COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

MEETING OF SOUTH DUBLIN COUNTY COUNCIL

Monday, July 14, 2008

HEADED ITEM NO. 14

 

SUBMISSION TO AN BORD PLEANALA IN RESPECT OF N7 RESOURCE RECOVERY PROJECT AT BEHAN'S QUARRY, WINDMILL HILL, RATHCOOLE, COUNTY DUBLIN

REPORT OF CONSERVATION OFFICER

An application under the Strategic Infrastructure Act was lodged with An Bord Pleanala (Ref. 06S.PA0006) on the 29^th May 2008 for permission for the proposed development of a resource facility for the thermal treatment of non-hazardous residual, municipal and construction and demolition waste at Behan’s Quarry, Windmillhill, Rathcoole, Co. Dublin.

 Appraisal

 The proposed development as described above includes for the development of:

1. A mechanical treatment facility, which includes a waste receiving and processed refuse fuel storage building with an associated administration building that includes a new landmark windmill building comprising 3-storeys and an upper plan room over 6-storeys located below ground.
2. An energy recovery facility, which includes thermal treatment, air quality control, and turbine/generator equipment and associated stack (approx. 84m above t he finished floor level of the quarry and approx. 9m above the level of the adjoining ground) located on the southern boundary of the site and
3. A materials recovery facility, which includes ash processing, metals and aggregate recovery, and concrete products manufacturing equipment (approx. 4,477sq.m and max. building height of approx. 19m)
4. Renovation and extension of the existing farmhouse and renovation of the existing farmhouse outbuildings for use as administrative offices and a visitor/education centre
5. Ancillary outbuildings including warehousing, vehicle maintenance building and electrical distribution building.

In total the building area is approx. 25,852sq.m on a 14.5 Ha site at the existing quarry (know locally as Behan’s Quarry), Windmillhill, Rathcoole.

An Environmental Impact Statement has been submitted as part of the application.  Included in the EIS is a conservation report which deals with the Protected Structure on the adjacent site and the existing vernacular buildings Windmill House and associated outbuildings which are to be retained and renovated for use as offices.  An assessment of Archaeological and Cultural Heritage was undertaken.  It details a desktop survey of the archaeological potential of the N7RRP site, and a field inspection of the study area.  The report includes information on sites and monuments of archaeological, architectural and industrial archaeological interest in proximity to the N7RRP site. 

Architectural Heritage

 A Stone Windmill (ruin) which is a Protected Structure RPS Ref. 358 is located a short distance (approx. 20-30m) outside the southerly boundary of the proposed site along the quarry edge.  The existing structure probably dates to the 18^th century.  The windmill is not directly impacted by the proposals however battering of the quarry face for stabilisation will bring the southern perimeter of the development within 35m of the existing structure.  It is also considered that there is a direct impact on the environs and the setting of the existing structure. 

 A landscape and visual impact assessment has been carried which includes comments in relation to visual obstruction and site visibility.  The nature of the site results in low visibility of the majority of the proposed development.  However, some parts e.g. the proposed stack and the proposed windmill building will be visible in a number of views from the surrounding area. 

 Although the setting of the structure has previously been altered by the existing quarry pit the proposed new structures consisting of an 84m tall stack and proposed windmill building will be visible in a number of views from the surrounding area.  The existing quarry at Windmill hill is a human activity in the area which has shaped the current environs and has influenced the wider landscape surrounding the proposed development.  It is likely that the quarry has been worked since the early 18^th century and has therefore formed part of this landscape for a significant length of time. Due to the prominent location of the existing windmill structure it has become one of the main landmark features of the area.  It is therefore important that the significance of the setting be given full consideration in terms of the overall impact of the proposed development.

The existing windmill structure (ruin) is visible from a number of locations to the southeast, south and southwest of the application site.  The proposed stack being higher than the top ridge of the quarry is visible against the view of the Protected Structure from some locations.  The proposed stack detracts from the views of the existing windmill from a west direction.  The stack will be the dominant feature on the landscape in this location and the Protected Structure will no longer be the focus of its setting.  Therefore it is considered that the sack in its proposed location would have a negative affect on the setting of the Protected Structure.   

It is stated in the landscape and visual impact assessment that “the proposed windmill building will have a slight to moderate impact on the landscape character, as it is seen in the context of the existing development (see photomontage 13.2).  A windmill was present in this area for a number of years, the ruined base of which is located just south of the application site. There is therefore a historical relevance to the new structure of a windmill.   The impact on landscape character resulting from the construction of the stack will be higher, as it is visible on higher ground.  However, in the more distant views the stack will resemble the ruined windmill base, as they will be of similar colour and height”. 

Based on the details provided within the Landscape and visual impact assessment in relation to the above issues it is considered that the location and design of proposed windmill building and stack compromises the setting and uniqueness of the existing 18^th century stone windmill (ruin) which is a Protected Structure.  It is therefore considered that the proposed stack should be re-located to an area further away from the site of the existing windmill (ruin) in order to minimise the overall affect on the setting of the Protected Structure.

It is not acceptable to justify the location and height of the proposed stack because the stack will resemble the ruined windmill base.  The stack should stand alone and be recognised for what it is a purpose built structure associated with the proposed resource recovery facility.  A landscape and restoration plan has been produced in order to provide for some vegetative screening.  Mitigation measures have only been provided for the most significant visual impact which is the proposed stack. 

 As already detailed above the proposed windmill building will have a slight to moderate impact on the landscape character. It is considered that by nature of its scale and building type this structure will be visible in some locations.  The design of the structure and its dimensions fail to contribute to the existing landscape and provide a structure which is of poor architectural quality.  The proposed windmill structure looks completely alien to the existing landscape.  Justification has not been provided for constructing such a building in this location nor has any sort of design rationale been offered.  It is considered that the proposed new structures should be of a contemporary design using modern materials i.e. reflective surfaces that would blend into the existing landscape.  The new structures should be designed using architectural design and innovation of today.

 There are no Protected Structures or buildings recorded in the National Inventory of Architectural Heritage for South County Dublin located within the proposed development site. However Windmill House and its outbuildings form a complex of vernacular structures which are located within the development site north of the quarry.

 South Dublin County Councils Development Plan includes an objective under Section 8.1.3.v which states that “in addition to the buildings of special interest included in the Record of Protected Structures (RPS), South Dublin contains a wide variety of vernacular buildings.  These buildings contribute in a particular way to the distinctive character of local areas, which can be significantly diminished by their loss through demolition and replacement.  The Council will seek to retain such buildings where feasible”. 

The following are the strategy for Archaeological and Architectural Heritage of the County as stated under Section 8.2.i of the County Development Plan:

• Protect and conserve the archaeological heritage of the County.
• Protect and conserve buildings, structures and site of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest.
• Secure the preservation in situ or by record of all sites and features of historical and archaeological interest.
• Protect and conserve areas that have particular environmental qualities that derive from their overall layout, design and unity of character
• Protect and conserve historic milestones, street furniture, and other significant features wherever feasible.
• Encourage the rehabilitation, renovation and re-use of existing older buildings where appropriate.

It is proposed to retain and renovate Windmill House and outbuildings for use as offices.  The Conservation Architects Report provides full details on the impact that the proposed development will have on Windmill House and its outbuildings and associated features. 

A number of mitigation measures have been provided which are deemed to be acceptable however it is considered that some additional recommendations are required to ensure that the vernacular quality of the existing buildings are retained.

 Archaeological Heritage

 The site of the existing Windmill (ruin) a Protected Structure is also a Recorded Monument as listed under the Record of Monuments and Places Ref. DU021-038.  The Record of Monuments and Places files suggest that the current Windmill structure on the site dates from the 18^th Century but that the site occupies that of an earlier structure referred to in 1413AD which provides the site with Recorded Monument status (pre 1700). 

 The windmill is not directly impacted by the proposals however as already mentioned above the battering of the quarry face for stabilisation will bring the southern perimeter of the development within 35m of the existing windmill structure.  There will be a potential impact on any sub-surface archaeological features and material associated with both the windmill and its medieval precursor within the north-western environs of the upstanding remains.  One Area of Archaeological Potential was newly identified during the assessment; a possible hillfort is located east of the existing quarry.  Its western extents have previously been partially quarried out.  No groundbreaking will be undertaken along the eastern perimeter of the development, therefore there is no further predicted impact on the potential hillfort.  A number of mitigation measures have been recommended based on the Archaeological Assessment.

Recommendations

 The following are recommendations and comments in relation to the design of the proposed development and the impact of the proposed development in relation to the architectural and archaeological heritage in/or within close proximity to the proposed development.

1. Details of how the Protected Structure will be safeguarded during the proposed development should be finalised and agreed prior to the commencement of construction works.

1. Front elevation proposals particularly the construction of a canopy at the main entrance should be re-designed in a more sympathetic way so to be in keeping with the vernacular style of the original house or should be of modern design so that any additions are clearly defined.  The setting and landscaping proposed for the front site should also take account of the existing fabric and style of the original house which should influence the character of the overall plans.

1. In relation to the proposed works affecting the existing outbuildings of Windmill House the replacement of slate sections of roof with metal roof decking is unacceptable.  It is considered that the surviving slate roofs shall be retained. Also where the use of metal roof decking is proposed in the replacement of corrugated-iron roof sections roofing material to match the existing corrugated-iron shall be used as this was the original type of roofing material for re-roofing vernacular structures when slate tiles were not available.
2. A detailed Method Statement and Schedule of works shall be included in a Programme of conservation repairs which should be finalised and agreed prior to the commencement of works.

1. The proposed stack dominates views of the existing windmill from some locations. It is considered that the stack in its proposed location would have a     negative affect on the setting of the Protected Structure as the existing windmill will no longer be the focus of its setting. It is therefore important that the significance of the setting of the Protected Structure be given full consideration in terms of overall design and location of the proposed stack and windmill building. Consideration should be given to the re-location of the proposed stack to an area further away from the site of the existing windmill (ruin) in order to minimise the overall affect on the setting of the Protected Structure.

1. It is considered that by nature of its design and scale the proposed windmill structure will be visible in some locations.  The design of the structure and its dimensions fail to contribute to the existing landscape and provide a structure which is of poor architectural quality.  The proposed windmill structure looks completely alien to the existing landscape.  It is considered that the proposed new structure should be of a contemporary design using modern materials i.e. reflective surfaces that would blend into the existing landscape.  The new structure should be designed using architectural design and innovation of today. Full details are required to address those issues outlined above (Item 5 & 6).

1. In addition to the recommendations outlined above it is recommended that the mitigation measures provided in the Conservation Architects report (Appendix 14.2-Section 5) be adhered to in relation to re-use of Windmill House, outbuildings and associated features.

1. In relation to the archaeological features of interest that were identified during the Archaeological Assessment the following mitigation measures shall be adhered to:

(a)       It is recommended that advance archaeological investigations within the north-western environs of the windmill prior to the construction of the batter be conducted.  This will take the form of test trenching wit the aim of locating potential features and material of archaeological significance associated with the windmill and any earlier structures.  This work shall be carried out by a suitably qualified Archaeologist under licence in accordance with Section 26 of the National Monuments Act 1930, and with a method statement agreed in advance with the National Monuments Service (Dept of the Environment, Heritage and Local Government).  The results of this investigation will determine whether full archaeological excavation and/or monitoring are required.

(b)       It is recommended that archaeological monitoring be undertaken during all topsoil stripping associated with the development, including any associated roadwork’s, drainage works etc., with the provision for full excavation of any archaeologically significant material uncovered at this time.

Singed: ___________________________________ Date: 24/06/08

              Irenie McLoughlin, Conservation Officer