sustainable development.
• Promote best practice in the restoration of the fabric of historic buildings and enhance adaptive capacity, strengthen resilience and reduce the vulnerability of heritage in line with the National Climate Change Sectoral Adaptation Plan for Built and Archaeological Heritage (2020).

11.5    Policies and Objectives

11.5.1 The Record of Protected Structures

The Planning and Development Act, 2000 (as amended) requires each Planning Authority to include in their development plan objectives for the protection of structures, or parts of structures, which are of, special architectural, historical, archaeological, artistic, cultural, scientific, technical or social interest. These buildings and structures are compiled on a register referred to as the Record of Protected Structures (RPS). The RPS for Dublin City is listed in Volume 4 and shown on development plan maps. The record is a mechanism for the statutory protection of such structures. Reference to the National Inventory of Architectural Heritage (NIAH) and Ministerial Recommendations is made when assessing a building for inclusion on the RPS.

A ‘Protected Structure’[2] is defined as any structure or specified part of a structure, which is included in the RPS. Unless otherwise stated, it includes the interior of the structure, the land lying within the curtilage of the structure, any other structures lying within that curtilage and their interiors and all fixtures and features which form part of the interior or exterior of the above structures. The protection also extends to any features specified as being in the attendant grounds including boundary treatments.

External and Internal Works

All works to protected structures shall be carried out to the highest standards in accordance with the Architectural Heritage Protection Guidelines for Planning Authorities (Department of Arts, Heritage and the Gaeltacht, 2011). Additional guidance for proposed works to and the repair of historic structures and features are published by the Department of Housing, Local Government and Heritage Advice Series (available https://www.buildingsofireland.ie/resources), comprising a range of specific advice and guidance for example on: Windows: The Repair of Historic Windows (2007); Iron: The Repair of Wrought and Cast Ironwork (2009); Energy Efficiency in Traditional Buildings (2010); Access: Improving the Accessibility of Historic Buildings and Places (2011) and Paving: The Conservation of Historic Ground Surfaces (2015).

The City Council will manage and control external and internal works that materially affect the architectural character of the structure through the development management process. Planning permission is required for any works, including repairs, which would materially affect the character of the structure or its special interest.

All planning applications relating to Protected Structures shall contain the appropriate level of documentation in accordance with Article 23 (2) of the Planning and Development Regulations, 2001 (as amended) and chapter 6 and appendix B of the ‘Architectural Heritage Protection Guidelines for Planning Authorities’ (2011), or any variation thereof including where relevant an Architectural Heritage Impact Assessment.

Curtilage of a Protected Structure

The curtilage[3] of a Protected Structure is often an essential part of the structure’s special interest. In certain circumstances, the curtilage may comprise a clearly defined garden or grounds, which may have been laid out to complement the design or function. However, the curtilage of a structure can also be expansive and be affected by development at some distance away. The Architectural Heritage Impact Assessment submitted with any development proposal should also include an appraisal of the wider context of the site or structure including potential visual impacts on curtilage of a protected structure.

Historic Use

The historic use of the structure is part of its special interest and often the best use for a building will be that for which it was built. However, on occasion the change of use will be the best way to secure the long-term conservation of a structure. Where a change of use is proposed, the building should be capable of being converted into the new use without harmful extensions or modifications, such as the insertion of new openings, staircases, the substantial subdivision of historic floor plans and/or serious loss of historic fabric. Issues such as fire protection, sound proofing, servicing and access will also require careful consideration. In finding the optimum viable use for protected structures, other land-use policies and site development standards may be relaxed to achieve long-term conservation. In some circumstances, short-term uses may be deemed appropriate in order to ensure a building remains weather-tight and in use pending long-term solutions.

Fixtures and Fittings

Historic fixtures and fittings are at risk of damage or theft when buildings are vacant, undergoing building work or on the market. Where development is proposed, the Architectural Heritage Impact Assessment should outline how proposals will manage this risk. If architectural features are damaged or stolen they must be re-instated; this is likely to require a new planning application.

Demolition

Planning permission shall not be granted for the demolition or substantial demolition of a Protected Structure or a proposed Protected Structure except in exceptional circumstances (Section 57(10)(b) of the Planning and Development Act, 2000 (as amended)). It is accepted that in some circumstances, the loss of a protected structure may be the only option and this may be permitted where it will secure substantial public benefit or where there is no other viable option. Any proposal regarding the demolition of a Protected Structure will require the strongest justification provided by a qualified professional with expertise in architectural conservation. The applicant will be required to provide preservation by written and visual record of the structure or any element of the structure that contributes to its special interest, or the architectural salvaging or reinstatement of any such element, before the authorised development takes place.

Buildings-at-Risk

Each owner and occupier of a Protected Structure is required to ensure that the structure/building and any of its feature(s) of special interest are not endangered; under Section 58 of the Planning and Development Act, 2000 (as amended). Any person causing damage to a Protected Structure without lawful authority is guilty of an offence.

Dublin City Council maintains and proactively manages the Buildings-at-Risk Register of Protected Structures that are considered to be endangered or to have the potential to become ‘endangered’ through neglect, decay, damage or harm. The Conservation Section liaises between Planning Enforcement, Derelict Sites and Dangerous Buildings Sections of the City Council in order to prevent endangerment and to address endangerment where it has been identified.

Building Regulations

In carrying out works to protected structures in accordance with the requirements of building regulations, the special interest and character of the building should be considered. Further guidance is provided in the Advice Series publication “Access: Improving the Accessibility of Historic Buildings and Places (2011)”, and “Energy Efficiency in Traditional Buildings” (2010), published by the then Department of Arts, Heritage and the Gaeltacht, and now issued by the Department of Housing, Local Government and Heritage.

It is the Policy of Dublin City Council:
BHA1	Record of Protected Structures To include those structures that are considered to be of special architectural, historical, archaeological, artistic, cultural, scientific, technical or social interest in the Record of Protected Structures, and to remove those structures where protection is no longer warranted. To maintain and review the RPS whilst having regard to recommendations for additions to the RPS made by the Minister under Section 53 of the Planning and Development Act, 2000 (as amended).
BHA2	Development of Protected Structures That development will conserve and enhance Protected Structures and their curtilage and will: Ensure that any development proposals to Protected Structures, their curtilage and setting shall have regard to the ‘Architectural Heritage Protection Guidelines for Planning Authorities’ 2011 published by the Department of Culture, Heritage and the Gaeltacht. Protect Structures included on the RPS from any works that would negatively impact their special character and appearance. Ensure that works are carried out under supervision of a suitably qualified person with expertise in architectural conservation. Ensure that any development, modification, alteration, or extension affecting a Protected Structure and/or its setting is sensitively sited and designed, and is appropriate in terms of the proposed scale, mass, height, density, layout and materials. Ensure that the form and structural integrity of the Protected Structure is retained in any redevelopment and ensure that new development does not adversely impact the curtilage or the special character of the Protected Structure. Respect the historic fabric and the special interest of the interior, including its plan form, hierarchy of spaces, structure and architectural detail, fixtures and fittings and materials. Ensure that new and adapted uses are compatible with the architectural character and special interest(s) of the Protected Structure. Protect and retain important elements of built heritage including historic gardens, stone walls, entrance gates and piers and any other associated curtilage features. Ensure historic landscapes, gardens and trees (in good condition) associated with Protected Structures are protected from inappropriate development. Have regard to ecological considerations for example, protection of species such as bats.
BHA3	Loss of Protected Structures That the City Council will resist the total or substantial loss of Protected Structures in all but exceptional circumstances.
BHA4	Ministerial Recommendations To have regard to the National Inventory of Architectural Heritage (NIAH) rating of a structure and any associated Ministerial Recommendation in the assessment of planning applications.
BHA5	Demolition of Regional Rated Building on NIAH That there is a presumption against the demolition or substantial loss of any building or other structure assigned a ‘Regional’ rating or higher by the National Inventory of Architectural Heritage (NIAH), unless it is clearly justified in a written conservation assessment that the building has no special interest and is not suitable for addition to the City Council’s Record of Protected Structures (RPS); having regard to the provisions of Section 51, Part IV of the Planning and Development Act, 2000 (as amended) and the Architectural Heritage Protection Guidelines for Planning Authorities (2011).
BHA6	Buildings on Historic Maps That there will be a presumption against the demolition or substantial loss of any building or other structure which appears on historic maps up to and including the Ordnance Survey of Dublin City, 1847. A conservation report shall be submitted with the application and there will be a presumption against the demolition or substantial loss of the building or structure, unless demonstrated in the submitted conservation report this it has little or no special interest or merit having regard to the provisions of the Architectural Heritage Protection Guidelines for Planning Authorities (2011).

It is an Objective of Dublin City Council:
BHAO1	Buildings-at-Risk Register 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.

11.5.2 Architectural Conservation Areas

The Planning and Development Act, 2000 (as amended), provides the legislative basis for the protection of Architectural Conservation Areas (ACAs). Under the Act, an ACA is defined as a place, area, group of structures or townscape that is of special architectural, historical, archaeological, artistic, cultural, scientific, technical, social interest or value, or contributes to the appreciation of Protected Structures.

Architectural Conservation Areas (ACAs) are designated in recognition of their special interest or unique historic and architectural character and important contribution to the heritage of the city. This character is often derived from the cumulative impact of the area’s buildings, their setting, landscape and other locally important features which developed gradually over time. An ACA may consist of groupings of buildings and streetscapes and associated open spaces. Chapter 3 of the Architectural Heritage Protection Guidelines for Planning Authorities (2011) provides more detailed guidance in relation to of Architectural Conservation Areas and the assessment of development proposals within them.

The protected status afforded by inclusion in an ACA only applies to the exterior of structures and features of the streetscape.

While the purpose of ACA designation is to protect and enhance the special character of an area, it should not be viewed as a means of preventing new development but rather to help guide and manage change to ensure developments are sympathetic to the special character of the ACA.

The City has 24 designated ACAs which range from historic villages such as Chapelizod, to Georgian streets and squares, such as North Great George’s Street, Fitzwilliam Square and Mountjoy Square and attractive Victorian streetscapes such as Haddon Road and Victoria Road in the suburbs of Clontarf.

Each of the ACAs adopted by the City Council is shown on a map and accompanied by a detailed description of the architectural character and special interest of the area supported by policies and objectives to assist in the future management of development proposals for the area. The ACA document for each ACA is available online: https://www.dublincity.ie/archaeologyconservation&heritage/architecturalconservationareas

There is a presumption against the demolition or substantial loss of a structure that positively contributes to the character of the ACA except in exceptional circumstances where such loss would also contribute to a significant public benefit. In such exceptional circumstances, a proposal for demolition or substantial demolition will be considered having regard to the provisions of the ‘Architectural Heritage Protection Guidelines for Planning Authorities’ (2011). Where it is proposed to demolish a structure that contributes to the character of an ACA or to demolish behind a retained façade, the onus is on the applicant to make the case for demolition. Dublin City Council will consider the effect both on the character of the area and any adjacent Protected Structures. When it is proposed to demolish an undistinguished building in an ACA, the proposed replacement should not be of lesser quality or interest than the existing one and should not adversely affect the character of the area.

In considering a proposal for demolition, the applicant must demonstrate that the proposed replacement integrates exemplary principles of sustainable design.

Priority Architectural Conservation Areas

Dublin City currently has 24 Architectural Conservation Areas and further ACAs will be considered for designation over this development plan period. Fifteen ACAs have been identified for prioritisation following careful consideration of the aspects required to identify areas for protection under an ACA, as set out in chapter II, Part IV of the Planning and Development Act, 2000 (as amended) and expanded upon in Chapter 3 of the ‘Architectural Heritage Protection Guidelines for Planning Authorities’ (2011). These 15 ACAs and any others considered necessary at any time, will be progressed over the development plan period subject to a prioritisation programme to be agreed as part of the implementation of the development plan and the availability of resources.

Priority ACA projects (in alphabetical order)

• Aungier Street
• Brú Chaoimhín & Environs
• Ceannt Fort
• Collins Barracks, Arbour Hill & Environs
• CIE Estate Inchicore
• Grove Park
• Harold’s Cross
• Henrietta Street
• James’s Street/Thomas Street (west end)
• Marino
• Moore Street
• Parnell Square
• Rialto Court & Environs
• Stoneybatter
• The Tenter’s

Areas of Special Planning Control

An Area of Special Planning Control (ASPC) is all, or part of an Architectural Conservation Area which is considered to be of special importance to the civic life or the architectural, historical, cultural, or social character of a city or town in which it is situated. The legislation relating to ACAs and ASPCs is contained in Chapter II of Part IV of the Planning and Development Act, 2000, as amended.

Two Areas of Special Planning Control have been created for Dublin City Centre, O’ Connell Street and Environs ASPC and Grafton Street and Environs ASPC. The designation of these ASPC’s allows Dublin City Council to specify development objectives for the preservation or enhancement of the area that would further strengthen its designation as an Architectural Conservation Area. Dublin City Council monitors and reviews the schemes over a six year period and may by resolution, amend or revoke the scheme as necessary.

It is the Policy of Dublin City Council:
BHA7	Architectural Conservation Areas To protect the special interest and character of all areas which have been designated as an Architectural Conservation Area (ACA). Development within or affecting an ACA must contribute positively to its character and distinctiveness, and take opportunities to protect and enhance the character and appearance of the area and its setting wherever possible. Development shall not harm buildings, spaces, original street patterns, archaeological sites, historic boundaries or features, which contribute positively to the ACA. Please refer to Appendix 6 for a full list of ACAs in Dublin City. Ensure that all development proposals within an ACA contribute positively to the character and distinctiveness of the area and have full regard to the guidance set out in the Character Appraisals and Framework for each ACA. Ensure that any new development or alteration of a building within an ACA or immediately adjoining an ACA is complementary and/or sympathetic to their context, sensitively designed and appropriate in terms of scale, height, mass, density, building lines and materials and that it protects and enhances the ACA. Contemporary design which is in harmony with the area will be encouraged. Seek the retention of all features that contribute to the character of an ACA including boundary walls, railings, soft landscaping, traditional paving and street furniture. Promote sensitive hard and soft landscaping works that contribute to the character and quality of the ACA. Promote best conservation practice and encourage the use of appropriately qualified professional advisors, tradesmen and craftsmen, with recognised conservation expertise, for works to buildings of historic significance within Architectural Conservation Areas. All trees which contribute to the character and appearance of an Architectural Conservation Area, in the public realm, will be safeguarded, except where the tree is a threat to public safety, prevents universal access or requires removal to protect other specimens from disease.
BHA8	Demolition in an ACA There is a presumption against the demolition or substantial loss of a structure that positively contributes to the character of the ACA except in exceptional circumstances where such loss would also contribute to a significant public benefit.

It is an Objective of Dublin City Council:
BHAO2	Designation of ACAs To identify and designate further Architectural Conservation Areas (ACAs), within the identified priority areas in accordance with the Architectural Heritage Protection Guidelines, (2011).
BHAO3	Areas of Special Planning Control To prepare schemes for Areas of Special Planning Control, where deemed desirable and appropriate, having regard to the statutory needs of the city.
BHAO4	Bewley’s Oriental Café Bewley’s Oriental Café at No. 78/79 Grafton Street, is deemed to be a use that contributes significantly to the special and unique character of Grafton Street and, as such, is considered an essential part of the street. It is an objective, in accordance with the Scheme of Special Planning Control for Grafton Street and Environs, to protect the use of the building as a café, which is intrinsic to the special character of the building at basement, ground and first floor. Appropriate ancillary uses may be considered on the upper floors.