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Ref 14 to 17 Moore Street – Oral hearing held in the Gresham Hotel, Dublin on 20th to 24th April 2009 regarding Dublin Central Development

Plan Design Associates

Unit 3 Killala Road Business Park, Killala Road, Ballina, Co. Mayo

Ph(096) 72058 Fax (096) 75905

 An Bord Pleanála

64 Marlborough Street

Dublin 1 

20th April 2009


Re: Dublin Central Development

Dublin City Council Application No. 2479/08

Decision Date 15-Dec-2008

Decision Order No P5573

Location Former Carlton Cinema Site, the site consists of the majority of a city block bounded by Parnell Street, Moore Lane, O'Rahilly Parade, Moore Street, Henry Street, Henry Place and O’ Connell Street Upper.

 Dear Sir / Madam

 I have been asked to prepare comments and submissions for the oral hearing of the 20th April 2009 with respect to the above named development on behalf of National Graves Association Ireland and others.  The National Graves Association Office is registered at 74 Dame Street, Dublin 2.  The appeal lodged by the National Graves Association was lodged and receipted on the 20th January 2009, Receipt No. B100261. 

The basis for objection to the proposed development are outlined as follows and each item is dealt with in greater detail hereunder:

(1)                      Dramatic changes proposed to no’s 14, 15, 16 and 17 Moore Street and construction of substantial development on a National Monument

(2)                      Loss of three quarters of existing route known as Moore Lane and poor pedestrian link to Parnell Street

(3)                      Independence of Specialists

(4)                      Non compliance with Dublin City Development Plan and concerns regarding the scale, height and mass of the proposed development

(5)                      Omissions from the Public Notices

 1.0   Dramatic changes proposed to no’s 14, 15, 16 and 17 Moore Street and construction of a substantial development on a National Monument

 1.1   General

14 to 17 Moore Street are protected structures, added to the record of Protected Structures of DUBLIN CITY DEVELOPMENT PLAN 2005-2011, added by Resolution of City Council 4th September 2006.  No. 14 to 17 Moore Street are also National Monuments as in January 2007 the Minister for the Environment, Heritage and Local Government, Dick Roche, placed a preservation order under The National Monuments Acts 1943 to 2004 on these buildings, following an announcement by Taoiseach Bertie Ahern on 10th December 2006.  While proposed restoration of the Protected Structures and National Monuments, numbers 14 – 17 Moore Street is very desirable the architects and agents for Chartered Land Limited failed to address the reasons for demolition of the buildings to the rear of 14 to 17 Moore Street.  The National Monuments (Amendment) Act 2004 Section 5 states:

 In respect of a national monument of which the Minister or a local authority are the owners or the guardians or in respect of which a preservation order is in force, it shall not be lawful for any person to do any of the following things in relation to such national monument:

(a) to demolish or remove it wholly or in part or to disfigure, deface, alter, or in any manner injure or interfere with it, or

(b) to excavate, dig, plough or otherwise disturb the ground within, around, or in proximity to it, or

(c) to renovate or restore it, or

(d) to sell it or any part of it for exportation or to export it or any part of it,

without the consent referred to in subsection (2) of this section or otherwise than in accordance with such consent.

 The proposals of this application with regard to 14 to 17 Moore Street include the following:

·       Partial demolition( extensions to rear of houses)

·       Whole demolition ( buildings to rear)

·       Alteration of buildings

·       Interference with buildings

·       Excavation within rear yards, not only within close proximity but actually on the monument. 

We welcome the proposal to use No. 16 as a museum/commemorative centre but are aghast at the changes proposed to these buildings, which are not only of architectural significance but also historical significance on account of being the location of the last headquarters of the Provisional Government during the 1916 Rising, to quote minister Roche ‘This building is of immense historical significance to the State.  This is the site of the last stand of the 1916 leaders, Pearse, Connolly, Plunkett and Mac Dermott.... Their actions ultimately lit a fire of Irish nationalism that led in a relatively short time to the foundation of the modern Irish State’

1.2   Conservation Report prepared Shaffrey Associates Architects for No’s 14 to 17 Moore Street for submission with the planning application dated February 2008

1.2.1        Extract Page 8

Firstly it is of ‘Historical Interest’ due to its association with an important historical event, namely the 1916 Rising. It merits a National rating for its historic importance.

No. 14 Moore street is of ‘Architectural Interest’ as it is a good example of a modest mid eighteenth century townhouse, a typology that once would have dominated this area but that has become increasingly rare. It merits a Local rating for its architectural importance.

It is acknowledged that due to the events following the 1916 Rising that the buildings are of National Historical Interest and Local Architectural interest rating

1.2.2        Extract Page 5

Nos. 15-17 Moore Street were built as a small speculative development of three houses, all of which have remarkably survived, albeit with considerable alterations in the mid-19th century to the façades¹. However the rear façades and much of the original planned layout of these houses including original features such as the newelled staircases (still present in all three houses) and window and door architraves remains consistent with typical modest middle class houses of this date……The rear elevation gives us our strongest physical evidence of the nature of their integrated construction. All of these have a three-storey gabled return (nos. 16 & 17 having symmetrical plans, and share a diagonal chimney breast across their party wall), while the windows to the main back wall typically alternate in height, as those on one side are the windows on the half landings of the stairwell, and those on the other, are the main rear windows on each floor.… The diagonal chimneybreast has been long considered a feature of early-18th-century houses, but its survival here in a house whose date is absolutely clear from lease and map evidence, is an important addition to our understanding of 18th-century building technology’ (Page 5 extract)

 The proposed plans for the development contradict the author as follows:

(i)             The plans do not include the restoration of the diagonal chimney stack at ground floor level in No. 16, despite the existing chimney being retained in no. 17 and therefore replacement details are easily available. ( I draw your attention to 4.3.2. of Page 37 of the report that described the conservation process as including reconstruction of missing features)

(ii)          It is proposed to alter most of the plans of the existing premises

(iii)       The stairs are only being retained as a condition of planning permission condition no. 3(iv)

(iv)       The rear elevations are being completely altered.

 1.2.3        Extract Page 6

Nos. 14-17 and the street in general, underwent considerable architectural and social changes during the mid- to late-19th century. Moore Street became increasingly identified by its food and provision shops, with a particular emphasis on victuallers, poultry shops and butchers, many of the latter having their own slaughter houses to the rear and mews buildings and in the side lanes. The prevalence of butchers in particular was to continue into the 20th century when it was estimated that there were as many as twenty butcher shops on Moore Street alone in 1915 (Seamus Scully’s contemporary account).

Extract Page 7

In April 1916, Nos. 14-17 Moore Street would have looked very similar to how they do today. ………The intactness of the interiors varies, with No.15 having lost the majority of its early fabric, and with No.16 retaining its mid eighteenth character to the greatest degree.

 It is incredible that given the National Historical Interest Rating of this building due to the 1916 rising that the author of this report describes ‘Remove later additions and alterations’ as part of the Outline Schedule of works (Page 37)   This contradicts the author in that the buildings are of National importance due to the events that took place in the buildings in 1916, they were constructed circa 1759 and later additions were added ‘mid to late 19th century’, the author acknowledges that in April 1916 the buildings looked ‘very similar to how they do today’ and yet it is proposed to demolish the very partitions and extensions to the buildings that existed in 1916.  The National significance of the buildings cannot be ignored and the buildings should be repaired to their condition of 1916.  The author acknowledges that no. 16 retains its original 18th century character to the greatest degree yet it is proposed to remove most of the internal partitions of this building.  These partitions are the partitions against which the men of 1916 leaned, the floorboards on which they sat, the doors they opened and watched around, the window opes through which they kept watch, these are the details of greater significance than those of the date of construction and as a National Monument and Protected Structure of National interest, the partial demolition and the reconstruction of these buildings cannot be permitted. 

The plan no. 0707-00-102 by Shaffrey Associates Architects (dated Jan ‘08) does not reflect the description of works as ‘Conserve and restore historic interiors where appropriate’, as described in the Outline Schedule of works (Page 37).  This plan shows the partitions of the buildings to be retained in black and those to be removed as orange in colour, there are not many black walls.   I refer to Para 4.3.3. (Page 38) of the report ‘Changes to a building that have acquired historic significance in their own right will be retained and preserved.’  The authors words are not reflected in the proposed plans for this development.

 1.2.4.                     Extract Page 23 to 28

The report of February 2008 and November 2005 use the exact same wording on the description of the condition of the interior of the property and indeed uses the same photographs, this would lead to the question of whether or not the premises was indeed even visited and if so why the condition of the interior as of February 2008 was not recorded despite the dates on the reports being 27 months apart and the roof covering being missing.  The condition of the roof timbers, interior plaster work, interior flooring, ceilings etc. and the structure may have changed dramatically due to water ingress for that period and it is extremely irresponsible to use old photographs and an old description and not recorded the condition of the property in February 2008.

 1.2.5.                     Extract Page 34 and 36

There is also a proposed new public space to the rear of the National Monument, which is described in more detail below’ and ‘A new public space is formed to the rear of the National Monument by stepping back the adjacent new development.’

This is entirely incorrect as the public space is not at the ‘rear’ of the National Monument, the extent of the National Monument clearly shows the outline of the National Monument to extend to Moore Lane, however part of the proposed development is on top of the National Monument, located in the rear yards of these buildings and this statement shows the author using terminology to suit the proposed development in leading the reader to assume that the extent of the National Monument is the extent of the original 4 buildings, 14 to 17 Moore Street, this shows a total disregard for the actual extent of the National Monument.

 1.2.6.                     Extract Page 35

As such, the new buildings will only abut the National Monument at one location—

that is at the gable of No. 14….’

This is incorrect, in fact the plan shown on the same page shows the new development abuts the gable of No. 14 but there is a proposed new development on the gable of no. 17 also, again the author is misleading the reader.  Incidentally the extension to No. 17 is not shown on the previously mentioned drawing no. 0707-00-102, yet the partial removal of the gable of no. 17 to accommodate access to the extension is shown.

1.2.7.                     Extract Page 36

Two new additions are proposed to Nos. 14 to 17 and these are designed to facilitate greater engagement between the National Monument and the new development.’  Once again this is incorrect in that the Outline Schedule of works details an extension to No. 16 and No. 15 also, therefore an accurate description would be that the developer intends to extend each of the properties 14 to 17 Moore Street. 

1.2.8.                     Extract Page 37

The outline schedule of works to each of the addresses makes no reference to the entire demolition of the rear yards, the rear building onto Moore Lane or the entire excavation of the rear yard to form the basement section to the building to the rear.

This is a serious omission as the works to the rear yard are located within the National Monument.

1.2.9.                     Extract Page 38

Prior to commencing any works, a further detailed condition survey will be carried out to establish the condition and soundness of surviving structure and fabric.’

Surely the author of the report should have carried out this survey to ensure that the structure and fabric of the buildings can be retained as proposed prior to giving a description of the impacts of the proposed development, what will happen in the event that the follow on survey reveals a structural deficit in one or all of the buildings and the structure of the buildings are undermined, this condition survey is an integral part of the conservation report, a responsible conservation architect cannot recommend a schedule of works if they are uncertain if these works are feasible to carry out. 

1.2.10.               Extract Page 40

Alterations include the selective removal of buildings or other features of the environment or building site that are intrusive and therefore detract from the overall historic character.

The removal of all the buildings to the rear of buildings no. 14 to 17 is not included elsewhere in the report and is not given in the outline Schedule of works for each premises, despite the fact that these buildings form part of the National Monument, their entire removal was afforded a mere 27 words.

 1.2.11.               Extract Page 41

Where appropriate a fire safety engineering design solution by Specialist Fire Engineering consultants based on risk assessment of the building and development of a strategic approach to fire safety measures will be adopted to minimise impact on the building , important fabric and elements of the protected structure to lead to a more sympathetic solution. Compensating measures will be proposed where appropriate and allowed to enhance fire safety.’ 

The Architectural Heritage Protection guidelines for Planning Authorities issued by the department of the Environment, Heritage and Local Government 2004, states the following: Para 17.1.3. ‘In the interests of good conservation, consultation between the applicant, the planning authority and the fire authority should take place where possible, at a pre-planning stage.’  Fire Safety issues need to be addressed early in the conservation process to ensure adequate fire safety of the buildings and adequate escape is provided without compromising the conservation of the buildings. 

1.2.12                  Extract Page 43

‘The basements of the buildings have limited height and to improve the usability of this space the floor will be lowered and the basements will also be extended out to the line of the proposed deep basement of the adjoining overall development. Existing buildings will be underpinned and the necessary temporary support will be put in place in such a manner that adequate support is maintained at all times to the underside of the wall.’

There are no details provided as to how it is proposed to lower the basements, how the front wall will be supported with the removal of the front wall of the basement, how the spoil shall be removed etc..  No evidence has been provided to suggest that the basements were originally lower and should therefore be changed at all.   

1.2.13                  Extract Page 45 - 4.5.13

‘The stair remains in all buildings but has been interrupted by alterations and modifications. It is proposed to fully reinstate the stairs. Missing flights will be reinstated to match existing. Damaged timber stair treads, riser, handrails, balusters will be repaired. Missing balusters will be replaced to match the existing. The under carriage will be strengthened’

It is vey unclear on the plans the status regarding the stairs, this states that all stairs will be retained and yet there are numerous plans showing the stairs being removed, for example Drawing No. 0707-00-102 clearly shows a number of stairs in orange colour indicating that they are to be removed, no stairs are retained in No. 16 or 14 at all according to this ground floor plan, despite the plans being drawn by the same consultancy that wrote the above statement one month later.  The lack of clarity is this regard is reflected in the conditions imposed in the decision to grant planning of permission by Dublin City Council. 

1.2.14                  Extract from Page 46 – 5.1

‘The principle urban design proposals—i.e. the altering of the existing street pattern within the development block to provide two new pedestrian streets and two new public spaces will impact on the setting of the Nos. 14 to 17, in particular the east-west street which will run directly north of No. 17, and will accordingly alter the public presentation of these buildings from their present street terrace arrangement.

There is no reference to the impact of the removal of Moore Lane despite it’s historical significance as it was used as the access route to the Moore Street properties during 1916.  This is dealt with in greater detail in Section 2 of this objection. 

1.2.15                  Extract from Page 46 – 5.2.

Thus, the impact of the proposed works to Nos. 14 to 17 is considered to have a positive impact on these Protected Structures/National Monument in that their  condition will be restored, appropriate uses are proposed—including the proposed use of No. 16 as a Museum/ Interpretive Centre— to a large extent their historic layout will be retained/reinstated and, the historic relationship to Moore Street will be retained.

It is unclear how the proposed development can have a positive impact on the Protected Structures / National Monuments when in fact the majority of the National Monument is destroyed by total or partial demolition and the above matters have not been addressed.   

Given that the uses of No. 14, 15 and 17 are not detailed other than retail, it is not possible to determine the intensification of the usage and if the uses are ‘appropriate’

 As No’s 14 to 17 are Protected Structures the entire boundaries of each of the properties are also subject of protection under the definition of a protected structure as defined in the Planning and Development Act as follows:

any building, structure, excavation, or other thing constructed or made on, in or under any land, or any part of a structure’ 

A guide to protected structures issued by the Department of the Environment, Heritage and Local Government gives the following guidance: What parts of a protected structure must be preserved? The obligation to preserve a protected structure applies to all parts of the structure, including its interior, all land around it, and any other structures on that land. The obligation also applies to all fixtures and fittings forming part of the interior of a protected structure or of any structure on land around it.’

The demolition of rear yards and buildings in the yards to the rear of 14 to 17 Moore Street must be addressed accordingly. 

 1.3     Drawings prepared By Shaffrey Associates Architects

In this section I specifically refer to the drawings dated January ’08.  There are a large number of discrepancies between the proposed demolition plans and floor plan proposals that mislead the public (and officials) and are grossly inaccurate considering they are detailing a National Monument and the proposed works to same.

 1.3.1.                     Drawing 0707-00-101 and Drawing 0707-01-101 – Basement Floor Plans

No. 17 - The surrounding partitions to room 17B.4 are shown to be retained on the proposed demolition plan but to be partially removed on the basement plan proposal 

The thickening to the wall at the rear of No. 17 is shown to be retained on the proposed demolition plan but to be removed on the basement plan proposal, this could undermine the rear wall.

 No. 16 – The opening in the main wall traversing the centre of the basement has increased in width on the basement plan proposal.

 No. 15 – A comparison of the party wall between No. 15 and 16 and the thickness of the front wall shows a huge difference between drawing 0707-00-101 and Drawing 0707-01-101 and indicates that a large portion of these walls are to be removed to achieve maximum space in the basement of No. 15. 

The partition wall between 15B.2 and 15B.3 is shown to be retained on the proposed demolition plan but to be removed on the basement plan.

 There is a new door ope formed in the rear wall that is not shown as partial demolition on the proposed demolition plan 

No. 14 - There is a new door ope formed in the rear wall that is not shown as partial demolition on the proposed demolition plan

 1.3.2.                     Drawing 0707-00-102 and Drawing 0707-01-102 – Ground Floor Plans

No. 17 - The return of the gable wall to number 17 is shown to be retained for the entire width of the front wall on the demolition plan and is shown as partially retained on the ground floor plan proposal, this could seriously undermine the front wall of the monument.  It is also noted that the computer generated image of Moore Street depicts a substantial gable return to be retained. 

There is a section of wall shown on plan 0707-01-102 at the rear door of No. 17 shown as an existing wall, this wall is entirely omitted from the survey drawing and yet is being retained on the proposal drawing.  Also on this section of No. 17 the rear wall to the staircase is shown to be demolished on No. 17 and yet to be retained on ground floor proposal

 There is a door underneath the staircase in No. 17 that is shown on the demolition plan to be retained and is omitted from the ground floor plan proposal.  There is an existing return to the north east of the door affording access to the stairwell on the proposed plan shown as a wall to be retained and yet the survey plans show no such wall exist.

 No. 16 - There is a substantial difference shown between these two plans, the proposed demolition plan shows the existing partition between room 16G.2 and 16G.1 to be retained but the ground floor plan proposal shows the partition removed between these same rooms. 

 No. 15 - At the rear of No. 15 the demolition plan shows a square protrusion from the wall to room 15G.5 and shows the entire rear wall (including the stack) to be retained, the proposal shows a corner without such a protrusion and a stairs is neatly accommodated in its place.

 No. 14 - The gable of No. 14 adjoining the proposed new development is shown on the demolition plan to be retained for a distance of 12.535m, however close examination of the proposed ground floor plan shows the gable retained for a distance of 10.68m.  The revised plans for the Further Information show a large ope in the gable rear wall of No. 14 and the integration of this unit with No. 13 Moore Street.

 1.3.3.                     Drawing 0707-00-103 and Drawing 0707-01-103 – First Floor Plans

No. 17 - There is a substantial difference shown between these two plans, the proposed demolition plan shows the entire gable of No. 17 being retained at first floor level, the proposed first floor plan proposal shows the gable of no. 17 removed for a distance of 4.75m to afford access to the proposed extension to the gable of No. 17.   

The wall between the rooms 17F.5 and 17F.6 is also shown to be retained on the demolition plan and yet the wall is removed on the first floor plan proposal to accommodate a staircase.  

The partition dividing 17F.5 and 17F.3 is shown as demolished on the demolition plan and partially retained on the first floor plan proposal.

No. 14 - The proposed demolition plan does not show any provision for a link to the proposed extension through the gable wall as is shown on the proposed first floor plans, indeed the size of the opening forming this link varies depending on which consultants plans you refer to, the plans prepared by Dublin Central Architects, Drawing No. 5539-LA-L1-002 shows a different ope size despite being stamped as received by Dublin City Council on the same date as the Shaffrey Associates Architects plans.

 1.3.4.                     Drawing 0707-00-104 and Drawing 0707-01-104 – Second Floor Plans

No. 17 - The wall between the rooms 17S.5 and 17S.3 is shown to be retained on the demolition plan and yet the wall is removed on the second floor plan proposal to accommodate a staircase.

 No. 15 – The second floor plan proposal Drawing 0707-01-104 shows a window in the rear of 15S.4 that does not appear on the survey plans nor is a new ope highlighted on the demolition plans.

 The partition between 17S.5 and 17S.1 shows a new door ope on the second floor plan proposal.

 1.3.5.                     General comments on Drawings prepared by Shaffrey Associates Architects.

It is noted that the commemorative plaque located on No. 16 is not shown on Drawing No. 0707-00-201 survey elevations of Moore Street.

The chimney shown at the rear of No. 14 on Drawing No. 0707-02-202 (Proposed rear of Moore Street elevations) is not shown on the computer generated image labelled No. 14 to 17 Moore Street

 The image of the kiosk shown on Drawing No. 0707-01-102 – Kiosk Proposal  at the rear of No. 17 Moore Street is drastically different from that shown on the computer generated image called rear of 14 to 17 Moore Street and indeed the Kiosk is removed from drawing No. 0707-01-103 Revision A.I.-C, also dated January ’08, also prepared by Shaffrey Associates Architects and also available for public viewing.  

 Drawing No. 0707-03-301 accurately shows the ‘Civic Space’ that keeps being referred to throughout the entire application, there is barely place to illustrate somebody sitting down, let alone have a civic square.

 Drawing No. 0707-03-302, 303 ,304 and 305 do not show the excavation depths for the basement levels to the rear of the buildings on the proposed sections of Moore Street buildings.

 1.4   Conservation Report on No. 14 to 17 Moore Street prepared by Shaffrey Associates Architects for Dublin City Council, November 2005.

 1.4.1.       Para 5.2.4. and Fig 5.9

‘Long narrow rear site at present opened with No. 15.  Boundary walls of calp rubble and sections of concrete.  Industrial building late 19th century to rear, built as a pair with No. 15 and comprising front wall of coursed calp rubble with machine made red brick above.  Carriage arch entrance with modern steel sliding shutter attached internally.  Pedestrian entrance adjacent, having tripartite arrangement of square window opes above.  Flush granite cill course beneath run of vertical slit window ope’  and  ‘The rear building forms an attractive composition with its neighbour and makes a positive contribution to the streetscape in terms of design, scale and use of materials’  and ‘This rear building along with its more intact pair is an integral element of this small scale streetscape onto Moore Lane.  It is a fine example of nineteenth century urban backlands architecture, a typology that is being rapidly eroded in the city.  This building displays a good quality workmanship and design, of particular note is the execution of the stone and brick work

There is a vast difference between the appraisal of the rear site in the report dated February 2008 and the report dated November 2005 in that the author of the 2008 report no longer refers to the ‘typology that is being rapidly eroded in the city’ .

 1.4.2Para 7.1.2.- Recommendations and conclusions

Prior to any works being carried out to No. 16 it is recommended that a detailed survey of the building is carried out in order to identify any presently obscured detail which might add to the current understanding of the building, in particular any evidence which might throw greater light on the events during its occupation by the rebel forces during the 1916 rising’  This recommendation has not been met in that the report dated 23 months later does not even show any new photographs.

 1.4.3Para 7.1.4.

‘It is likely that considerable redevelopment will take place in Moore Street in future years. As suggested above, the grouping comprising No’s 14 to 17 should be retained and integrated within any such development.  The approach to redevelopment should ensure the visual coherence of this grouping is protected.  Junctions between existing and new should ensure visual clarity.  Conceptually, the architectural approaches taken in the Irish Film Institute on Eustace Street and the National Gallery of Ireland’s recent extension, are worthy of consideration.  In particular the way in which the new additions have addressed the existing buildings and new public / social spaces have been made’

It appears that the recommendations regarding taking example from these two fine projects has been ignored.

 1.4.4Para. 7.1.5 and Para. 5.2.4.

In terms of defining a suitable building line for new development to the rear of No. 16, the east boundary identified on the 1852 lease – which equates to the rear (inner) wall of the recently demolished former industrial building onto Moore Lane suggests itself as an appropriate line to ensure the setting of No. 16 is protected’ and ‘The 1892 lease provides a schedule of area for No. 16 which is 20 feet by 92 feet in length.  The distance from the front façade of Moore Street to the rear (inner) wall of the building onto Moore |Lane is approximately 92 feet and this would indicate that this wall formed the boundary line of the 2 leases’

92 ft (28.04m) is therefore the recommended building line for new development as per Shaffrey Associates Architects Recommendations of November 2005.  The measurement of this to best fit on a map is approx 28.5m. 

Drawing No. 0707-01-103 dated January ’08 shows the new development constructed circa 19m from Moore Street when measured along the party wall between No. 15 and 16.  

1.4.5Para. 7.1.7.

The events of the Easter Rising which took place on other sites within the Moore Street area, which have been extensively altered since 1916, should be acknowledged within any new development in a coordinated and planned manner.  Shane Cullen’s touching wall plaque erected on O’ Rahilly Parade, which sets out the dying words to his wife which The O’ Rahilly struggled to write, is one of the more affecting monuments in the city. It shows how the individual stories, which make up any historic event, can be commemorated in imaginative and effective ways’.

2.0         Loss of three quarters of existing route known as Moore Lane (formerly known as Brick Field Lane) and poor pedestrian link to Parnell Street

2.1   General

Page 6.10.5 details the history of Moore Lane laid out in 1773

The proposed development shows the removal of Moore Lane from the junction with Henry Place to the junction with O Rahilly Parade. This street forms part of the historical street fabric of Dublin City Centre, clearly shown on the Pool and Cash maps of 1780.  Moore Lane is described in the Dublin Street Directory of 1862 as ‘From Great Britain Street to Off Lane’ and lists a number of residents and tenants   

The proposal includes the removal of circa 120m of Moore Lane and circa 73m of Henry Place is being removed.  I refer to Section 1.4.2. above and in particular to the reference to acknowledgment of ‘other sites within the Moore Street area’, this proposal does not acknowledge other sites, it totally demolishes the streets including the majority of Moore Lane.

 An Phoblacht carried a feature in September 2005 regarding the historical significance of 16 Moore Street and in that article it states ‘they left the GPO by the side entrance in Henry Street and made their way under constant sniper fire to Moore Lane’   

An extract from Saoirse, the Sinn Fein Publication states ‘They left the GPO by the side entrance in Henry Street and made their way under constant sniper fire to Moore Lane

There is little doubt that Moore Lane was the route used by the Provisional Army Leaders in gaining access to No. 16 Moore Street and therefore has a strong historical significance and its removal should be refused.

 I refer to the Conservation Report prepared by David Slattery, Architect, and in particular to Section 10 Potential Impact of the Proposal on Henry Place, O Rahilly Parade and Moore Lane ‘The buildings are of little interest architecturally or historically and the current proposal sets out to rationalise this area and to create a significant new development within the area.  The loss of what currently exits cannot be seen as significant’  The significance of the removal of the Lane is not addressed, this refers to the buildings only.

 I refer to the conservation report prepared by Shaffrey Associates Architects dated October 2008 and in particular to Pages 45 and 46 of same, giving details of the impact on the Protected Structure / National Monument, Moore Lane is not mentioned, the rear yard of No. 15 and 16 are not mentioned and the demolition of the façade onto Moore Lane, which was earlier referred to as ‘an integral element of this small scale streetscape onto Moore Lane’ ( Shaffrey Associates Architects report dated November 2005.

 I refer to the Bureau of Military History Witness Statements summarised in the rear of the Shaffrey Associates Architects report dated November 2005 and to the numerous references made to Moore Lane in same, there is no doubt that Moore Lane is of significant historical interest from the 1916 rising from these statements.  Refer to statements from Ruaidhrí Henderson, Diarmuid Lynch, Seán McLoughlin, Seamus Robinson, Desmond Ryan, Michael Staines, Liam Tannam, Feargus de Burca, Oscar Traynor, Eamon Bulfin, Patrick Caldwell, Elizabeth O Farrell and Julia Grenan. 

 2.2   ILTP Consulting Report

Section 4 of the ILTP Consulting report states ‘The site is located adjacent to O’ Connell Street with Parnell Street bounding the site to the North and Henry Street bounding the site to the south.  There are also additional streets within the scheme, which are to be retained’  This is obviously incorrect as the majority of the internal streets are not being retained.

 2.3   Department of the Environment, Heritage and Local Government submission

I refer to the Submission Ref DAU-2008-DU-DC 08-2479 by Department of the Environment, Heritage and Local Government dated 30th May 2008 and the reference to the loss of Moore Lane as follows: ‘The loss of the historic street pattern within the ACA, including the complete loss of Moore Lane, which dates from 1760, would seriously diminish the character of the ACA and is contrary to the Planning Authority’s development control policy for the area’ and ‘Consideration should be given to revising part of the proposed layout to retain the existing historic street pattern as part of the new development’ 

2.4   Report for Failte Ireland by ICON Architecture

I refer to the proposal for new streets as follows: ‘It is the first time Dublin stands to gain new streets since the activities of the Wide Street Commissioner in the 1950’s’  However the author omits to mention that the creation of the new streets is at the cost of the loss of part of the historical street pattern of Dublin City Centre.

 2.5   Failte Ireland Submission

I refer to the submission of Fáilte Ireland dated 6th June 2008 and in particular to the issues they listed which ‘need to be addressed’ as follows; ‘The lack of a strong connection to Parnell Street and Square which would help to develop better the strategic linkages envisaged in the development of Parnell Square as a lively cultural quarter’. 

2.6   Planner Report for file reference 5343/07

I refer to the planning permission granted to Kellgrove Properties Ltd for No. 17 to 19 Moore Lane and in particular to the planners report dated 13th February 2008 that describes the area as follows: ‘This area, particularly Parnell Street exhibits a strong sense of place as there are already a vibrant mix of uses’  However the planners now feel that this area no longer deserves a pedestrian link and have downgraded Moore Lane, the same site subject of 5343/07, to a service lane.

 2.7   John Spain Associates Appeal

I refer to the appeal lodged by John Spain Associates on behalf of Treasury Holdings and in particular to Section 3.11 in which it is argued that the chance to provide a pedestrian link with the existing Moore Lane and Henry Street has been lost through this application and the dual benefit of this would be that it would ensure appropriate retail and commercial use as per previously granted planning permissions for Moore Lane (on the section of Moore Lane to be retained) and Parnell Street.  In summary the proposal fails to realise potential linkages to Parnell Street via Moore Lane and thus increase pedestrian traffic flows to the retail area of Parnell Street.

 Interestingly the exact line of the extent of O Connell Street ACA is Moore Lane 

3.0   Independence of Specialists

 3.1         General

The EPA guidelines on the information to be contained in EIS states that ‘EIA is critically dependent on the expertise, experience, independence and objectivity of environmental specialists’ I respectfully submit that independence and objectivity of specialists are critical and it may be considered somewhat inappropriate for a specialist for the developer to also act for Dublin City Council. 

 3.2         Inspectors Report Ref PL 29S.228512

I refer to the Inspectors report regarding Independence of Specialists and the Inspector deemed that the submissions should be from independent specialists but still considered the submissions from the specialists in the preparation of the report.

 4.0   Non compliance with Dublin City Development Plan and Scale, height and skyline of the proposed development

 4.1         Dublin City Development Plan 2005-2011

4.1.1.       Extract Page 23 - Urban Design : Local

Urban design at the local level is concerned with the street or urban space and in particular with the relationship between the following three elements:

·       The buildings, (built heritage and new developments) of appropriate height, form and architectural quality, linked visually to contain and define the street or space

·       The uses which enliven the spaces and the buildings and

·       The public domain ie the area defined by buildings – the street, public space

The proposed development does not take into account the relationship between the existing buildings and the streets, with regard to appropriate height, form, architectural quality and does not take into account the existing street layout but is based on a principally new street layout. 

4.1.2.       Extract Page 23 – Buildings - Built Heritage

To maintain and enhance the potential of protected structures and other buildings of

architectural/historical merit to contribute to the cultural character and identity of the place, including identifying appropriate viable contemporary uses

The existing identity of the area is not being maintained or enhanced as the existing identity of the area is being changed by the changes to the streets areas. 

4.1.3.       Extract Page 23 – New Development

To complement the established pattern of development in the immediate environs, with particular regard to the established grain, scale, massing, materials and colour of the built fabric

To determine an appropriate height, scale and massing to define the street or space

To reinforce the definition of the space/street by relating to an established common building line and enclosing the building block

The established pattern is being demolished by the removal of Moore Lane at the rear of No. 16.

The proposed development is not considered to an appropriate height, scale and massing to define the street. 

The proposed development will not exactly ‘reinforce’ the definition of Moore Lane.

 4.1.4.       Extract Page 24 – Public Domain

To reinforce/create an identifiable network of safe, and pedestrian friendly, interconnected streets and spaces

The proposed revised street layout does not reinforce an identifiable network of safe and pedestrian friendly streets in that the existing routes will change dramatically as follows:

There is currently 2 no. pedestrian routes from Moore Street through the site, Henry Place and O’ Rahilly Parade.  O’ Rahilly Parade will be effectively changed to a service lane as the proposed plans show O’ Rahilly Parade and Moore Lane with a number of ESB substations and ramps.  Henry Place is being partially removed.

The proposed new east west ‘street’ is located circa. 36m from O’Rahilly Parade and does not provide a link to Henry Place or to Parnell Street as was accessible from the portion of Henry place to be removed.

4.1.5.                     Extract Page 71 – The Curtilage and Attendant Grounds of Protected Structures

Protection extends not only to the protected structure itself but also to the structures that are of heritage value within the cartilage and to specified features within the attendant grounds of such structures. 


It is the policy of Dublin City Council to protect the curtilage of protected structures or proposed protected structures from any works which would cause loss of or damage to the special character of the protected structure and loss of or damage to, any structures of heritage value within the curtilage of the protected structure.


It is the policy of Dublin City Council to protect structures and features that are considered to be of heritage value which lie within the attendant grounds of a protected structure.

These policies have not been applied to this application in that the curtilage of the sites has not been addressed at all with regard to properties 14 to 17 Moore Street and the demolition of the features to the rear of the site are being demolished without consideration of the alternatives. 

4.1.6.       Extract Page 75 - POLICY H19

It is the policy of Dublin City Council to seek to protect the character, vibrancy and historic fabric of key historic streets.

Moore Lane must be considered as an Historic Street given the links with the 1916 Rising as outlined before.

 4.1.7.       Extract Page 76 -  Para. 10.3.4. - The Public Realm inclusive of street furniture and historic paving

Historic features located within the public realm contribute to the special interest and character of the city. Such features include … sett…… which are worthy of conservation and repair. In recognition of the importance of these features and the pressure placed on them from road and paving works, Dublin City Council will seek to preserve, repair and retain in situ historic streetscape and paving features of heritage value which are set out in Appendices 8, 9,and 10.

I refer to the report dated November 2005 prepared by Shaffrey Associates Architects and in particular to Para 7.1.1 Page 42, ‘Moore Lane….retain little of the character of this time (with the notable exception of surviving granite kerbs and limestone setts along Moore Lane adjacent to the latter site’ These are the very setts that the men of 1916 died on including The O’ Rahilly.  Surely this must define an ‘Historic Street’. 

Objective H11

It is an objective of Dublin City Council to preserve Number 16 Moore Street as a commemorative centre marking the events of Easter 1916.

Given the extent of No. 16 and the queries raised with regard to the accuracy of details and what actually defines ‘preserve’, this objective is not being adhered to.

4.1.8.                     Extract Page 120 – Para. 15.1.1. – Design

The analysis of any proposal will assess the visual characteristics of the building form(s) and related elements, such as: aspect and orientation; proportion; the balance of solid to void; the shapes and details of roofs, chimneys, windows and doors and the materials used. Details of walls, gates, street furniture, planting and paving will also be noted.

This has obviously not been adhered to as the details with regard to finishes for the development have not even been provided in any detail and thus the planner has recommended a condition of planning permission, Condition No. 2(i) requests exact details of all external material finishes to be agreed with the planning authority prior to commencement.  The finishes of a development are critical to the overall design and it is not acceptable that these finishes be agreed outside the availability of public comment or objection. 

4.1.9.                     Extract Page 123 – Para 15.4.- Plot ratio

The indicative plot ratio for Zone Z5 is given as 2.5-3.0.

The actual plot ratio of the proposed development is not in compliance with this guideline as the plot ratio of the development is 5.13 according to the details of the Senior Planners report (under Section 3.2), double the plot ratio recommended in the Development Plan.

 4.1.10                  Extract Page 123 –Para 15.6.0- Building Heights

The definition of appropriate building height in context is relative and relates not only to the prevailing or dominant heights but also to the grain and its consistency or diversity within an existing character area

The proposed design should therefore take into account the existing prevailing heights, the existing urban grain, and the existing character of the area.  The actual design subject of this application marks a stark contrast to the prevailing heights and densities surrounding it.  The impact of proposed development will constitute gross overdevelopment and over intensification of use of the site, will be highly obtrusive, will seriously injure the visual amenity of the area.  The proposed development will have a significant adverse impact on the streetscape and on the setting of the many protected structures (and National Monument) within the site.

 4.1.11      Extract Page 134 – Para 15.10.2 - Development within the Curtilage and Setting of Protected Structures

An insistence on quality design will be a foremost consideration when assessing proposals for development within the curtilage of protected structures, with particular emphasis on siting, building lines, proportions, scale, massing, height, roof treatment and materials. This does not preclude innovative contemporary buildings which can contribute to the richness of the historical context.  Materials shall be appropriate to the locality and sympathetic to the existing buildings.

The building line recommended in the report of Shaffrey Associates Architects dated November 2005 has not been adhered to.  The height of the existing parapet of No. 16 Moore Street is 10.2m.  The height of the proposed development to the rear of the National Monument is approximately 4 times the height of the existing building.

 The Planning Authority will seek to retain the traditional proportionate relationship in scale between buildings, their returns, gardens and mews structures, and shall also seek to retain gardens and mature trees (those in good condition) which contribute to the character of a protected structure, as soft landscape.

The rear gardens of No. 14 to 17 Moore Street are not being retained as part of this proposed development contrary to this section of the Plan. Approximately 6m to the start of the new development from the rear of the annex to No. 16 does not constitute retaining the traditional garden and the proposal includes the complete removal of the mews in the rear yard.  

4.1.12      Extract from Page 135 – Para 15.10.4- Development in Conservation Areas

All new buildings should complement and enhance the character and setting of conservation areas.

The impact of development on the immediate streetscape in terms of compatibility of design, scale, height, plot width, roof treatment, materials, landscaping, mix and intensity of use proposed

The ACA of O Connell Street does not appear to have been afforded these policies of Dublin City Development Plan.

Development within conservation areas should be so designed so as not to constitute a visually obtrusive or dominant form of development.

The new development when viewed from O Connell Street is, without doubt, visually obtrusive and dominant!

 4.2     Comments on Report of Planning Officer, Paul Kearns of Dublin City Council Planning Department

 4.2.1.       Para 1.1 Site Location and Description

The Planners description of the site location and Description completely omits any reference to Moore Lane (until he describes the proposed development and demolition of buildings on same) despite the fact that the site completely traverses the site subject of this application.

 In Buildings of Note he does not refer to the buildings to the rear of No’s 14 to 17 despite these buildings being located on a National Monument.

 4.2.2.                     Para 1.2 Description of the proposed development 

Proposed Land Uses

The list of proposed land uses listed by the planner include the following:

3 no. public spaces at street level

An outdoor performance space (c263sq.m.)

These items listed in the proposed land uses are nothing short of laughable, a public street is not a public space.  A public space is defined as ‘open space …for active and passive recreation, including relaxation and children’s play…and maintenance of wildlife habitats’   I do not think the public streets proposed as part of this development will accommodate the type of ‘wildlife’ intended in the DCC Development Plan.

The outdoor performance space is an irregular shaped small area to the rear of No. 14 to 17 Moore Street, to be used as a thoroughfare to the many restaurants and the commemorative area, hardly a suitable place for outdoor performances!  Once again the typology wording is enhancing the proposal beyond reality.

New Streets

‘The proposed development results in the creation of 2 no. new streets

The Planner does not mention that the proposed ‘new streets’ replace 2 no. streets that are being removed as part of the application and the planner does not address the impact of the removal of these streets from the area.  The planner is wording his report, clearly in support of the development.

Works to Protected Structures

Under the description of the works to the protected structures and National Monument consisting of 14 to 17 Moore Street the planner makes no reference to the rear of the streetscape buildings along Moore Street.  He does not refer to the demolition of the façade along Moore Lane.

The planner makes no reference to the opening up of the gables of No. 14 and 17 for connection with the proposed extension to 17 and the adjoining proposed development to 14, despite the recommendations of the Development Plan that spatial areas be retained as far as possible.

Site Works

All other building, other than the protected structures and facades and national monuments noted above are to be demolished

The Planner has yet again failed to notice the buildings to the rear of 14 to 17 Moore Street that are indeed protected structures, form part of a National Monument are indeed proposed for demolition. 

Conservation department

The planner lists the concerns of the Conservation department including: ‘The height and ephemera quality of the proposed 13 storey building adjacent to the most significant battleground and focal point of the 1916 Rising – the iconic GPO- will have an impact on the setting and visual amenity of a number of protected structures and an ACA 

4.2.3.                     Para 1.4 Objection and Observations

Objections were received from 14 persons.  The summary of the objections are given very briefly but any support for the development is emphasised and indeed repeated in the Planners report. 

4.2.4.                     Para 2.0 Policy Framework

The IAP identifies the following urban design issues:

·       The need to maintain the existing scale on O’ Connell Street

·       The need to maintain small units on Moore Street that link with the market use

·       The need to create permeability from O Connell Street to Moore Street.

The planners report does not address how these issues are dealt with in the application as the existing scale of O Connell Street is clearly not maintained, small units directly on Moore Street are all listed as proposed restaurants (excluding the anchor tenant and the commemorative centre) and will not provide for variety links with the market uses and the route from O Connell Street to Moore Street could have been easily accommodated as an extension to O Rahilly Parade to O Connell Street.  

Architectural Conservation Area (ACA) for the O’ Connell Street Area

The planner refers to ‘protecting the existing strong local sense of place while accommodating the changing needs and image of the area.  Significantly the ACA documentation notes that the designation is not intended to prevent development’ 

The Planner is again finding portions of the plans to express support for the development and he does not address the items of the Policy of DCC as follows:

All new buildings should compliment and enhance the character and setting of conservation areas..  And ..the impact of development on the immediate streetscape in terms of compatibility of design, scale, height, plot width, roof treatment, materials, landscaping, mix and intensity of use proposed 

The ACA description by the planner is even incorrect in that it does not extend to the west to Moore Street, it extends West to Moore Lane, this is significant as this is the Lane the development deletes from our streetscape. 

Urban Design Brief for the Carlton Site

It is considered that a strong case could be made for an urban marker or landmark structure that punctuates the skyline.  Any such building would have to set well back from the O Connell Street view corridor but would express itself primarily from the Henry Street/Moore Street view corridors with glimpses above the existing parapet Heights

The Planner does not address whether or not he feels that in excess of 30m above the parapets of Moore Street is what one would interpret as a ‘glimpse’ 

4.2.5Para 3.2

Density of development

The density calculated by the Planner in his report is 5.13 according to the submitted schedule of floor area.  The planner should have stated that this is grossly over the limit of 2.5 to 3.0 as stated in the development plan but instead the planner states ‘in the interest of clarity…the applicant be requested to clarify the proposed plot ratio

The Planner goes on to say that the indicative plot ration for lands zoned Z5 is 3.5, this is not correct, Paragraph 15.4 of DCC Development Plan states it is 2.5-3.0.

The planner then goes on to say ‘The Planning Authority is of the opinion that the plot ratio proposed under the current development does not constitute an excessive level of density’

This is contrary to DCC Development Plan guidelines.

 Policy Context

‘The need to stitch into the urban grain’

The planner has interpreted this as the development of a new Urban Grain in a newly generated area rather than reading the policy as it is, to stitch into the EXISTING urban grain 

The need to create positive Urban Spaces

Positive Urban spaces will not be achieved in an area in which the historical streets are removed, the ‘significant’ Facades of Moore Lane are destroyed, the National Monument is changed forever and the protected structures are overshadowed and domineered by a further 29m above their parapet height!

 4.2.6.       Para 3.4- Amenity Value of Apartments

No reference has been made to the viability of the roof gardens given their altitude and the inclement weather conditions will not be usable for probably 90% of the time in the Irish climate.  No similar roof gardens or Urban public spaces were referred to in the submission.

4.2.7.                     The Iconic Building

The Planner describes the revised submission for the iconic building and the access to same from the rear of the Moore Street National Monument – as stated numerous times, this is grossly incorrect as the steps are actually proposed to be constructed on the National Monument, not to the ‘rear’ of it.  His comments are as follows ‘This approach not only improves public accessibility and legibility through out the entire scheme it also critically gives a new dimension to the National Monument, which is now at the outset of a journey to the roof terraces that will breathe new life into the physical and historic relationship between the National Monument and the GPO.  With 2016 some eight years away, there is an exciting opportunity here to reintroduce a fresh dialogue between the past and the future, between the GPO and Moore Street’

The Planner has not addressed what should be told to the visitors to the commemorative centre who want to retrace the steps of the great men of 1916 from the GPO to Moore Lane, into the rear gardens of Moore Street and into No. 16 Moore Street.  How can we explain that we permitted a new sky garden ‘iconic building’ on foot of the rear gardens of the National Monument and we permitted the entire removal of the rear gardens in which the Rebels waited to attack before being recalled by Pearse prior to his surrender, and what do we say of the removal of the very streets on which rebels died for the cause of Ireland’s freedom, I do not think our visitors will appreciate the link between the past and the present in this scenario.  The Planner seem oblivious to the important link between the GPO and Moore Street historically, this is Moore Lane.

The Planning Authority concurs that the revised design gives greater coherence to the National Monument and the historic significance of the area in an appropriate manner

Who is the Planning Authority concurring with? It is hardly the large number of objectors that once again voiced their objection on seeing the revised plans for the development.  It is not considered that a building of 39m in height beside a building with a 10m parapet is coherent or appropriate in any manner.

 Once again the Planner refers to ‘A 1916 commemorative centre in No. 16 Moore Street incorporated with the restoration of the National Monument at 14 – 17 Moore Street.’ 

When referring to No. 13 and 14 Moore Street the Planner states ‘No’s 13 and 14 Moore Street are to accommodate café / restaurant uses at all levels, and will act as two separate units on ground floor / basement level and first / second floor level.  The lower unit will be accessed directly off Moore Street via No. 13 and the upper unit will be accessed both from Moore Street and a second floor terrace off the dramatic flight of stairs…The integration of No’s 13 and 14 with each other and the public route ….allows for the national monument buildings to form an integral part of the new development, both in terms of architecture / place making and functionally’

The revised plans by Dublin Central Architects show a large ope at first floor level and the plan by Shaffrey Associates Architects shows an ope of 1200mm in the gable at first floor level.  The building fabric of No. 14 will be destroyed by removing such large opes as are shown at the ground floor level and the spatial layout of No. 14 will be destroyed.  The structural stability of the building will no doubt be compromised by these large opes proposed and they should not be permitted, yet alone commended by the Planner.  Extract report Dated October 2008 ‘The proposed uses have been considered in relation to their compatibility with the existing structures, in particular their spatial layout’. 

Omissions from Public Notices

There are omissions from the public notice that should have deemed the original planning application invalid.  The omissions are as follows:

(1)                      The proposal includes the removal of circa 120m of Moore Lane and circa 73m of Henry Place but the removal of these streets and the change of use of the land is not mentioned in the public notices.

(2)                      The existing façade and building remains at the rear of the yard of No. 15 and 16 Moore Street, part of the National Monument, are being demolished and this is not mentioned in the public notices.

(3)                      There is no description regarding the excavation on the National Monument for the new development behind the existing buildings fronting onto Moore Street

(4)                      The actual description of works to the National Monument are grossly misleading by the above omissions.


Conservation Principles - Published by the Department of the Environment, Heritage and Local Government list the Main Conservation principles as follows:

·       Research prior to planning work

·       Minimum intervention – repair rather than replace

·       Respect the setting

·       Maintenance of visual setting

 It is clearly demonstrated throughout this submission the following:

(1)                      The drawings prepared for the proposed works to No’s 14 to 17 Moore Street have a large number of discrepancies and inaccuracies, all of which are important details that should have been clarified prior to the planning process.

(2)                      The proposed development does not demonstrate ‘minimum intervention’ in any shape or form.

(3)                      The visual setting, to the front and the rear of the National Monument will be destroyed if this development proceeds and the iconic existing setting and streetscapes will be lost, this does not demonstrate respect for or maintenance of the setting or visual setting. 

The proposed development provides the potential irreversible impact on the National Monument, on the architecture of Moore Street and O Connell Street and will result in the complete removal of part of Dublin’s historical Streetscape with the loss of parts of Moore Lane and Henry Place, I trust that you will consider these items when making your decision in this case.

 Signed : ____________________ 

        Michael Conmy, MBEng, MRIAI, RIBA, Chartered Architect


 Representatives of NGA at Oral hearing

1.               Loretta Clarke, NGA

2.               Sean Whelan, NGA

3.               Michael Conmy, NGA and Plan Design Associates

4.               Orlagh Cawley, NGA and Plan Design Associates

 The main basis for the objection by NGA to the development is that the proposed development involves partial demolition and major alterations to no. 14 to 17 Moore Street and also involves construction of part of the development on The National Monument (to the rear of 14 to 17 Moore Street).

 The report was prepared by Orlagh Cawley and Michael Conmy of Plan Design Associates and the evidence was presented to the hearing by Orlagh Cawley, following introduction by Loretta Clarke.

 Cross questioning of the applicants representatives was carried out by Orlagh Cawley.

 The hearing concluded on the 24th April and a decision will now be determined by An Bord Pleanála.

 Contact Details

Plan Design Associates

Unit 3 Killala Road Business Park

Killala Road


Co. Mayo

 Ph (096) 72058 and Fax (096) 75905

The following transcript is taken from contemporaneous minutes.  A verbatim transcript will be available from An Bord Planala after a decision has been reached.

 Sean Whelan: ‘Madam Inspector, my name is Sean Whelan.  I am Chairperson of the National Graves Association (NGA).  To my right is Loretta Clarke who is our representative for Connaughtand to her right are Michael Conmy and Orlagh Cawley.  Michael is an architect and engineer and Orlagh is an urban planner.  Together they will present the detail of our objections to the planning matter under consideration here today. 

By way of introduction, the NGA is some 140 years old having been founded originally as Young Irelander’s Graves and Monuments Committee.

 Aside from numerous patriot graves, we have in excess of 500 historical monuments in our care.  WE have a long history of seeking to protect historical monuments. 

The inclusion of the National Monument on Moore Street, as part of the plans under consideration here today, is of extreme concern to our organisation both because of the importance of this monument in it’s own right, and, because of the implications for any National Monument in relation to planning issues.

 We are not against development in this city.  We are against the infringement upon and desecration of any historical or cultural monument.

 Loretta Clarke will continue this presentation’.

 Loretta Clarke:   ‘I see here in front of me a bunch of people in suits with no name tags.  People representing the developer.  Nothing but a bunch of hooligans and vandals.  This is the same developer named in a Sunday Newspaper as being one of the Anglo Irish Golden Circle.  Men who looted the Irish people in your own greed.  You have brought this country to it’s knees.  Now you want to desecrate the Moore Street National Monument.  The final headquarters of the men of 1916 who sacrificed their lives for this country and its people.  Shame on you all.’

 Madam Inspector:‘We’re not here to insult people.’

 Loretta Clarke:‘Sorry I know I’m being passionate, but that’s the person I am.  I’m a lifelong Republican Socialist.  When I was just a 17 year old student, I brought 7,000 people out on the streets in protest.  Now I’m in the departure lounge of life.  This is my last battle and I’ll certainly give it my best.  Moore Street is Ireland’s Alamo.  People like these also sought to demolish Kilmainham Jail in the name of progress.  It’s now one of the most important buildings in the state attracting nearly 200,000 visitors per year. 

 These people here make me mad.  They are a disgrace and they should be ashamed of themselves.’ 

Sean Whelan:‘Madam Inspector, in relation to our presentation here today we note that any proposal to demolish part of, or build on part of, or seriously alter any part of any National Monument is contrary to the National Monuments Acts.

 Our objections all fall within two points.  Firstly, there is the matter of the damage to this particular monument.  Secondly, should such damage be permitted to this monument, then, clearly no National Monument in this state is safe.

 (We note that any proposal to demolish part of, or build on part of, or seriously alter part of any National Monument is Contrary to The National Monuments Acts.

 We object on the following grounds:

A1)  The rear section of the National Monument includes existing buildings clearly within the designated area.  This section of the National Monument is to be totally demolished as it is included in the revised plans as part of a completely new structure.

 The solar reflector structures in the revised plans are almost entirely within the National Monument area.

 A2)  The revised plan includes major extensions to the rears of numbers 14, 15, 16 and 17 on all levels.  This is clearly a major alteration to all four buildings and we believe should be unacceptable. 

A3)  The above plans envisage lowering the entire basement area in all four building no’s 14, 15, 16 and 17.  Again this is clearly a major alternation and also unacceptable

 A4)  The above plans include the provision of a ‘new stairs’ in no. 17.  While any repairs that may be necessary to maintain the existing structures are acceptable, the provision of new structures such as this stairs is not. 

A5)  The revised plan seeks ‘to include demolition of non-original additions and partitions’ in all four buildings 14, 15, 16 and 17.  We object to this part of the proposal for two reasons (i) There are certainly some additions and partitions that were in situ at the time of the 1916 Rebellion that were not constructed at the time of the original building construction and could therefore be deemed ‘non-original’.  Since these four buildings are part of the National Monument because of the events of 1916, the internal structure should reflect as far as is now possible, how it was in 1916. (ii)  Given the age of the building, what criteria could be used to decide what is or is not an original partition and who would make the decision.) 

We further note that the legislators who created the National Monument’s Acts in the 1930’s allowed for some interference in ‘exceptional circumstances’.  We have no doubt that this was to facilitate maintenance and restoration only.

 We would like to bring the Board’s attention to Kilmainham Jail, already mentioned by Loretta.

 Kilmainham Jail fell into severe disrepair and was due to be demolished in the 1950’s.

 As early as the 1930’s the NGA became involved with others and after a long public awareness campaign the buildings were eventually saved.  Despite, the poor state of the buildings at the time, they were extensively restored, initially by the Kilmainham Restoration Committee, and later by the office of public works.

 Today, it is the second most visited museum in the state and one of the most significant Historical Monuments in the country.  It is a major tourist attraction.

 On a separate point, in relation to planning proposals infringing on National Monuments, I bring your attention back to Loretta’s point about Moore Street being Ireland’s Alamo.  On a visit to the United States, I visited the Alamo which is a National Monument in that country.  While there are significant differences between the two, there are three things that spring to mind:

 1)  The city of San Antonio, where The Alamo is located is roughly the same population as Dublin.

 2)  The Alamo is located in the City Centre.

 3)  It is totally untouched by development and the surrounding buildings are back far enough not to infringe in any way on the structure itself.

 Clearly, no developer would waste time and money on any planning application that would infringe upon it.

 It is our understanding that this is how National Monuments are treated in virtually every western democracy.  We would respectfully suggest that An Bord Planala use this opportunity here now to put out a message that this is how the National Monument on Moore Street will be treated and by extension all National Monument’s in this state will be so respected.

 I pass back to Loretta Clarke.’

 Loretta Clarke:‘The NGA stands alone.  WE are an autonomous body.  Nobody on our board can be a member of any political party.  We owe allegiance only to those who died for Irish Freedom.

 There are two deaths:  The death of the body and the death of the spirit.  While the NGA exists, no Irish Patriot will die twice.  We remember the blood of The O’Rahelligh on the wall of Moore Lane.  Here a British soldier shot The O’Rahelligh.  With his own blood he wrote on the wall of Moore Lane ‘RIP, here died The O’Rahelligh.’  Here on Moore Lane, as he lay dying, he also wrote a final note to his wife.  He will not die twice.’

 Sean Whelan:‘Orlaigh Cawly will now present the detail of our objections.