Planning submission on the Cobblestone
27 October 2021
We have submitted the following planning observation to Dublin City Council in relation to the proposed development of a hotel on 77-80 King Street North, Smithfield, which includes the Cobblestone Pub.
RE: Planning Application 3617/21 in respect of
77-80 King Street North, Smithfield, Dublin 7
To whom this may concern,
I write to oppose this planning application on the grounds set out below:
1) Breaches of the City Development Plan
This proposed development constitutes several clear breaches of the Dublin City Development Plan 2016-2022.
The City Development Plan represents the clearest articulation of an agreed vision for Dublin City. It has been democratically approved by Dublin City Councillors and offers a considered, coherent guide for the future development of this city.
The goals set out in the City Development Plan should not be disregarded without serious consideration and an overwhelming public interest reason to do so. I would contend that the construction of a hotel, as in this case, would not meet the criteria for setting aside the requirements of the Development Plan.
1.1 Purposes of Zone 5 zoning
This site is designated as Zone 5 (Z5), the purpose of which is to “sustain life within the centre of the city through intensive mixed-use development” and to provide “a dynamic mix of uses which interact with each other, help create a sense of community, and which sustain the vitality of the inner city both by day and night.”
This proposal would violate the purpose of Z5 designation by reducing the cultural space within our city centre, particularly its night-time culture, and by facilitating an over-concentration of hotel development within the area.
1.2 Over-concentration of hotels
The over-concentration of hotels within the North Inner City has already been recognised and lamented by Dublin City Council. Permission for new hotels have recently been rejected on this basis, as occurred with Planning Case 2021/21 (Francis Street) and 3609/20 (Capel Street).
The Planner’s Report for the proposed Capel Street development in particular identified an over-concentration of hotel developments within the North Inner City “which could fundamentally undermine the mixed-use ethos for this portion of the city centre, as set out in the Dublin City Development Plan.”
This proposal would represent the third hotel development on Smithfield Square alone: a clear breach of the stated need for “a dynamic mix of uses” to sustain the vitality of the inner city.
1.3 Site density and height limitations
The zoning for this site establishes a clear limit of 90% as regards density. However, the proposal represents a site density of 98% - clearly and substantially in excess of the maximum.
Furthermore, the area in which this development is proposed is not identified by the City Development Plan as suitable for new high-rise development. On the contrary, Smithfield’s existing height limit of 28 metres would be exceeded under this proposal.
While each of us will have different views on the ideal height and density of Dublin City, there exists a clear mechanism by which these decisions can be taken. The height limitations of Smithfield and other areas should be respected until and unless they are changed through amendment of the City Development Plan.
1.4 Plot ratio
The proposed plot ratio for this site is 6.4, which far exceeds the advised plot ratio of 2.5-3 set out in the Dublin City Development Plan.
Approving a plot ratio substantially more than double the maximum set out in the City Development Plan would represent an alarming disregard for the Plan tantamount to abandoning its purpose entirely.
2) Impact on Protected Structures
This proposal directly impacts on three Protected Structures: numbers 77, 80 and 81 King Street North (RPS_4263, RPS_4264 and RPS_4265, respectively), each of which will be totally overwhelmed by the scale and sheer incongruity of the new construction.
Objective 17 of the National Planning Framework (NPF) commits us to “enhance, integrate and protect the special physical, social, economic and cultural value of built heritage assets through appropriate and sensitive use”; goals which cannot be met through the construction of a nine-story hotel atop and overlooking these Protected Structures.
In the case of Number 77 (the Cobblestone Pub), the proposed hotel development would completely swallow up the existing building within an enormous, unrecognisable new structure of a completely different design. This same design would also fail to appropriately incorporate the structure at Number 80 and visually dominate the neighbouring structure at Number 81.
Furthermore, the overbearing presence of a hotel and the related reduction in floorspace available to the Cobblestone Pub would significantly reduce the ability of the structure to function as a cultural asset. Such a profound change to the nature of this building would unquestionably violate the NPF’s requirement for “appropriate and sensitive use” of these structures.
3) The Cobblestone Pub as an Invaluable Cultural Asset
The Cobblestone Pub is a well-known cultural asset within the North Inner City, and has a deep, intangible value to the heritage of the area. The Cobblestone has long served as a unique venue for live traditional music and a hotspot for the promotion of Irish language and culture within our capital city.
There can be no doubt that this proposal will fatally undermine the ability of the Cobblestone Pub to continue functioning in its existing cultural role in the area. These plans involve the total loss of the Backroom music venue and the Cobblestone outdoor area. This loss of floorspace, coupled with the total absorption of the Cobblestone into the structure of a large hotel will fundamentally and irreversibly change the cultural character of the institution.
The deliberate destruction of an invaluable cultural asset within a Protected Structure would nakedly contravene numerous policies to which Dublin City Council is subject, including:
The Dublin City Development Plan 2016-2022:
- CHC24: To ensure the continued development of Dublin as a culturally vibrant, creative and diverse city with a broad range of cultural activities provided throughout the city, underpinned by quality cultural infrastructure.
- CHC29: Dublin City Council will seek insofar as possible to protect the cultural and artistic use of buildings in established cultural quarters.
- CHC34: To support and promote opportunities for everyone to participate in the city’s cultural life by facilitating the provision of effectively-managed, self-sustaining cultural infrastructure suitable for all ages at the neighbourhood level, including regeneration areas, that is accessible to all in the locality and reflects the identity of Dublin’s neighbourhoods.
The National Planning Framework:
- National Policy Objective 17: Enhance, integrate and protect the special physical, social, economic and cultural value of built heritage assets through appropriate and sensitive use now and for future generations.
The Regional Spatial and Economic Strategy for the Eastern and Midlands Region:
- RPO 9.24: Promote and facilitate the role of arts and culture in recognition of its importance to people’s identity and the potential for economic development through a unique cultural tourism offering throughout the Region.
- RPO 9.25: Seek to work with all relevant stakeholders to promote equality of access to and engagement with arts and cultural services and in the promotion of culture and heritage led urban and rural regeneration.
The Dublin City Local Economic and Community Plan 2016-2021:
- High Level Goal 6: Maximise opportunities and support for the creative industries and cultural and artistic sectors to develop. Promote the Irish language and access to cultural experiences for all through the provision of diverse cultural artistic programming.
Any development which substantially restricts the cultural activities of the Cobblestone Pub, as this proposed development will certainly do, with no proposals to ensure the continuation of these cultural activities at this or at any other location, could only be taken in violation of the policies listed above.
Preserving and enhancing the cultural character of our city requires careful safeguarding and stewardship of cultural institutions of all kinds, particularly those which may be threatened by commercial decisions such as the construction of new developments. It is strongly incumbent upon all of us to ensure that Dublin retains those cultural spaces without which the soul of our city simply would not be the same.
I submit that the Cobblestone, a unique space for traditional music, the Irish language and cultural activities within the North Inner City, represents such a cultural landmark and must be protected accordingly.
For this and the other reasons detailed above, I urge that this Planning Application be refused permission.
Senator Marie Sherlock
Labour Party Spokesperson on Arts and Culture