Height in Dublin City
By Michael Smith
Dublin City Council is pushing a high-rise strategy through the Development Plan variation process. After fractious public meetings it has toned down an initial draft of what it called in somewhat Orwellian terms: “Maximising the City: A strategy for densification and height”. If successful it will come into force just before the Council initiates the process of creating a whole new Development Plan. Clearly the process is pre-emptive and so wrong. But the substance also threatens Dublin’s unusual, human scale. It is perfectly sensible to like New York and to be happy when it goes higher still while recognising that Dublin City Centre has a different unique selling point. When we think of Dublin, when tourists spend two days in Dublin, it is the low rise character that IS the city. A Dublin that people overall like. It is fragile because two twenty-storey buildings could change it forever.
This document threatens it very really.
The document is discursive and self-contradictory in places – no doubt reflecting the complex discussions that led to the final draft. But for those of us who have been involved in the planning process it is clear that loose language and confusion (which admittedly pervade the current development plan) is leapt on by developers to promote a laissez-faire approach. And in any event the cynics know well that the city council is often happy to breach its own development plan e.g. in the case of the development on the site of the former Carlton Cinema on O’Connell St or the Clarence Hotel.
Height versus density
We should all be able to agree to densification of the Dublin City area – in accordance with the principles of sustainable development. The advantages of density include being able to justify significant infrastructural, including public transportation but also for example parks, expenditure, which promotes the maximisation of quality of life The benefits of high-rise including legibility and the making of corporate or other statements are small in comparison.Intensification (or densification) is good as it benefits many and harms few. Height benefits very few and may be detrimental to the majority.In general it is not in the public interest to search Dublin City for “opportunities”, “potential” or “scope” for high buildings; or flexibility as a useful tool to this end. It is important to note also that high-rise buildings – such as in Heuston – are usually not ultra-high density as problems of overshadowing usually lead to requirements for plazas at ground level. Certainly the city should look for opportunities to densify, but it should control, not maximise, the opportunities to build high.
A high-rise strategy may actually be premature until there is a coherent and agreed strategy for intensification.
The false premise
It appears that City Council officials have in effect misinterpreted the planning strategies of cities comparable to Dublin. Current policy as represented in a report by DEGW states that in the three cities it deemed comparable to Dublin (Copenhagen, Amsterdam and Lyon) “the planning strategy has been to intensify and consolidate city centre functions within the historic height restrictions and develop new peripheral cores at public transport nodes to meet emerging demands [p14, emphasis added]”. DCC has ignored the key notion of peripherality! Dublin should choose its analogues carefully. It survived the second world war and has a large number of protected structures. It should not be adopting strategies perhaps appropriate for Frankfurt or Rotterdam, even if there is a lobby for it from opportunistic developers and trite commentators. DCC needs to get a dictionary out and look up peripheral.
Substance
The manager’s recently updated document which accepts the difference between high-rise and high-density, is clearer than before and uses a rhetoric about high-rise which is more mature than that used in earlier versions. However, the substance of the document does not mirror this acceptance and rhetoric. Despite efforts by commentators (e.g. Frank McDonald disappointingly in the Irish Times) and some councillors, led surprisingly by Sinn Fein’s Daithi Doolan, which gloss over them, there remain substantial concerns about the substance of the revised document.
Transport Nodes and Height versus Density
The document continues in part to confuse the benefits of high-density with those of high-rise. Transport nodes, meaning train stations but also perhaps future Metro stations such as one proposed for the edge of Temple Bar) should attract high-density development to capitalise on the expensive transport infrastructure. But the document proposes “high-rise” for transport nodes such as Connolly and Tara. This is not justified where the transport nodes are in the city centre where amenities and the city’s heritage may be compromised by height.
Particular areas
Concerns remain about some of the particular areas envisaged for high-rise, though most commentators support the proposed and existing schemes in the Docklands and Heuston areas. The justification has not yet been made for many of the other areas or catchments envisaged for high-rise development. Management needs to explain and justify the impact of high-rise buildings in the particular parts of the city cited. Ostensibly they risk undermining amenities and the historic heritage of the city.
City Centre: General
There is particular concern about the impact of high-rise on the city centre and inadequate protection is provided for the historic core. It is unclear whether it is envisaged that much of the City Centre could be developed at eight storeys. Certainly only buildings over eight storeys are defined as high-rise when under the current regime as represented by the DEGW report [at 5.1] height is expressly a relative concept. The new document removes the existing provision for systematic assessment of the implications of high-rise in the city centre – unless the proposal is above eight storeys. A seven-storey building on Bachelors Walk, for example, would not be specially assessed,
City Centre: Particular
High-rise in each of Tara St, Connolly and the Digital Hub around historic Thomas St is risky as they are all are close to the city centre and important landmark historic buildings and streets. A proper assessment of the receiving capacity of the area should be conducted before adoption of statutory Local Area Plans (LAPs) in each case. It may be that high-rise would work in the area of the Connolly Car Park and Sheriff St. It may be that some high-rise would mask the horrors of Hawkins House and the Ulster Bank on George’s Quay. And t there may be some opportunities to mirror the heights of existing high industrial buildings around Guinness’s near Thomas St. We don’t know and the City Council certainly isn’t telling us. That’s why we require the robust and fool-avoiding mechanism of LAPs. LAPs demand full community consultation, a Strategic Environmental Assessment (which show the impact), LAPs also obtain statutory effect. Dublin City Council suspiciously continues to promote nebulous “area action plans” which have dubious effect but allow the flexibility that has in the past enabled the Corpo to facilitate the vociferous development lobby.
These last three areas face buildings up to thirty storeys. Why?
High-rise at Broadstone is risky as the area boasts significant heritage and does not in any way require signature buildings – as opposed to high-density development – if it is to become an attractive city quarter.
There is no logic in urban planning terms to creation of a knowledge axis between the Digital Hub and Grangegorman if this informs height in the area.
So, where is high-rise desirable?
The answer is we do not know. All we have is a confusing, incomplete and preliminary 2000 study, by DEGW. Outside Dublin City (particularly in the other Council areas such as “South Dublin”, it is possible that, if green fields have to be rezoned, consideration should be given to high-rise where there is excellent public transport. Much soulless suburbia could actually be improved, visually and otherwise, by attractive high-rise. Beyond this, we cannot and do not know because, except for Docklands and Heuston, identified by DEGW, proper studies and proper consultation have not been carried out. Reflecting this, the proper course would be to promote plan-led high-rise in suitable parts of Docklands particularly, subject to improved accessibility, on the Poolbeg Peninsula where they could serve as portals to the city; and on specific sites near Heuston. There may be other possibilities: Ballymun can absorb some high-quality high-rise. Perhaps some of the commercial/industrial areas in Walkinstown, the Naas Road, parts of Crumlin and parts of Finglas might derive some architectural interest from height punctuation.. These suggestions are not definitive because they are not rooted in proper research and proper local consultation.
Process
In order to further twin primary objectives of promoting sustainable development and listening to public opinion we believe the variation process should be followed by the adoption of local area plans, following proper public consultation. This is the mechanism envisaged under the 2000 Planning and Development Act for major changes in the planning of local areas. Framework plans are outmoded and ill-equipped to deal with a major change in Dublin City Council’s planning policy at local level.
Specifically, the City Manager should initiate a variation to the Dublin City Development to provide that tall buildings, meaning buildings significantly higher than neighbourhood or surrounding buildings, may be considered only following adoption of LAPs which should specifically provide for preservation in full of existing positive local and civic character; and should be prepared only after the fullest consultation and engagement with the public including local residents, public sector agencies, non-governmental agencies, local community groups and commercial interests within the area. If possible, local community groups should be afforded reasonable costs for making submissions on LAPs.