Urban renewal

We write to ask you to examine the procedure used to assess the proposed redevelopment of Ballymun in north Dublin by Dublin Corporation in view of the fact that no Environmental Impact Assessment has been prepared for this development.
Initial Friends letter to Commission


J. Ruiz-Tomas,
Environmental Directorate XI
Legal Affairs Division B.3
Rue de la Loi, 200
B-1049, Brussels, Belgium

25 April, 1999

Re:
Infringement of Environmental Impact Assessment Directive 85/337 in urban development in Ireland

Dear Sirs;

We write to ask you to examine the procedure used to assess the proposed redevelopment of Ballymun in north Dublin by Dublin Corporation in view of the fact that no Environmental Impact Assessment has been prepared for this development.

This development is part of the newly introduced integrated area plans (IAPs) for six areas within the Dublin Corporation authority's jurisdiction - Ballymun, Inchicore/Kilmainham, O'Connell Street, the north-east inner city, Liberties/Coombe, and the HARP (Historic Area Rejuvenation Project) area extending westwards from O'Connell Street to Collins Barracks) and that tax concessions are being provided for these developments.

The Ballymun development currently houses 20,000 people in high rise buildings constructed in the 1960's. It the stated intention to demolish these buildings and rehouse the residents. A Master Plan was drawn up and subject to an "environmental appraisal", the Irish authorities stating that this was sufficient examination.

The first phase of this redevelopment is comprised of 11 sites represented by 11 separate planning applications to the local authority. [Dublin Corporation Planning Register No: 3661 - 3665 of 98; 3726-3730 of 98; 2704 of 98; and others.] In total these applications comprise 750 housing units covering approximately 48 acres and with an estimated cost of IR£ 275 million.

We believe that the proposed development is of a scale and nature to require an Environmental Impact Assessment, notwithstanding the fact that each individual application may be beneath the threshold requiring such an assessment.

We would be most grateful if the European Commission would examine the facts of this case and determine if the local authority's recent notice of intention to grant permission for these applications without an environmental impact assessment is an infringement of the European Environmental Impact Assessment Directive 85/337.

-------------

A number of further submissions and replies were made whiuch we hope to post here shortly.




Complaint in relation to non-implementation of the EIA Directive 85/337 in relation to urban developments in Ireland.

FRIENDS OF THE IRISH ENVIRONMENT


8 February 1999


Mr. G. Kremlis,

DG XI,

European Commission,

Molesworth St.,

Dublin 2





Dear Mr. Kremlis,

We wish to draw your attention to a serious flaw in Irish implementation of the EIA directive.

The planning system in Ireland operates by the drawing up of a Development Plan for the local authority area. This plan makes the fundamental decisions in relation to development in an area. All planning applications received by a local authority are then considered in the context of this plan.

The zoning for development of land in a Development Plan (or in what is termed a Variation of the Plan) creates a legal entitlement on the part of the landowner to obtain planning permission for development of a type or types permitted in the relevant zoning. In effect, therefore, the decision whether or not to permit a particular development (e.g a large urban development on greenfield land) is made not at the planning permission stage but at the Development Plan stage.

Ireland has implemented Directive 85/337 by requiring that certain applications for planning permission will be accompanied by an Environmental Impact Statement and that a form of E.I.A. is carried out by the planning authority who receive the application (although it is clear that in many cases this does not happen due to, inter alia, a lack of relevant expertise on the part of the planning authority).

Article 2 of the Directive which requires that

"Member States shall adopt all measures necessary to ensure that, before consent is given, projects likely to have significant effects on the environment ... are made subject to an assessment with regard to their effects."

Article 1 of the Directive specifies that

"'development consent' means the decision of the compent authority or authorities which entitles the developer to proceed with the project."

It is clear from the situation as set out above that Article 2 of the Directive is not being complied with in the case of many developments in Ireland. Many developments are approved without EIA at Development Plan stage and then required to go through a formal EIA process when a legal entitlement to consent has already accrued to the landowner. (In the case of others, the development is carried out piecemeal by means of multiple planning applications and no EIA is ever carried out.)

We would draw your attention in particular to the case of Santry Demesne, an old demesne containing parkland and woods of considerable ecological value and enormous amenity value and potential which is the last green space between the densely populated areas of Santry and Ballymun, which latter district includes areas of serious social deprivation, and the motorway to the north of Dublin. It lies at the Southern edge of the Fingal County Council area, while most of the residents of Santry and Ballymun are within the Dublin Corporation area.

Fingal County Council resolved in May 1998 to rezone most of the Demesne, in particular the western part near Ballymun for industrial and residential use. This decision was made as a stand-alone amendment to the existing Development Plan, at the request of a development consortium who had acquired interests in the land.

An alternative procedure available to the developer would have been to have submitted a planning application and requested the approval by the Council of a "Material Contravention" of the Plan. However, that approach would, because of the way the EIA Directive has been implemented, required the Council to carry out an EIA on the proposal before the developer received a legal entitlement to develop the land.

No EIA was carried out on the proposal before the decision was made (although one is now being carried out as part of the planning permission process). Indeed the decision was made with no analysis whatsoever of the impact on the neighbouring areas of Santry and Ballymun and the effect on the human environment for the communities of those areas. This failure or indeed refusal to consider them went as far as the maps which were considered by the Council which showed the areas to the south of the Demesne as blank space - because they were in another local authority area. The official documentation supplied as advice to councillors will substantiate this, and the then Cathaoirleach of the council advised the councillors that the areas of Santry and Ballymun in the Corporation jurisdiction were irrelevant to the decision. We raised these (and other) issues with the Council before it rezoned the land.

For your information, and so that you are aware of the complexity and importance of the issues raised, we attach a copy of the bound volume of public comments made in relation to the rezoning, containing our letter as objection 579.

We also enclose a copy of the 5-page report supplied to the councillors at the meeting where they decided to make the rezoning. It makes clear that in the absence of a formal requirement for EIA there is effectively no meaningful consideration of the environmental impact of the development before the decision is made.

We should point out that there has now been a planning application, including an EIS. However, we have no faith in this process, as under Irish law the Council is effectively now obliged to grant permission.

We would appreciate it if you could treat this complaint as a matter of great urgency. It is of real and serious importance for the sustainable development of Dublin and its hinterland. Further rezoning proposals by Fingal County Council are going through formal public consultation at the moment. Major rezoning proposals amounting to thousands of hectares in total are included in this new draft Development Plan. No EIA has been carried out and the Council is likely to be making decisions on this draft Plan in March or April 1999.

The protection given the environment by the EIA Directive is only a procedural protection. In that context it is vital that proper environmental impact analysis is made of these major decisions and proposal in relation to the urban form of Dublin, and of similar proposals in other areas. Under the current Irish legislative provisions, EIA after the zoning decisions have been made in the case of new urban developments is effectively meaningless.
The Plasticisation of Limerick

Friend's submission to the Limerick City Development Plan Review:

Limerick, mock Georgian PVC window capital of Ireland
"In recognition of the special quality of the brick and timber sash windows which defines the character of the major part of the city's historic building stock..."


Mr. Maurice Moloney, City Manager, 8th.June 1998

Limerick Corporation

Civic Offices , Limerick.


RE; SUBMISSION ON 1998 LIMERICK CITY DRAFT DEVELOPMENT PLAN REVIEW.


For decades the lack of planning control on Limerick's noble streets and

terraces has been a source of frustration and bewilderment to those

concerned about Ireland's cultural heritage and environment. The current

Limerick Corporation Review of the City Development Plan presents the

opportunity to address the matter.


With is impresive Shannonside setting, medieval heart of Cathedral and

Castle, great Newtown Pery layout of steets and Crescent, and new Hunt

Museum Limerick should be poised to take its place in the premier league of

European historic cities of its size. However the Limerick Corporation

Development Plan provisions providing for the maintenance of the city's

architectural heritage have not increased in content or effectiveness over

the last three decades. Limerick's failure of planning enforcement of

Development Plan Listed Building objectives to ensure that detrimental

Material Alterations are subject to Planning Permission, is unequalled not

just in Ireland, but probably in any European historic city. The level of

unauthorised aluminium and uPVC replacement all over its listed Classical

terraces gives Limerick the dubious distinction of being open to

international ridicule as the Mock Georgian Plastic Capital.


The 1998 Limerick City Draft Development Plan shows that Limerick

Corporation is not remotely confronting its responsibilities. Despite the

high quality work that has been achieved in projects such as the Milk

Market, the Hunt Museum, the conversion of the Presbyterian Church, and by

Limerick Civic Trust in different locations, the quality of the overall

historic fabric is spiralling downhill. Uncontrolled gritblasting and

cement pointing is ravaging the city's older brickwork and uPVC windows

dominate most streets.


This situation cannot continue.


Limerick is now seeking to promote itself as a Heritage Tourism

destination, for which huge EU funding has been granted for the

overwhelmingly worthy Hunt Museum project and the very dubious Castle Lane

one. The city cannot continue to market itself in this way and draw down

EU funds, while the quality of its real architectural inheritance is

progressively diminished.


Since 1997 Ireland has ratified the CONVENTION FOR THE PROTECTION OF THE

ARCHITECTURAL HERITAGE OF EUROPE, ( the Granada Convention 1985). This

imposes a European Treaty obligation on Ireland to maintain its distinctive

part of Europe's architectural heritage. Limerick Corporation as Planning

Authority for what is a significant European historic city is obliged in

conjunction with central government to implement a co-ordinated series of

measures in accordance with the Treaty Articles.


The most im- Mediate priority is to ensure that the current Development Plan

review process achieves a comprehensive Listing and planning control

framework for the preservation and enhancement of the city's historic

building stock. Its most im- Mediate objective must be to halt the tide of

plastic window infestation and initiate its appropriately designed reversal. As the same

time the commercial core of the city must be strengthened against the

threat of peripheral development, while reducing the level of dependency on

the motor car as primary means of mobility.






THE PLASTICISATION OF LIMERICK

FROM

WESTERNMOST RENAISSANCE CITY IN EUROPE

TO

PLASTIC MOCK GEORGIAN CAPITAL


HERITAGE TOURISM INVESTMENT - SHAM AND REALITY


Limerick has received what is in terms of international significance,

quality of design and huge good value for the EU grant involved, the most

impressive single heritage investment in Ireland; the Hunt Museum. At the

same time it has also received what is probably the single most dubious

"heritage" development in the entire country, the £3.8 million EU and

Shannon Development Castle Lane beside King Johns Castle (above right).

This includes the "reconstruction" of a 19th. century warehouse of the very

type still being demolished in the Milk Market area. It is a Disneyesque

piece of historical conceit basically designed as a large tour bus stop

pub,while the real heritage of the city suffers progressively accelerating

mutilation.








HONKEY TONKEY LIMERICK


As the city and economy grows the dependency on motor car mobility grows

even more dis-proportionally, due to the failure to invest in public

transport and promote cycling. The approach roads around the city are

becoming more like a mid west American city (above centre) . The design

reference for places of social resort are becoming more American (below

left and centre). When the "traditional" style is adopted in pub

refurbishment the result is over blown parody, such as "The Newtown Pery".

This adopts a bogus establishment date of 1806, but in its lumpy teak

street frontage, illiterately used Classical detailing plonked onto the

first floor windows, and kitsch clock, lamp and uPVC windows represents the

total anthesis of the simple design elegance of the early 19th. century.

The appearance of the city's terraces large and small is now dominated by

uPVC or coated aluminium windows,(above right and centre right), poorly

performing and inappropriate materials for the Irish climate as the

deteriorating new Tourist Office shows (below right).


THE NEW CIVIC ARCHITECTURE - AMBITION AND REALITY


Limerick more that any any other Irish city has commendably sought to design

new public buildings in a bold confidently contemporary idiom. The Louvre

pyramid in Paris shows how innovative contemporary design and materials can

compliment and add to the impact of historic buildings. Unfortunately the

new Civic buildings in Limerick have been let down by poor quality

materials and detailing. The Civic Offices (above) are ageing

disappointingly. The rusting gate and girders of the Kings John's Castle

Visitors Centre makes it look like and abandoned factory planthouse.


THE REAL TREATMENT OF LIMERICKS REAL HERITAGE


The real importance of Limerick is the extent and quality of its 18th. and

19th. planned streets and buildings. All over the major terraces original

sash windows with their delicate glazing bars and hand made glass have been

needlessly swept away and replaced by plastic flip out frames of various

incongruous designs. Catherine St.(below left and centre), Villiers

Almshouses (below right). Despite the European status of Limerick as a

major brick Classical city no concern or attention has been directed into

enforcing proper maintenance standards. However while hideous window

replacement can be reversed in the future, the abuse of brickwork through

ill advised grit blasting in the name of cleaning cannot be. This leaves

the surface pitted and its performance lifetime drastically reduced.

Blasted and pitted brickwork in Catherine St. with absurd new add on cement

detailing (above left). Brick facade in O"Connell St. being attacked by an

industrial shot blasting company in the course of a Sunday morning (above

right).


THE LEGACY OF THE 1960'S AND 1970S


Limerick suffered as badly as Cork or Dublin

from poor quality and out of scale buildings

in the 1960s and 1970s.AIB and Royal George

Hotel O'Connell St. (above) and various State

and Semi State offices in the Henry St. area

such as Telecom (below). Many of these

facades have poor quality facing materials

and window systems which will require

total replacement in the im- Mediate future. In

contrast the city still abounds with 150 to 200

year old buildings with brick facades and

timber doors and windows capable of

performing satisfactorily for generations more.


QUALITY OF RECENT COMMERCIAL ARCHITECTURE


Of all Irish cities Limerick has been the most successful in achieving an

overall coherence of quality and scale in the the extensive development

generated by the Urban Renewal Tax incentives from the late 1980s and

throughout the 1990s. A mixture of new buildings have satisfactorily

re-established streetscapes in Henry St. (above right), and Charlotte Quay

(above centre) though the effect of the slate clad plantrooms is

unfortunate. Cruises St. though bringing about the undesirable demolition

of the old Cruises Hotel, has been designed as an open shopping precinct

satisfactorily fitting into the grain of the city (centre and bottom

right). The conversion of the former Presbyterian Church in Henry St. to

offices (below centre) is a model of sensitively designed and creative

reuse.


CRUDE DESIGN QUALITY OF uPVC WINDOWS


uPVC and aluminium coated uPVC is incapable of replicating the subtle

design quality of Limerick's traditional sashes. It cannot be moulded or

modelled satisfactorily to suit arched window opes as Sullivan Insurances,

4 Hartstonge St. graphically illustrates (above left). A major fault

common to almost all uPVC windows is that the opening section is set within

the main frame, so that the mock pane divisions of the fixed and opening

sections are of different sizes and do not line up, O'Connell St. (above

centre and right). A unique uniform terrace in Hartstonge St. Lwr, exhibits

some of the ugliest window replacement in Ireland (below left). Only No.

8 (centre house below centre) retains its original camber headed Wyatt

windows on the upper floors. The flats converted Nos 9 and 10 and the

corner building forming 29 Henry St., occupied by Colin Marsden Chartered

Accountant, are treated with grotesque flat headed uPVC parodies, even

worse when swung out in an open position. However the hinged windows of No.

7 shows that wrongly designed timber replacement is as bad as anything in

uPVC.


PILLARS OF SOCIETY SETTING THE WORST CIVIC EXAMPLE.


Apart from representing an act of Civic vandalism all of the inappropriate

uPVC windows in the Crescent area are ILLEGAL Material Alterations to

Listed Buildings, which if subject to appeal to An Bord Pleanala would not

be given planning permission. In the 1991 and previous Limerick City

Development plans the Crescent is designated for preservation under List

"A"and the surrounding streets are designated list "B" which requires that

"any proposal to alter or demolish shall be the subject of an application

for permission to the Corporation" While the Corporation's failure to

prosecute

its Statutory responsibility is indefensible, so to is the behaviour of

some of the most prominent property owners in the city.


THE LEADING OFFENDERS WHO SHOULD KNOW BETTER


Limerick Leader Ltd. Newspaper, 54 O'Connell St (above left)

The Jesuit Order, north side the Crescent (above centre)

Belltable Arts Centre/ Arch Confraternity, 69 O'Connell St

(above right).

The Medical Profession,e.g. Dr. Morgan Costelloe's surgery

13 Barrington St. (below left).

St. Vincent de Paul Hartstonge St. (below left centre).

The Estate Agents eg; Frontline 28 Mallow St , and

G.V.M. 26 Cecil St (below right centre and right).

The Legal Profession. e.g. Lucy Collins Solr. 55 O'Connell St.


THE QUALITY OF LIMERICK CRAFTSMANSHIP AND DETAILING


Limerick adapted the form of the Classical terrace to create a distinctive idiom

of proportion detailing and craftsmanship. The terraces of the late 18th.

and early 19th. century are distinguished by a superb soft textured brick.

There is a hierarchy of door designs ranging from tri-partite in the

grander houses in O'Connell St (above left and right centre) and the

Crescent, where doors are flanked by three quarter columns with pilasters

framing the embellished glazing of the sidelights. Off O'Connell St the

more important terraces such as Mallow St (below left) have full columned

doorcases, while more modest examples such as in Catherine St. have half

columns (below left). The quality and survival rate of embellished

fanlights in the city is outstanding. Original windows indicate an

accomplished school of joinery in Limerick. Sashes are executed to a

carefully considered Classical proportion in the size and number of panes.

Despite rampant plastic replacement there are still hundreds of sashes of

150 to 200 years in age around the City capable with good maintenance of

being given indefinite life. These retain most of their original hand made

crinkled crown or sheet glass (above right) which give the facades an

irreplaceable patina and texture in diffusing and reflecting light, sun and

shadow. All to often old sashes are unfairly written of as jammed, shabby

or even rotten when the problem is only one of over accumulation of paint,

needing to be stripped back.


THE WESTERNMOST RENAISSANCE CITY IN EUROPE


The layout of what was first called Newtown Pery outside the Medieval Walls

in the 1760s, was distinguished by a bold Classical grid plan, recalling

that of Edinburgh but equally the cities of North America with which

Limerick had such close links. The area acquired an impressive sequence of

uniform brick terraces culminating in the uncompleted Pery Square in the

mid 19th. century (above left.) . The greatest achievement was the

combination of the double Crescent and great length of O'Connell St (left)

creating a major axis parallel with the river. Off the west end of this

were streets with well proportioned terraces of the early decades of the

19th. century, notably Mallow St (below) and Barrington St. (above

centre). Newenham St. (above right) contains more modestly scaled houses.


ORIGINAL COMMERCIAL AREAS OF NEWTON PERY


The eastern end of the great New Town layout adjoining the medieval city

was designed with uniform terraces of shopkeepers premises such as Patrick

St (above left) and Ellen St (above right). 4 Patrick St the birthplace of

Catherine Hayes "The Swan of Erin " the most internationally acclaimed

Irish singer of the 19th. century (below left) and 34 Denmark St. (below

right), both of the early 1800s are the best reminders of the former

character of the area.


EXTENSION OF COMMERCIAL AREA INTO RESIDENTIAL


Most of what is known as Georgian Limerick is the legacy of a prosperous

merchant, professional and trading class. The majority would have done

business in their own houses. In locations such as Roches St. stone

warehouse adjoin residential terraces . As the late 19th. century

progressed the area of retail and commercial activity spread westwards

along O'Connell St,(above left) and southwards along William St (below).

Business activity became more prominent in the streets off O'Connell St.

such as Cecil St (above right). However the character of the upper floors

remained largely intact though with the original sashes very often replaced

with larger pane divisions. In some cases facades were plastered and

embellished such as the Chamber of Commerce O'Connell St.


THE PLASTIC WINDOW INVASION


Removal of sashes and replacement with top hung frames begun only in the

1970s initially with tropical hardwood and later aluminium. The window

replacement problem only began to make a serious impact with uPVC coated

aluminium in the 1980s followed by solid uPVC in the 1990s. The phenomenon

is already becoming second generation with plain aluminium hinged windows

installed in the late 1970s or early 1980s being replaced by mock Georgian

uPVC, showing that modern factory window systems have a performance life of

no more than 15 to 20 years. A jarring variety of inappropriate

materials and opening designs now dominates Thomas St. (entire left and

below left), O'Connell St (above left) and the Crescent, Catherine St.,

(above right ) Cecil St., Glentworth St (below left), Mallow St., and all

of the city's other main Classical terraces. The example the treatment of

Adrian Greaney's Solicitors ground floor offices in 8 Catherine Place

illustrates how even the inappropriate alteration of one floor can ruin the

character and quality of an entire building (below right).


FIRE SAFETY PROBLEMS OF ALUMINIUM AND uPVC WINDOWS.


Most prefabricated uPVC or aluminium based replacement window systems in

older buildings are double glazed and top hung. This means that the window

is impossible to climb out through in an emergency ladder rescue evacuation

situation. Because of the air cushioning effect of the double glazed seals

windows are difficult to break without heavy implements either from inside

or outside. The above photograph shows the behaviour of uPVC/Aluminium

frames in a recent fire in 32 Denmark St. Limerick. While new fire

Regulations coming into effect on July 1st.1998 require that bedroom

windows should be openable to facilitate emergency ladder assisted egress,

this is not applicable to the converted flats such as Mallow St. (above

right) and hotels such as in Glentworth St (below right). While the fire

trapped occupant of a uPVC double glazed sealed room would of course die

primarily from loss of oxygen, once sufficient temperatures are reached

uPVC building components such as fascias, windows etc. are subject to

meltdown emitting dioxins posing a risk to firefighters.


I refer to previous correspondence about complaint P99/4449 concerning the failure to undertake an environmental impact assessment (EIA) in respect of the redevelopment of Ballymun Dublin.
EU Directorate IX

12 December 2000

Dear Sir;

I refer to previous correspondence about complaint P99/4449 concerning the failure to undertake an environmental impact assessment (EIA) in respect of the redevelopment of Ballymun Dublin.

I would like to confirm that the Commission has recently notified a Letter of Formal Notice (first warning letter) to Ireland arising out of the failure of Dublin Corporation to ensure the EIA of Phase 1 of the redevelopment.

The Commission notes that the thirteen separate developments making up Phase I were all closely related and that when taken together they exceeded the relevant threshold of the Irish legislation for EIA. Nonetheless the Corporation did not require EIA in respect of the developments.

In its decision of 21 September 1999 in Case C-392/96 Commission v Ireland the European Court of Justice points to the need for Member States to ensure that a requirement of EIA is not circumvented by project splitting.

In the Commission's view Phase 1 of the re-development of Ballymun represents an example of project splitting circumventing the requirement of EIA. As an example it is of particular concern given firstly the close connection between the applicant Ballymun Regeneration Ltd. and the decision-maker Dublin Corporation and secondly the major responsibilities the latter has for urban development.

In notifying this Letter of Formal Notice the Commission is not calling into question the merits of re-development of Ballymun. Substantial investments to improve the quality of life in Ballymun are clearly welcome and have the Community's support via the Structural Funds. However the scale of redevelopment the size of the population concerned and the environmental challenges presented (including potential flooding risks) all point to the need for and wisdom of EIA in respect of key phases.

The Commission acknowledges and welcomes the steps taken by Ireland's Planning Appeals Board to ensure the EIA of those developments appealed to it. However the Board's role cannot be considered as completely off-setting the deficient practice of a local authority decision-maker. In particular there is no guarantee that the Board will be involved by way of an appeal. In this case only three of the thirteen development consent applications forming part of Phase 1 of the Ballymun redevelopment were appealed. The cumulatively high administrative charges that appeals would have entailed are also noteworthy.

The response of the Irish authorities is now awaited. If you have any comments or additional information I would welcome hearing from you.

Yours sincerely

G.KREMLIS

PROPOSED AMENDED VERSION OF CHAPTER 7

OF LIMERICK CITY DEVELOPMENT PLAN

CHAPTER 7

URBAN DESIGN AND CONSERVATION OBJECTIVES


The Corporation through its obligations for the implementation of existing

and proposed legislation to preserve and enhance the National historic

building stock will ensure that all buildings of International, National,

Regional and Local significance in Limerick City are given appropriate

preservation and protection listings.


The Corporation through its European Treaties obligations for the

implementation of Ireland's ratification in 1997 of the CONVENTION FOR THE

PROTECTION OF THE ARCHITECTURAL HERITAGE OF EUROPE

( the Granada Convention), in relation to Limerick City, will work with

all relevant State and Non Government organisations in compliance with the

following Articles .


DEFINITION OF ARCHITECTURAL HERITAGE. ARTICLE 1


The Corporation defines the pre 1900 hundred building stock, in addition to

any specific 20th. century buildings identified to be of architectural

merit, as comprising the architectural heritage of Limerick City.


IDENTIFICATION OF PROPERTIES TO BE PROTECTED. ARTICLE 2


The Corporation undertakes to carry out, complete and publish a full

inventory of the City's pre 1900 building stock to the National Inventory

of Architectural Heritage and European Core Data Index format in conjuntion

with the Department of Arts, Heritage Gaeltacht and the Islands within

three years of the adoption of this Plan.


STATUTORY PROTECTION MEASURES. ARTICLES 3 to 5


The Corporation undertakes to ensure the effective compliance with its

European Treaties and Statutory responsibility to prevent the

disfigurement, dilapidation or demolition of the historic building stock.

In particular it will ensure that the demolition and material alteration of

all buildings and structures Listed "A" and "B" on this plan will be

subject to planning permission control requirements. In the event of

unauthorised material alterations carried out to buildings or structures

legal enforcement will be taken to secure redress.


The Corporation will appoint a Conservation Officer with appropriate

expertise, who will be supported by adequate administrative resources to

ensure that all works to structures listed "A" and "B" in this plan are

subject to adequate preliminary advice monitoring and supervision.


ANCILLARY FISCAL MEASURES. ARTICLE 6


This Corporation will in conjunction with the Department of Arts, Heritage

Gaeltacht and the Islands provide appropriate financial incentives to

secure the proper conservation of the historic building stock.


SETTING AND SURROUNDING OF HISTORIC STREETS AND MONUMENTS ARTICLE 7


The Corporation will ensure that development proposals for sites and

buildings adjoining or forming part of the setting of structures or groups

of buildings in List "A" and "B" of this plan, will be of a design quality

and scale enhancing the listed structures.




PROTECTION AGAINST PHYSICAL DETERIORATION OF ARCHITECTURAL HERITAGE. ARTICLE 8


In recognition of the special quality of the brick and timber sash windows

which define the character of the major part of the city's historic

building stock, the Corporation will promote research and implement

guidelines on the appropriate methods of

* cleaning and pointing of brickwork

* maintaining 18th. and 19th. century window sashes and glass


LEGAL SANCTIONS. ARTICLE 9


The Corporation will ensure that effective enforcement action is taken

against all cases of demolition or material alteration of buildings on List

"A" or "B". In the cass of unauthorised works been carried out to a

building e.g. timber sashes being replaced by swing out uPVC frames, action

will be effected in all cases to ensure restoration of the building to the

original design.


CONSERVATION POLICIES. ARTICLE 10


The Corporation delares its adoption of an integrated conservation policy to:


(i) ensure the protection of the architectural heritage as an essential

planning objective in assessing all planning applications

(ii) promote programmes for the restoration and maintenance of the

architectural heritage

(iii) make the conservation, promotion and enhancement of the of the

architectural heritage a major feature of cultural, environmental and

planning policies.

(iv) seek the maintenance and proper use of the older building stock in

general, in addtion to buildings specifically listed for preservation or

protection.

(v) foster, as being essential to the future of the architectural

heritage, the application and development of traditional skills and

materials.


APPROPRIATE NEW USES FOR OLD BUILDINGS ARTICLE 11.


The Corporation will seek the maintenance of the city's historic building

stock, while at the same time ensure its adaptation to the needs of

contemporary life. In cases where buildings become redundant, appropriate

new uses will be sought to secure their continued economic life.


ACCOMMODATION OF PUBLIC ACCESS . ARTICLE 12


While recognising the value of permitting public access to protected

properties, the Corporation will seek to ensure that the develoment of

tourist and visitor facilities does not injure the fabric, integrity,

character and setting of protected buildings


ADVANCEMENT OF OBJECTIVES THROUGH CO-OPERATION WITH OTHER BODIES. ARTICLES

13 and 14


The Corporation will work to achieve effective co-operation at all levels

with all relevant State, Regional and non Government Bodies, in

conservation, cultural, environmental and planning activities.


The Corporation recognises the contribution of An Taisce as a prescribed

body under the Planning Acts and of the Irish Georgian Society and Limerick

Civic Trust in furthering these objectives.


INFORMATION AND TRAINING. ARTICLES 15 and 16


The Corporation will develop public awareness of the value of conserving

the architectural heritage, both as an element of cultural identity and as

a source of inspiration and creativity for present and future generations.



The Corporation will support and promote training in the craft trades

necessary for the proper maintenance of the city's historic building stock

and in particular:

(i). Stone masonry and pointing.

(ii). Brick maintenance and pointing.

(iii) Sash window maintenance and repair and manufacture

(iv) Joinery maintenance and repair

(v) Ironwork and in particular railing maintenance and repair

(vi) External and internal lime plastering.

(v) Decorative plasterwork maintenance, cleaning and repair.


EUROPEAN CO-ORDINATION. ARTICLES 17 TO 21


The Corporation will enter into exchange programmes with other Eurpoean

cities for information benefit and to assist in the implementation of

appropriate policy structures to ensure compliance with European Treaties

obligations.


SPECIFIC PRESERVATION OBJECTIVES LIST A


The Corporation indicates the following development objectives for the

preservation of buildings of artistic, architectural or historic interest


LIST "A"


The Corporation declares the preservation of the following buildings and

structures as necessary to the core identity of the City. The demolition of

any buildings and structures on List "A" will be a Material Contravention

of the Development Plan. The preservation designation and planning control

objective contained in List "A" is deemed to include the interiors of all

buildings, unless the listing designation is specifically applied to the

facade or exterior only.


All external and internal material alteration to List A buildings and

structures will require Planning Permission. It is the specific objective

of the Corporation to protect all List "A" buildings from inappropriately

designed window replacement or other material alterations, and to take

enforcement action against such alterations where carried out without

permission.



KING JOHNS CASTLE

WALL OF EXCHANGE NICHOLAS STREET

ST. MARYS CATHEDRAL

BOURKES CASTLE ATHLUNKARD STREET

FANNINGS CASTLE OFF MARY STREET

REMAINS OF OLD CHURCH OFF NORTH CIRCULAR ROAD

VILLLIERS HOUSES CHURCH STREET, ST MARYS

THE COUNTY COURTHOUSE MERCHANTS QUAY

THE HUNT MUSEUM (FORMER CUSTOM HOUSE) RUTLAND STREET

REMAINS OF DOMINICAN CHAPEL FISH LANE

REMAINS OF OF DOMINICAN PRIORY BISHOP STREET

ST. JOHNS CATHEDRAL, AND CLERGY RESIDENCE

ST JOHNS CHURCH AND GRAVEYARD.

ST JOHNS GATE AND ASSOCIATED HOSPITAL BUILDING

ST JOHNS SQUARE ENTIRE

AT ALPHONSUS LIGUORI CHURCH , UPPER HENRY STREET

ART GALLERY PERY SQUARE

ST SAVIOURS CHURCH , DOMINIC STREET

FRANCISCAN CHURCH AND FRIARY RESIDENCE, HENRY STREET

BISHOPS HOUSE, CHURCH STREET

GERARD GRIFFIN MEMORIAL SCHOOL (FORMER COURTHOUSE) BRIDGE STREET

TERRACE OF STONE HOUSES CHURCH STREET

THE MILK MARKET, CARR STREET

ST MICHAELS CHURCH AND GRAVEYARD, MICHAEL STREET

ST. MUNCHINS CHURCH AND GRAVEYARD CHURCH STREET

MEDIEVAL HOUSE CURRY LANE

UNDERCROFTS AND CELLARS CIVIC OFFICES

EARL OF LIMERICK HOUSE HENRY STREET

BISHOP PERY HOUSE HENRY STREET

ST MICHAELS CHURCH PERY SQUARE

ST. JOSEPHS CHURCH O'CONNELL AVENUE

THE SAVINGS BANK GLENTWORTH STREET

FORMER TOWN HALL (COMMERCIAL BUILDINGS) RUTLAND STREET

FACADE OF FORMER TRINITY CHURCH CATHERINE STREET

THE ROSARY CHURCH ENNIS ROAD

ORIGINAL STONE BUILDING OF FORMER BARRINGTON'S HOSPITAL

ST . JOHNS TEMPERANCE HALL

TOLL HOUSE THOMOND BRIDGE

ST MARY S CHURCH,ATHLUNKARD ST

PAROCHIAL HOUSE ATTACHED TO ST MARYS CHURCH, ATHLUNKARD ST

LAX WIER CORBALLY

SHANNON ROWING CLUB SARSfieLD BRIDGE

SARSfieLD BRIDGE

THOMOND BRIDGE

LIMERICK JAIL, MAIN ENTRANCE AND RAILINGS

THE ROUND HOUSE

FORMER BOYD'S, 11 & 12 WILLIAM STREET

CONVENT AND CHAPEL O CONNELL AVENUE

FORMER MODEL SCHOOL O CONNELL AVENUE

MALLOW STREET 2 TO 28

MALLOW STREET LOWER 1 TO 14

HARTSTONGE STREET 1 TO 6, ST VINCENT DE PAUL HOUSE, FORMER LEAMY SCHOOL.

HARTSTONGE STREET LOWER, 7 TO 22

O'CONNELL AVENUE 1 TO 3, 6 AND 7

BARRINGTON STREET 6 TO 8, 12 TO 15, 2 TO 26

NEWENHAM STREET, 2 TO 7, 10 TO 12

CONVENT OF MERCY, BISHOP STREET

BANNATYNES WAREHOUSE, DOCK ROAD

HENRY STREET, FORMER PRESBYTERIAN CHURCH EXTERIOR.

STONE BUILDINGS, FORMER O MARA'S BACON FACTORY

TIPPERARY ROAD, BORU HOUSE, KATE O BRIEN CHILDHOOD HOME

THE CRESCENT, 1 TO 11 ( South Side) CRESCENT COLLEGE (EXCLUDING 1930S

CORNER BUILDING TO NEWENHAM STREET) JESUIT CHURCH, 15 TO 19.

CATHERINE PLACE 1 TO 8

O'CONNELL STREET. 64 TO 94

O'CONNELL STREET , CHAMBER OF COMMERCE

PATRICK STREET 1 TO 9

BANK PLACE 1 TO 3

RAILWAY STATION, RAILINGS, MAIN ENTRANCE BLOCK AND SHED

RAILWAY HOTEL, BOHERBOUY



THE FOLLOWING STREETS WITH PRE 1850 BUILDINGS RETAINING ORIGINAL GEORGIAN

HOUSE ARRANGEMENT OF BASEMENT AREA, RAILINGS AND BRICK ELEVATIONS


CATHERINE STREET

CECIL STREET

HENRY STREET

THOMAS STREET.

PERY STREET


SPECIFIC PROTECTION OBJECTIVES LIST B


It is the general objective of the Corporation to secure the appropriate

maintenance and protection of the architectural character of the pre 1900

building stock, because of its contribution to the economic base, social

identity and character of the city, and the setting and surroundings of the

List "A" buildings.


All external material alteration to List "B" buildings and structures will

require Planning Permission. It is the specific objective of the

Corporation to protect all pre 1900 buildings from inappropriately designed

window replacement or other material alterations, and to take enforcement

action against such alterations where carried out without permission.


All pre 1900 buildings in the city will be spefically scheduled for

protection under List "B" where not already scheduled on List "A"


OBJECTS AND SITES LIST "A.F"


RETAIN AS PROPOSED.


VIEWS AND PROSPECTS


RETAIN AS PROPOSED


PRESERVATION OF TREES


RETAIN AS PROPOSED