15.15 - Built Heritage and Archaeology

Dublin city centre and its suburbs comprise a number of significant historic and other buildings, streetscapes and spaces which contribute to the character and heritage of the city. There are also a number of areas that fall within zones of archaeological interest. It is essential that new development in these historic and distinct areas respects the existing character, safeguards the historic setting of the streets and spaces and addresses built heritage and archaeology. In this regard, a series of development management standards are provided to guide new development in these areas and to ensure that our built heritage and archaeology are protected. The following section sets out the relevant guidelines and policies that apply to all new development and any extension or refurbishment in the historic areas or areas of significance in the city.

15.15.1         Archaeology

The definition of archaeological heritage includes structures, constructions, groups of buildings, developed sites, moveable objects, monuments of other kinds as well as their context, whether situated on land or under water, in accordance with the Valletta Convention, 1992. In order that the City Council’s policy on archaeology is implemented, the following shall apply:

15.15.1.1      Preparing Planning Applications

Applicants shall have regard to Archaeology in the Planning Process (Office of the Planning Regulator, 2021) and Archaeology and Development Guidelines Good Practices for Developers (Heritage Council, 2000).

All applications for proposed new developments at sites marked as Sites and/or Zones of Archaeological Interest identified on the development plan zoning maps shall be subject to pre application discussion/consultation with the Archaeology Office.

Where a site is located within a Zone of Archaeological Interest, an Archaeological Assessment as defined in National policy and guidelines shall be prepared in consultation with the City Archaeologist and provided as part of the planning application. The assessment will evaluate the archaeological potential of the site for and the impact of the proposed development on them.

15.15.1.2      Exempted Development

Exempted development does not apply to any development that would consist of or comprise the alteration of any archaeological site, the preservation or protection of which is an objective of the relevant local authority development plan.

Where a development site is within a Zone of Archaeological Interest, is over 0.5 hectares in size, or for linear developments more than 1km in length, the applicant shall employ a suitably qualified archaeologist to carry out an archaeological assessment in consultation with the City Archaeologist at pre-planning stage and report on any necessary site investigation works prior to an application being lodged.

15.15.1.3      Best Practice

All archaeological reports submitted with a planning application and/or prepared in compliance with planning permission shall be produced in accordance with Excavation Reports Guidelines for Authors, (NMS, 2006).

All development shall be carried out in accordance with the Framework and Principles for the Protection of the Archaeological Heritage, 1999 and other National policy and guidelines for the archaeological heritage.

Archaeological work shall be carried out in accordance with current archaeological best practice policy and guidance published by the National Monuments Service, and with reference to technical guidelines issued by the Institute of Archaeologists of Ireland and Transport Infrastructure Ireland. Where National technical best practice guidelines are unavailable, internationally recognised best practice guidance may apply.

Where archaeology services are incorporated into fixed priced contracts, the contract shall be prepared with regard to Standard and Guidance Procedures for Archaeological Services in Fixed Price Contracts used in the Republic of Ireland, (IAI, 2012).

Archaeological work shall be undertaken in accordance with the Policy and Guidelines on Archaeological Excavation, (NMS, 1999). All archaeological monitoring shall be done under licence.

Archaeological excavations shall comprise a specialist-led environmental site strategy and conducted in accordance with Environmental Sampling: Guidelines for Archaeologists, (IAI, 2007).

15.15.1.4      Basements

New basement development in the medieval core and known medieval sites shall be avoided. Approved basements may be rescinded where undue damage to in situ archaeological deposits will occur as a result.

15.15.1.5      Industrial Heritage

Archaeological assessments shall have regard to the Dublin City Industrial Heritage Record and evaluate any above and below ground industrial heritage features. Where industrial remains are identified, the application may be required to engage the services of an industrial heritage expert to prepare a specialist report.

15.15.1.6      Foundations

The impact and merits/demerits of foundation type and soil hydrology shall be archaeologically assessed to determine appropriate mitigation (including avoidance, redesign, etc.).

15.15.1.7      Archaeological Excavation

When planning permission for development involving sub-surface excavation is granted, the applicant’s attention will be drawn to the legal obligation to report the discovery of archaeological finds to the National Museum of Ireland.

15.15.1.8      Archaeological Mitigation

Where a site has tested positive for archaeology, in situ remains shall be evaluated for preservation in situ.

In situ medieval structures shall be carefully evaluated with the aim of preservation and presentation in situ within the new development.

Where preservation in situ is not feasible, sites of archaeological and/or industrial heritage interest shall be subject to a full archaeological excavation and post excavation analysis according to best practice in advance of redevelopment.

Where an excavation is the agreed mitigation strategy the licenced archaeological director shall submit bi-weekly briefing notes to the City Archaeologist for the full duration of the excavation. A preliminary excavation report in digital and hard copy shall be submitted to the planning authority for the attention of the City Archaeologist within four weeks of the completion of the excavation or of each phase of the excavation and a detailed final report submitted within twelve months of the completion of the excavation.

The results of all archaeological excavations shall be evaluated for publication either as a monograph or scholarly article, within 1 year after archaeological site completion. Information about medieval sites will be disseminated to the public through the Friends of Medieval Dublin or similar free event within 1 year of site completion.

The excavation archive shall be prepared in accordance with Dublin City Archaeological Archive (DCC, 2008) and submitted to the Dublin City Archaeological Archive within 1 year of excavation completion.

15.15.1.9      Preservation In Situ

Where a proposed development is at a known Monument / Site or within an Archaeological Zone, discussions about the retention of features within / below developments (preservation in situ) and mitigation options shall take place at the outset of project planning and shall be reviewed at each stage of the project.

Before considering whether an archaeological site can be appropriately retained within a development (preserved in situ), the following shall be addressed:

1. The current state of preservation of the archaeological finds and deposits and how they contribute to the site’s significance.
2. The likely development and how these will affect the site’s significance.
3. For sites containing waterlogged archaeological remains, the availability and quality of water on the site and how sensitive this hydrological regime is to changes.

Preservation assessments shall form a discrete part of desk-based assessments and site evaluation reports.

Consideration shall be given to the impact of any development proposal on waterlogged deposits that could be potentially threatened through changes to the hydrological regime, water levels and quality.

Test excavations shall be carried out to investigate and evaluate the deposits and the artefacts they contain in sufficient detail to establish their significance, their state of preservation and their susceptibility to adverse impact from proposed development.

Preservation assessments (including characterisation of the environmental conditions of the deposits) to form a regular part of the evaluation methodology for sites where retention within the development is likely to be the final mitigation outcome.

When the state of preservation of material is poor, and further burial following development is likely to cause additional damage to that material, excavation of the archaeological remains to recover their remaining significance and evidential value is the most appropriate strategy.

Where sites contain waterlogged archaeological remains, water environment studies to determine water availability and water stresses may be required.

If the condition of surviving material and deposits is good and development risks are not going to cause a change to below ground environments (including site hydrology), then harm to significance may be limited. In these instances, the retention of the site and its future management as part of the development may be achievable. For such sites, monitoring will not normally be necessary.

Where there is concern about potential impacts of development on well preserved archaeological remains, it is good practice for monitoring to only be considered appropriate if a mitigation scheme is in place to manipulate water levels or provide access for future excavation if environmental conditions deteriorate.

15.15.1.10     Piling and Archaeology

Where piling is being considered as part of a foundation design on a site containing archaeological remains, a range of site-specific information will be needed to enable sound decision taking with regard to the particular technical issues raised by the use of piled foundations.

• The applicant shall provide sufficient information demonstrating an adequate understanding of the significance of the archaeological site and assessment of potential harm to that significance arising from the development.
• The planning application shall include an appropriate desk-based assessment and where necessary the site will be evaluated by way of archaeological testing in advance of the grant of permission.
• Sufficient geotechnical site investigation shall be undertaken in accordance with Eurocode 7, early in the design process to ensure that appropriate engineering information is available to allow for a flexible foundation design and reduce the impact on archaeological remains.
• The developer shall consider foundation options and inform the piling contractors that archaeological remains are present on site before they tender.

Technical aspects associated with piled foundations will be appropriately assessed. These include but are not necessarily limited to:

1. The potential for the particular pile type utilised to damage archaeological deposits.
2. The cumulative impact of successive piling on a site resulting in damage to so much of a site that future re-examination would not be worthwhile.
3. The potential for piling to change the site hydrology, draining waterlogged deposits.

15.15.1.11     Recording of Historic Buildings

Buildings on the first edition OS that are not protected structures shall be recorded as part of the archaeological assessment that accompanies the planning application. Appropriate specifications for the recording of historic buildings will be determined in consultation with the City Archaeologist. Records of historic buildings will inform decisions relating to the approval or implementation of a scheme of development as part of the planning process or to document buildings, or parts of buildings, which will be lost as a result of demolition or alteration.

15.15.2         Built Heritage

15.15.2.1      Architectural Conservation Areas

There are currently 24 Architectural Conservation Areas (ACA’s) within the city as identified in Chapter 11 and as indicated as a green hatch on the zoning maps. Development in these zones must respect the existing character of the area and protect and enhance the setting and appearance of the streetscape and / or protected features. Details on the requirements for development within ACA’s are set out in Policy BHA7 and BHA8 as set out in Chapter 11 as well as in the specific Framework for each ACA accessed in the link below: https://www.dublincity.ie/residential/planning/archaeology-conservation-heritage/conservation-built-environment/architectural-conservation-areas.

Many Architectural Conservation Areas (ACA’s) contain significant groupings of protected structures, streetscapes and views and vistas of significance as well as buildings that individually may be of local significance, but collectively would have a greater significance as a group.

Larger scale applications within or immediately adjacent to an ACA will need to provide an assessment, carried out by a suitably qualified conservation professional, of the impact of the development on the ACA the streetscape and the buildings in the immediate vicinity and demonstrate that there will be no material, adverse impact arising. Such an assessment should be accompanied by appropriate drawings, imagery and photomontages of the site and the surrounding context to assist the planning authority in assessing the impacts of the development.

15.15.2.2      Conservation Areas

Conservation Areas include Z8 (Georgian Conservation Area) and Z2 (Residential Conservation Area) zones, as well as areas identified in a red hatching on the zoning maps which form part of the development plan. These red-hatch areas do not have a specific statutory protection but contain areas of extensive groupings of buildings, streetscapes, features such as rivers and canals and associated open spaces of historic merit which all add to the special historic character of the city.

All planning applications for development in Conservation Areas shall:

• Respect the existing setting and character of the surrounding area.
• Be cognisant and/ or complementary to the existing scale, building height and massing of the surrounding context.
• Protect the amenities of the surrounding properties and spaces.
• Provide for an assessment of the visual impact of the development in the surrounding context.
• Ensure materials and finishes are in keeping with the existing built environment.
• Positively contribute to the existing streetscape Retain historic trees also as these all add to the special character of an ACA, where they exist.

Further guidance on Conservation Areas is set out in Chapter 11 Section 11.5.2

15.15.2.3      Protected Structures

There are almost 8,500 protected structures in the city, as identified on the Record of Protected Structures, Volume 4 of the plan. The inclusion of a structure in the Record of Protected Structures does not prevent a change of use of the structure, and/or development of, and/or extension to the structure, provided that the impact of any proposed development does not adversely affect the character of the Protected Structure and its setting. Conservation is the careful and sensitive management of change and DCC would support new proposals to conserve, repair and adapt Protected Structures to ensure they stay in long term sustainable use.

Any works which materially affect the character of a Protected Structure require planning permission. Some works may be considered exempted development where they do not materially affect the character of the building or those elements of the structure that contribute to its special interest.

A Section 57 Declaration may be requested from the planning authority in relation to the type of works that it considers would or would not materially affect the character of the structure or of any element of special interest of the structure. Separately, a Section 5 Declaration can be sought from the Planning authority to establish if specific works (such as repairs and other modest works) proposed would be considered exempted development (i.e. would not materially affect the character of the structure or any element of special interest of the structure).

A Protected Structure, unless otherwise stated, includes the interior of the structure, the land lying within the curtilage of the structure, any other structures (and their interiors) lying within that curtilage. The protection also extends to any features specified as being within the attendant grounds including boundary treatments.

Works to a protected structure should be carried out in accordance with the Architectural Heritage Protection Guidelines for Planning Authorities (2011) and the Conservation Advice Series published by the Department of Housing, Local Government and Heritage

All planning applications for development/works to Protected Structures must provide the appropriate level of documentation, including an Architectural Heritage Impact Assessment, in accordance with Article 23 (2) of the Planning and Development Regulations, 2001 (as amended) and chapter 6 and appendix B of the ‘Architectural Heritage Protection Guidelines for Planning Authorities’ (2011), to assist in the assessment of proposals.

This report should be prepared by an accredited conservation architect or equivalent conservation professional/expert (a useful list of suitably qualified professionals is available on the Irish Georgian Society https://www.igs.ie/ and RIAI https://www.riai.ie/ websites). The report should:

• Outline the significance of the building(s) or structure(s) and their settings and an assessment of how the proposed works would impact on that significance.
• Include a detailed drawn survey of the building/structure identifying all surviving original/early and later features that may contribute to its significance and associated photographic survey.
• Include a conservation focused method statement and specification of works.
• Details of proposed works should be clearly identified on the accompanying survey drawings by way of colour coding and/or annotated notes to distinguish clearly between the existing structure, the proposed works including demolition of existing fabric and/or features. The colour coding should also show the provenance of the historic building, including identification of the various stages of its development, identifying original, historic and later intervention.

The detail required to be submitted will be dependent on the significance of the building and the nature and extent of works proposed. It may be of benefit to discuss specific requirements, with an Architectural Conservation Officer, prior to making a planning application; through the pre-planning consultation process.

In assessing proposed development works (inclusive of extensions, alterations, change of use. etc.) to a Protected Structure, the Planning authority will ensure compliance with the policies, objectives and provisions of Chapter 11, Section 11.5.1 of this plan.

15.15.2.4        Retention and Re-use of Older Buildings of Significance which are not Protected

Our built heritage is rich and varied. Much of our built heritage is not protected nor located within an ACA.

The re-use of buildings/structures of significance is a central element in the conservation of the built heritage of the city and important to the achievement of sustainability.

In assessing applications to demolish buildings/structures of significance that are not protected, the planning authority will actively seek the retention and re-use of buildings and other structures of architectural, historical, archaeological, artistic, cultural, scientific, technical, social and/or local interest or those that make a positive contribution to the character and identity of streetscapes and the sustainable development of the city; also having regard to Policies BHA 05: Demolition of Regional Rated Buildings on NIAH and BHA 06: Buildings on Historic Maps. Where the planning authority accepts the principle of demolition, a detailed written and photographic inventory of the building may be required for record purposes.

15.15.2.5      Historic Buildings and Access

In assessing planning applications which relate to protected structures, regard shall be had to the protected status of the structure and the need to protect its special character. Detailed advice is provided in the Architectural Heritage Protection Guidelines for Planning Authorities (re-issued by DAHG, 2011) and in Access – Improving the Accessibility of Historic Buildings and Places (Advice Series, DAHG, 2011). There is a need for flexibility in the use of protected structures and in making them accessible to people with disabilities, whilst respecting their architectural integrity.

15.15.2.6      Barrier Free Access and Protected Structures

The creation of barrier free access to protected structures can be difficult to reconcile. Where access devices are proposed, the following information should be submitted:

• An assessment of the building’s access requirements, including details on the circulation and user requirements of the building.
• An assessment of the impact of access devices on the special character and setting of the protected structure, particularly where architectural details such as plinths, thresholds, steps, staircases and railings, which contribute to the special interest of the building, are involved.
• An assessment of alternative design options considered to ensure the proposal would represent the most sensitive access solution available.
• Details of the materials and specifications of both permanent and temporary devices which should be appropriate to the location so as to reduce the visual impact of the mechanism.

Creative architectural responses which represent the most sensitive access solution will be actively encouraged. Proposals should be so designed to ensure the device can be removed without damage to the fabric of the building, where possible i.e. reversible. In certain cases, it may be necessary to locate such devices on/in less significant parts of the building. All works should retain the maximum amount of historic fabric in situ and should be designed to cause minimum interference to the historic building fabric and reduce the visual impact of the mechanism.

15.15.2.7      Fire Safety Works and Protected Structures

Fire protection works to protected structures relate directly to the use and requirements of a building and can have a significant impact on the character of a protected structure and require planning permission, if they give rise to significant impacts and/or alter the character of the protected structure.

When considering proposals for fire safety measures, a strategic approach to fire protection works to the building will be encouraged. Uses which may diminish the special interest of a protected structure through inappropriate alterations will generally not be encouraged. Applications for fire protection works shall be guided by the principles of minimum intervention to the historic fabric and the reversibility of alterations, where achievable.

15.15.2.8      Lighting of Protected Structures and Buildings in Conservation Areas

Well-designed exterior lighting of landmark buildings, structures and spaces can play an important role in defining the character of the built heritage. A successful lighting scheme will relate to the architectural form of the building and will sensitively utilise the detailing and features of such buildings with low wattage and/or dimmable light sources in an appropriate colour, and discreet light fixtures. It will also minimise the spillage of potential obtrusive light to adjacent areas and will avoid unnecessary over lighting, which can alter the appearance of a building or area.

In considering applications for lighting schemes, the need for such schemes should be clearly established. Proposals for lighting schemes should include details of the size, type, siting, and number of fixtures and fixing methods, as well as wattage, colour of light source, light pattern and potential impact on the building material and features, and include visualisations to demonstrate the intended effects.

To avoid conflict, proposals should demonstrate how lighting schemes would enhance and protect the character of an area or group of protected structures and/ or co-ordinate with any adjacent lighting schemes. Powerful wide-angled over-lighting which can diminish the architectural features of a building, its setting or surrounding area will be discouraged. Lighting schemes may not be appropriate in certain residential areas, as the spillage of light from lighting schemes can impact on the amenities of such areas.