This response is in reference to the development proposals presented at public exhibitions in the MAC on 14th, 27th and 28th February 2017, and on the website belfastcitycentreregen.com (accessed Friday March 31st, 2017).
Community Arts Partnership
Community Arts Partnership is an independent advocate and delivery organisation for community arts and offers the widest possible range of assistance and opportunity to get creative and engage in community-based arts activity throughout Northern Ireland.
Our mission is to take the lead in the promotion, development and delivery of community arts practice, to affect positive change, and our vision is to see the emergence of a just, inclusive, peaceful and creative society, where difference is welcomed and participation is valued.
We have a two-fold approach to arts development: firstly, we support access and participation by seeking to affect policy through advocacy and leadership and secondly, we promote authorship and ownership through the active engagement in projects and programmes.
Advocates
Beyond our immediate aims and objectives, Community Arts Partnership locates in the Cathedral Quarter of Belfast City Centre and both now, and in a previous orientation, as New Belfast Community Arts Initiative, the organisation has been at the centre of working towards the regeneration of this area of Belfast.
Our organisation has been central to suggesting, advocating on behalf of, working within, and building initiatives in the area for nearly two decades.
We were part of the initial drive to establish Culture Night, now one of the largest events in Belfast’s festival calendar and our chief executive is its founding co-director, as indeed he was a founding member of the Let’s Get It Right campaign, the Cathedral Quarter Steering Group and the Cathedral Quarter Trust.
We have brought creative opportunity to the disenfranchised, whether economically, socially or through ethnicity, sexuality or religious orientation, and our offices have been a beacon for those looking to engage creatively.
Our new Arts Resource Centre (ARC) in CQ, has broadened even further our potential to offer further opportunities for those whose access to the arts and artistic activities is severely limited.
Assembly Rooms
Community Arts Partnership has always been at the forefront of arguing that the Arts generally and Community Arts particularly, enhance the quality of life of all our citizens.
We have campaigned for regeneration of the Cathedral Quarter, submitting proposals for the development of the Assembly Rooms into a Community Arts and Cultural Centre over a decade ago, seeing even then the potential for the area as a vibrant hub of creativity and an area which could, with an arts lead orientation, develop economically. We have consistently argued for investment and the redevelopment of the area.
Disappointed
That is why we are so disappointed in the present plan for redevelopment. To us it seems inconceivable, knowing the history of the area and our own role in its development, that there is no provision for a cultural plan, or dedicated space with regards the Arts and Creative Industries.
Although previously a keystone of the NE Quarter Masterplan of DSD Belfast City Centre Regeneration Office, there is now neither a commitment to arts provision nor indeed even the name that has become synonymous with the arts locally, namely Cathedral Quarter itself, replaced instead by the singular commitment of providing retail space for up-market retailers and hotel and office space thereafter, with scant provision of homes and even then none fitting the profile of this area.
Concerns
A major concern is that this redevelopment will result in the loss of built character and cultural function, and that it threatens the displacement and destruction of a thriving ecosystem of small arts and cultural organisations, and the businesses that depend on them.
As an office and retail-led development, this proposal is entirely unsuitable for the proposed site.
Belfast has large amounts of empty land suitable for office development. In addition, the Linen Quarter, south of City Hall, has been identified as a priority area for office development (Belfast City Centre Regeneration and Investment Strategy 2015; Linen Quarter Vision and Guidance 2015).
Belfast’s central retail core – the area north of City Hall encompassing Donegall Place, Royal Avenue, Castlecourt, and Victoria Square has a 17% vacancy rate.
Equally important, there is nowhere else in the city like the Cathedral Quarter. It is unique both in terms of its built heritage, but also in the kinds of activities that have found their home there.
It has enormous potential to be the creative engine of Northern Ireland’s new economy, driving an arts and cultural renaissance, incubating independent businesses, and drawing in tourists who want an authentic urban experience.
This proposed development will be detrimental to that potential. Put simply, it is the wrong kind of development, in an unsuitable location.
Community Arts Partnership is not opposed to development and our organisation is wholly in favour of investment in the area, but it should be sensitive to the heritage, history, architecture, and reputation of the area, and serve the interests of the city.
Community Arts Partnership objects to the proposal specifically on the following grounds:
Proposed demolition of buildings on North Street and Donegall Street
Policy Reference: PPS6 BH14, Demolition in a Conservation Area
The proposed development is uniquely situated between two conservation areas; the Cathedral Conservation Area and the City Centre Conservation Area. This requires careful thought when proposing new development, although it is also worth highlighting that this also presents opportunities and should not be viewed as an impediment to development.
The Cathedral Conservation Area Guide opens with the following statement:
“Conservation Area status provides a framework and a theme for the promotion of the area”
Cathedral Conservation Area Guide, pg.2
The proposed scheme must embrace the proximity to these two important conservation areas and strengthen, not detract, from the historic value created by these two areas.
Planning policy clearly states that:
“The Department will normally only permit the demolition of an unlisted building in a conservation area where the building makes no material contribution to the character or appearance of the area”.
A number of unlisted buildings proposed for demolition make a positive material contribution to the character or appearance of the area and should be sensitively incorporated into the scheme.
Sitting within two Conservation Areas the scheme should make a positive contribution to the special character of the area.
It is important to note that this area of the city, primarily dating from the 18th-20th century comprises a historic street pattern with buildings of traditional scale, grain and appearance. This must be preserved and enhanced.
Planning legislation requires that in Conservation Areas “special attention shall be paid to the desirability of preserving and enhancing its character or appearance”.
The Cathedral Conservation Area Guide states that:
“Developers will have to satisfy the Department that conversion and refurbishment of a building is not economically viable before redevelopment is considered. The Department will also encourage the retention where possible, of characteristic Victorian facades which are important in the street scene”.
Cathedral Conservation Area Guide, pg.29
What evidence has been presented that conversion or refurbishment is not economically viable? It is noted that many of the buildings proposed for demolition are occupied by profitable businesses paying rent and rates.
Scale, form, massing and height of proposed new buildings
Policy Reference: PPS6 BH11, Development affecting the Setting of a Listed Building
The proposal does not respect the setting of listed buildings in terms of scale, form, massing and height. The setting of St Anne’s Cathedral at Donegall Street and the former Assembly Buildings at Four Corners would be negatively impacted by the proposed development due to inappropriate height, scale and massing.
Writers Square
It is well documented that Belfast City Centre lacks useable open spaces (Belfast City Centre Regeneration and Investment Strategy 2015). Reducing the size of Writers Square by nearly half, as proposed, is counter to current strategy to increase the provision of useable city centre public spaces. If, as proposed, Donegall Street remains open to some vehicular traffic in front of St Anne’s Cathedral, and buildings are built on part of the existing Square, the actual useable space will be significantly reduced.
Significantly reducing the scale of Writers Square whilst also proposing 9-storey buildings abutting the space would be hugely detrimental to the setting of the listed St Anne’s Cathedral.
The proposed 9-storey building in front of the Cathedral (between Writers Square and North Street) dominates the setting of the listed Cathedral. The proposed building is not related to proposed reduced scale of Writers Square and will be over-bearing on the space.
The proposed building fails to take account of the Cathedral Conservation Area Guide which states that within the Cathedral Environs:
“Building heights should be related to the proposed open space area [Writers Square],to the heights of adjoining buildings and to the existing street scene”.
Cathedral Conservation Area Guide, pg.30
The proposed building also fails to comply with Belfast’s adopted Development Plan, which designates the area as a Character Area (Designation CC 010 – Scotch and Cathedral Quarters). The plan states that:
“Development proposals shall take account of the height of adjoining buildings … Building heights shall be a minimum of 3 storeys and a maximum of 4 storeys … or 5 storeys with use of setback.”
Belfast Metropolitan Area Plan
The proposed building height is inappropriate and the bulk, massing and scale are detrimental to the setting of St Anne’s Cathedral and Writers Square.
No shadow study to evaluate the potential impact of this building on the quality of Writers Square has been provided.
Proposed Tower (junction of North St, Rosemary St, Bridge St)
Referring to The Four Corners, the Cathedral Conservation Area Guide states that:
“The general height and mass of new buildings should be in scale with surrounding buildings … [and] … development should generally be at least three-storey in height and not exceed a maximum 15m eaves height”.
Cathedral Conservation Area Guide, pg.32
The proposed tower sits at the important Four Corners junction. At 24+ storeys the proposed tower fails to comply with the Conservation Area guidance.
The BMAP Urban Design Supplement describes that:
“[A] key consideration in determining building height is to identify the qualities we want to achieve in the city streets and spaces. For example, on many of the key streets, a vibrant, mixed use culture is generally promoted, enlivened by outdoor cafes and dining areas. To achieve these objectives, the street needs to be attractive and welcoming, with an appropriate micro-climate. In this regard, the extent of sun penetration into the street is a key consideration”.
BMAP Urban Design Supplement, pg.10
The proposed tower building will not create a quality streetscape or an appropriate micro-climate. The proposed building would for much of the day prevent sun penetration onto North Street and would result in shadow being cast on North Street, Four Corners and the listed former Assembly Buildings.
No shadow study to evaluate the potential impact of this building on the surrounding area has been provided.
The Four Corners is an important public space, hosting the city centre’s oldest civic building, and is the commercial and civic heart of the old town of Belfast. The proposed tall building is completely inappropriate at this location.
Inappropriate Bulk, Scale and Massing
Development shall be fine grain in nature, and aim to reflect traditional plot widths.The fac¸ade of larger development proposals shall be broken up visually to reflect the scale of traditional units – subdivision of block into 4 to 2 buildings.
Belfast Metropolitan Area Plan
The proposal is out of scale and does not respect the historic urban grain of the area. The proposed buildings located between Writers Square and North Street, and behind Rosemary Street Church are inappropriate in bulk, scale and massing.
Building Heights
Proposed building heights are inappropriate and do not take account of the existing urban environment, particularly the many listed buildings. Belfast’s adopted Development Plan designates the area proposed for development as a Character Area (Designation CC 010 – Scotch and Cathedral Quarters). The plan states that:
“Development proposals shall take account of the height of adjoining buildings … Building heights shall be a minimum of 3 storeys and a maximum of 4 storeys … or 5 storeys with use of setback.”
Belfast Metropolitan Area Plan
It is noted that building heights at important listed buildings (St Anne’s Cathedral and Rosemary Street Church) range from 7 – 9 storeys. The proposed buildings therefore fail to comply with BMAP. The proposed buildings also fail to take account of the Cathedral Conservation Area Guide which states that within the Cathedral Environs:
“Building heights should be related to the proposed open space area [Writers Square], to the heights of adjoining buildings and to the existing street scene”.
Cathedral Conservation Area Guide, pg.30
Basement Car Park Proposed Entrance/ Exit (Donegall Street)
Proposed location of entrance and egress of double-storey basement carpark at Buoy Park is unsuitable as it creates an obstacle to safe pedestrian flow from Royal Avenue to the Ulster University campus. The proposed location would require pedestrians to cross 6 lanes of traffic to and from the campus. The outline application provides no information on vehicle paths, or on its impact on the University’s transformation. A move of the exit to North Street would do little to mitigate this impact, and will simply extend the problem to another part of the site.
Building Uses
“The … Enhancement Strategy within the Cathedral Conservation Area … aims to … encourage a variety of new land uses including offices, small scale retailing, cultural and recreational”.
Cathedral Conservation Area Guide, pg.16
The proposed development will cause significant harm to existing businesses, traders, and organisations currently occupying the site. Particularly impacted will be the small independent traders of North Street and Donegall Street.
Lower North Street currently has a 71.8% occupancy rate of ground floor units, 65% of which are independent traders; Donegall Street Lower has an 86% occupancy rate of ground floor units, 76% of which are independent (source: Belfast City Centre Vacant Units Report January 2017). These traders are paying rents and rates and are contributing to the Destination CQ BID.
Proposed plans should accommodate these traders through the retention and restoration of existing buildings.
Arts and Culture
The Cathedral Conservation Area Guide states that:
“Developers will have to satisfy the Department that conversion and refurbishment of a building is not economically viable before redevelopment is considered” (pg.29).
The Cathedral Quarter has emerged since the 1990s as one of Northern Ireland’s most vibrant cultural hubs. It is supported by its proximity to the art college, the city centre, and larger cultural organisations, such as the MAC. It survives and thrives because of the availability of smaller, low cost retail and office units.
It is home to dozens of small businesses, cultural organisations, artists’ studios, galleries, and venues. This essential cultural infrastructure supports Northern Ireland’s regional cultural offering, gives the city its unique character, and makes it an attractive destination for national and international visitors. This delicate ecosystem is impossible to replicate elsewhere in the city, and it will be devastated by the proposed redevelopment, which will likely lead to significant harm in terms of economic activity, tourism, and the loss of livelihood.
Conclusion
CAP is not opposed to redevelopment per se, but wishes to lodge its strongest objection to a scheme that does not sensitively reflect the ambitions, reality or achievements of our vibrant cultural and creative Cathedral Quarter nor recognise the inherent wealth of our authentic, invaluable, historic city core, the very foundation of our capital at the physical intersection from which we derive the city’s name – the mouth of the Farset – Beile Feirste – Belfast.
Learn more about #SaveCQ, the campaign to save Belfast’s Cathedral Quarter, at the following links (and in the pages of the Weekly)
www.savecq.wordpress.com
twitter.com/hashtag/saveCQ
www.facebook.com/saveCQBelfast
