Ministerial guidelines
Architectural Heritage Protection: Guidelines for Planning Authorities
Protected structures, architectural conservation areas, curtilage, and works to historic buildings.
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- Architectural Heritage Protection Guidelines for Planning Authorities 229 CHAPTER 17 ALTERATIONS TO ENHANCE FIRE SAFETY resistance of floors, ceilings, walls and doors in a historic interior. Undivided roof spaces 17.6.3 Undivided roof spaces may exist not only between parts of a building but between different buildings in a terrace. It may be possible to deal with many of these concealed spaces by unobtrusively subdividing them. Upgrading historic walls, floors and ceilings 17.6.4 The fire resistance of existing timber walls or floors may require to be upgraded. This can be achieved by the addition of fire-resisting layers above, beneath or between existing studs or floor joists. The voids between studs or joists can also be filled with flame-resisting materials. There are a number of proprietary methods which have been developed for upgrading the fire resistance of floors which may be appropriate. Upgrading works should not involve loss or damage to important plasterwork on walls and ceilings or of historic floors. The applicant should be advised to explore alternative methods of satisfying the requirements of enhancing fire safety. Upgrading historic staircases 17.6.5 The removal or replacement of important staircases or parts of staircases should generally not be permitted. Alternative methods of meeting the requirements of fire-safety enhancement should be investigated by the applicant. Upgrading historic doors 17.6.6 Historic doors and doorcases are particularly vulnerable to inappropriate changes in order to achieve a specific fire resistance. Panelled doors have an inherent weakness in terms of fire resistance because of rebated panels. Traditional door details often include voids behind architraves which also lessen the effectiveness of a doorset to perform in the event of a fire. 17.6.7 Where an authentic door or doorcase of acknowledged quality or interest remains, efforts should be made to retain it in situ rather than replace it with a replica fire-resistant door. While a historic doorcase may not appear to meet a recognised standard of fire resistance, it nonetheless offers some degree of protection which might be acceptable in particular circumstances. Modest upgrading may be possible by using seals and linings or the application of intumescent paint or paper. Proposals to replace existing timber or glazed panels with alternative materials may not always be acceptable. The same is true of proposals to dismantle a historic panelled door in order to insert fire-resistant layers within the construction. There will generally be a visual and material impact on a building caused by encasing structural elements in fire-resisting materials. Alternative measures should be explored if these elements contain decorative detailing that would be disturbed or concealed by such work or if encased elements such as a timber floor, as shown here, or roof may become susceptible to fungal attack as a result of the treatment Decorative plaster ceilings can be upgraded by adding fireresisting layers between the joists, which should be carried out without loss or damage to the plasterwork, floorboards or structural timbers Increasing the fire performance of panelled doors may require a combination of methods. It can be assisted by work such as applying intumescent strips to the door and frame edges. The composition and condition of the door and doorset and presence of surviving historic door furniture, such as box locks or wrought iron hinges, should be examined in order to find the most appropriate solutions
- CHAPTER 17 ALTERATIONS TO ENHANCE FIRE SAFETY Architectural Heritage Protection Guidelines for Planning Authorities 230 17.6.8 Where the historic door is located within a thick wall, it may be acceptable to incorporate an appropriate fire-resisting door within the same structural opening whilst leaving the original door in place. 17.6.9 As a last resort, where a door cannot be brought up to required standards without unacceptable alteration, it may be appropriate that it be recorded and tagged before being carefully dismantled and safely stored in the building for possible reinstatement at a later date and an appropriate replacement door fitted. 17.6.10 Added elements of ironmongery required for fire protection, such as door closers, hold-open devices and the like, should be visually acceptable for the location. Concealed spaces 17.6.11 The presence of concealed voids or openings within the structure of an old building can make compartments ineffective. There may be interconnecting spaces behind panelling or wall linings or between floor or ceiling joists or there may be undivided roof spaces. 17.6.12 It may be possible to deal with many of these concealed spaces by unobtrusively subdividing them. Other situations will require a careful balance of other fire-protection measures in order to provide an acceptable solution. 17.7 External Fire Spread Roof coverings 17.7.1 Some protected structures have combustible roofcoverings such as thatch or timber shingles and alterations may be required to improve the fire resistance of such roofs. However, consideration should be given to the fact that flame-retardant treatments for thatch must be renewed regularly to maintain effectiveness and the chemicals used may damage the material or encourage its decay. 17.7.2 The replacement of historic or decorative glass with wired or other fire-resistant glass in rooflights and skylights should not be permitted. It may be considered acceptable to allow for fire-resistant secondary glazing to be used but only where this would not adversely affect the appearance of the original glass. Walls 17.7.3 The external walls of protected structures may be finished with combustible materials such as timber boarding, framing or shingles. Where these finishes form part of the special interest of the structure, proposals to enhance the fire resistance of such materials should not damage the fabric or appearance of these walls. 17.8 Access and Facilities for the Fire Service Sources of water for fire-fighting 17.8.1 Where a protected structure is sited in a remote location away from a mains water supply, consideration needs to be given to the necessity for an adequate water supply for fire-fighting. Where an application is received for works to such a building, the planning authority could consider, as a condition of permission, the provision of waterstorage tanks or otherwise adjacent to the protected structure. The appearance and siting of such water storage should not adversely affect the character of the protected structure or of an ACA. Consideration should be given to upgrading, or improving access to, existing water features located adjacent to the building such as ornamental lakes or fountains, which could serve as water sources. Alternatively, underground water-holding tanks could be provided where the construction of these would not disrupt important areas of hard landscaping or gardens. Small and unobtrusive door closers and hold-open devices are available, which should be used if standard ironmongery specifications would be unacceptable due to the visual and physical impact on the interior and its elements Where a door lining can accommodate a second door without requiring intrusive visual or physical alterations, the provision of an appropriately detailed fire-resisting door can be an acceptable method of upgrading the opening. In this example the new door is to the left in the photograph
- Architectural Heritage Protection Guidelines for Planning Authorities 231 CHAPTER 17 ALTERATIONS TO ENHANCE FIRE SAFETY Vehicle access 17.8.2 A range of compensating measures are considered appropriate under TGD-B where it is not possible to provide sufficient access for the fire service to existing buildings. These measures could include additional personnel access to the building for firefighting, additional internal fire mains and other facilities to assist fire-fighting. These requirements should be resolved in consultation with the fire authority. 17.9 Management Fire prevention measures 17.9.1 In the case of fire damage to protected structures, prevention is obviously better than cure. No matter how well reinstatement works are carried out, lost historic fabric is gone forever and can only be replaced in replica. Under Section 18 (2) of the Fire Services Act 1981 it is the duty of the persons in control of a number of specified building types to take all reasonable measures to guard against the outbreak of fire on such premises. However, a planning authority may have little opportunity to input into the operational practices that are undertaken in the management of a protected structure. The owners and occupiers of these buildings should be encouraged to take certain steps in order to prevent their building becoming endangered by fire. Such steps might include the preparation of a regularly monitored fire-safety plan. 17.9.2 A fire risk assessment should be carried out for the protected structure. This would be most useful in advance of preparing a detailed planning application. The likelihood of fire can be reduced by the identification of risks and their elimination or by the management of those which cannot be eliminated. Common causes of fire in protected structures include electrical faults, building or renovation work, arson and accidental fire from hearths, smoking, kitchens and the like. Many of these causes can be eliminated or minimised by the adoption of certain operational procedures such as banning smoking in or around the building or adjacent to flammable material such as thatch, the use of ‘hot work’ procedures during refurbishment work and the storing of combustible materials within the building. Staff training, where appropriate, should include maintenance and testing techniques as well as preparation for emergencies. Lightning may be a possible danger, particularly to large isolated structures. Where appropriate, these structures should be protected with earthed lightning-conductors. 17.9.3 Some of these matters could be dealt with as conditions of planning permission for works to protected structures. Lightning conductors may be a requirement on tall or otherwise vulnerable structures. The conductors should be channelled to earth unobtrusively; this example shows a discreetly coloured lightning conductor carefully concealed behind a downpipe
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- Architectural Heritage Protection Guidelines for Planning Authorities 233 CHAPTER 18 IMPROVING ACCESS 18.1 Introduction 18.1.1 It is accepted that there should be easy access to all buildings for people with disabilities. The need to provide access is implied by the Employment Equality Act 1998 and the Equal Status Act 2000 and new requirements will be included in forthcoming disability legislation. In the case of a material alteration, regard must also be had to the need to make adequate provision for access as required by Part M of the Building Regulations 2000. 18.1.2 Careful consideration will be needed in the context of the architectural heritage, requiring innovative solutions and a degree of compromise from all sides. A fair balance will need to be struck between accessibility and the preservation of the special qualities of a protected structure and its setting or of an ACA. Improving access to a historic building will require a creative approach and flexibility on the part of owners, architects, planning authorities, building managers, users and others. 18.1.3 The goals of improving access to an existing building are those of independent access and of integrated access. That is, people should be able to move independently with ease and dignity into and around the building, use the building as intended and exit the building safely in case of emergency. Ideally the access routes for all users should be the same. Meeting these goals will present some of the most challenging issues faced in the alteration of historic buildings but, in some cases, adaptation may be essential to ensure the continued use and viability of a building. 18.1.4 Where it is proposed to improve access to a protected structure, the ability of the building and its setting to meet this requirement must be carefully assessed. If the application of universal design principles and measures to improve accessibility are likely to cause major problems and lead to unacceptable alterations of the character and fabric of the protected structure, the onus should be on the applicant to show that consideration has been given to exploring all possible options for enhancing the accessibility of the protected structure and its site. Applicants should actively seek innovative solutions and good designs which minimise intervention into the historic fabric. 18.1.5 The ideal solution would minimise the alteration of original or fine building fabric and avoid works which would have an adverse impact upon the character of the exterior or interior of the building, whilst meeting the goals of improved access. The reversibility of proposals is an important conservation principle but should not be used to justify inappropriate interventions. Where barriers to access are found to exist, ways should be sought which avoid the obstacle rather than make alterations to it. For example, where a flight of stairs inhibits access to the upper floors of a building for some users, a lift installation could be considered. When intervention is unavoidable, permitted proposals should minimise the loss and alteration of the historic fabric and protect the architectural integrity and special interest of the protected structure. Unnecessary change should always be avoided. 18.1.6 It should be realised that there are some protected structures or groups of buildings within ACAs whose architectural qualities or rarity are such that they should not be compromised and it may have to be accepted here that full and easy access for all is not possible to achieve. For example, a Georgian terraced house which is separated from the street by a sunken area surrounded by stone plinths and iron railings and accessed by a flight of stone steps, Modern interventions can be acceptable where they use high-quality design and materials. Such work can address the needs of the users while respecting the architectural quality of the structure
- CHAPTER 18 IMPROVING ACCESS Architectural Heritage Protection Guidelines for Planning Authorities 234 may require excessive alteration and loss of historic fabric in order to provide access for wheelchairs. There may be an unacceptable loss of character or damage to the special interest not only of the individual building but also the terrace, street or square in which it is located. However, even in these cases, opportunities may nonetheless exist to improve access for the broader spectrum of disability. While it may not be possible to provide wheelchair access to a particular building or site, the provision of handrails or easily negotiable surfaces would still improve access for a larger number of people. 18.1.7 Where it is found not possible to make adequate provision for access and use of a building in accordance with the requirements of the Building Regulations, it will be necessary to receive a dispensation from, or relaxation of, this requirement from the Building Control Authority before commencement of the works. 18.2 Entering the Building 18.2.1 The conflict between improving access and the conservation of a historic structure is often most difficult to resolve at the entrance to the building. This is particularly so where there is a need to provide access to wheelchair users. Ideally, the principal entrance should be accessible to everyone, but compromise may be needed in sensitive cases. 18.2.2 Past styles of architecture have featured an impressive entrance approached by steps. Even humbler buildings had one or more steps up to the level of the ground floor for sound practical reasons such as preventing the ingress of water. There may exist several alternative means of improving the accessibility of an entrance. External ramps, lifts and steps 18.2.3 Sometimes a well-designed and sensitively sited ramp may be the easiest way to achieve access for wheelchair users. Permanent, integrated ramps of a sympathetic design and materials should be encouraged. However, when dealing with buildings or ACAs of high architectural quality or rarity, the installation of an access ramp against the façade of the building may not be an acceptable solution, particularly where a ramp would destroy the balance of a symmetrical or harmonious façade or damage significant architectural features. Where this is the case, the planning authority should encourage the applicant to explore alternative or more innovative solutions. The traditional Georgian terraced house with a basement area to the front can present problems with regard to improving access. Alterations to provide a ramp can result in the loss or disruption of historic fabric such as stone plinths, iron gates and railings and can compromise the natural ventilation and lighting of basement rooms. Traditional buildings almost always include one or more steps at the entrance, which may be important to the composition of the entrance and make a contribution to the character of the structure in the way they have worn through use over several generations. In the example shown here, the narrow double-leaf door would also cause difficulties for some disabled users but is essential to the character of the entrance
- Architectural Heritage Protection Guidelines for Planning Authorities 235 CHAPTER 18 IMPROVING ACCESS 18.2.4 Wheelchair platform lifts can be visually intrusive, although it may be possible to incorporate them sensitively within an existing porch or portico. 18.2.5 Proposals which require the demolition or partial removal of stone steps, balustrades, or other important features will not always be acceptable and should be carefully considered. However, in some cases, it may be appropriate to allow the alteration or partial removal of steps, iron railings or plinths to allow access to wheelchair platform lifts or ramps. Where this type of alteration is proposed, the planning authority should take into account the significance of the relevant building elevation and the quality of the elements proposed for alteration. 18.2.6 It should be borne in mind that while a ramp may be needed to facilitate wheelchair access, it should be supplied in addition to steps. Users with ambulatory disabilities may have difficulties in using ramps. Re-grading the external ground level 18.2.7 Where the differences in level are small, it may be possible to re-grade the ground immediately in front of the entrance, provided this does not result in the unacceptable visual loss of parts of the building’s plinth or base and does not involve the loss of important paving or other surfaces. Regrading will not usually be an option in an urban context where entry is directly off a street. Temporary facilities for wheelchair access 18.2.8 Occasionally the installation of a permanent ramped access may be considered inappropriate to the special character of the protected structure or of an ACA. In such cases, the provision of a temporary access ramp may be considered. In some particularly sensitive locations, the decision may be taken to allow the provision of a temporary ramp, constructed in compliance with current safety and health regulations, which is erected and dismantled by trained staff when required. The storage of such facilities should be given careful consideration. The ramp must be at hand when required, but should not obstruct access or cause unsightly clutter around the protected structure. Access ramps against the façade of a building can conflict with or obscure important architectural features such as stone plinths. While a ramp may be physically separated from the masonry by a barrier to allow its removal without damage, the visual impact still needs to be resolved A well-designed platform lift of a sympathetic design using high quality materials, and provided in addition to, and not as a replacement for, steps may be acceptable. However, alternative solutions may have to be explored where a symmetrical or harmonious composition would be unbalanced or damaged by the addition of a ramp The option of re-grading the ground adjacent to an entrance could be considered where the difference in levels is small, where the raised level would not conceal architectural details, where there is no loss of historic pavement and of course where sufficient ground is available to create a gentle gradient
- CHAPTER 18 IMPROVING ACCESS Architectural Heritage Protection Guidelines for Planning Authorities 236 18.2.9 The use of temporary ramps is rarely preferable to an appropriately designed permanent access, as they are not compatible with independent access. But they may occasionally be a necessary expedient. Generally the design and location of such ramps should be chosen with equal care as a permanent installation and the temporary nature of the facility should not excuse inappropriate schemes. For access routes or part of routes that are subject to material alteration, reliance on temporary ramps will not normally satisfy the requirements of the Building Regulations. Secondary entrances 18.2.10 Buildings such as narrow terraced houses and others will often not have the space necessary for an acceptable ramp to the principal entrance. It may be difficult to find an appropriate location for a wheelchair platform lift which would not involve undue loss or alteration of features such as railings, walls and steps. 18.2.11 In some cases, it may be possible, by means of careful design, to reorganise the internal spaces of some buildings so that access can be achieved through the adaptation of a secondary entrance. Ideally, where a second entry point is adapted to provide access for disabled users, it should also become the access point for all the building users. However this will cause difficulties where the new access route affects the appreciation of the building’s plan form or a carefully designed succession of rooms. 18.2.12 In some cases, it will not be possible to improve access through the primary entrance without inappropriate levels of disturbance and damage to the historic fabric of the building or to the character of an ACA. In such cases it will have to be accepted that a separate entry point be provided. Car parking 18.2.13 Ideally, dedicated car parking for visitors with disabilities should be provided at a location easily accessible to the entrance. This may have implications for the character and setting of a protected structure. Generally, on larger sites, car parking is often deliberately sited away from a protected structure in order to avoid impacting upon its immediate setting. In these cases, it may be necessary to permit separate dedicated parking nearer to the structure for users with disabilities. If this is not possible, suitable setting-down points for visitors may be an option. A demountable ramp has the advantage of being readily reversible. In these examples no alteration of the existing historic fabric has been made. Even where a ramp is demountable, its design and location should be given equal consideration to a permanent installation Dedicated parking spaces adjacent to an entrance may be easily provided in some urban contexts where on-street parking is already provided. In other situations, the design or identification of suitable setting-down points may be necessary In some cases, it will not be possible to provide access for all users through the main entrance and the provision of a secondary entrance will be an acceptable compromise
- Architectural Heritage Protection Guidelines for Planning Authorities 237 CHAPTER 18 IMPROVING ACCESS 18.2.14 The surface treatment of the parking areas should be appropriate in texture and colour to the location and should not damage the setting of the protected structure. 18.3 Circulation within the Building and Egress 18.3.1 Circulation within a protected structure can cause problems for certain users, particularly vertical circulation between floors and changes of level within a floor. When considering applications for alterations to improve access to a protected structure it must be borne in mind that adequate provision must also be made for emergency egress. Circulation between floors 18.3.2 The most effective means of providing for circulation between floors is a passenger lift. However, a lift, and machinery associated with it, can be unacceptably obtrusive in a historic interior. Proposals to install lifts in protected structures will need to be carefully considered on a case-by-case basis. 18.3.3 Care should be taken with such proposals to ensure that the installation of a lift shaft would not damage interior work of quality and that the associated machinery can be satisfactorily accommodated within a basement or within a roof space. In some cases, it may be more acceptable to locate a lift external to the existing structure but this may involve the alteration of existing openings or the formation of new ones. A lift which requires the remodelling of the roof profile of a protected structure should rarely be permitted. Hydraulic lifts could be considered as an alternative to conventional lifts where the location of lift gear above the roofline would be considered inappropriate. 18.3.4 Where the installation of a passenger lift is not possible, alternative means of providing vertical circulation, for example, wheelchair stair lifts or platform lifts, may be acceptable. In assessing the suitability of platform lifts, regard should be had to the acceptable maximum height of travel for such lifts. Innovative solutions, combined with high quality design and materials, can avoid conflicting with existing features while adding to the richness of a historic interior There will be cases where the character of a building or area is so sensitive to change that it will not be possible to alter it to provide independent access. In such cases a managed solution should include a clearly-signed contact point and appropriately-trained staff to assist
- CHAPTER 18 IMPROVING ACCESS Architectural Heritage Protection Guidelines for Planning Authorities 238 18.3.5 The principal staircase of a protected structure, and often the secondary staircase too, are usually significant architectural spaces within the building. It will often be difficult or impossible to alter such principal staircases to fit mechanical devices such as wheelchair stair-lifts without adversely affecting the special qualities of the space and damaging the historic fabric. Where this is the case, it may be considered more appropriate to install a wheelchair stair-lift on a secondary staircase. Changes of level 18.3.6 Changes of level may occur within a historic building. Minor changes can be overcome by the sensitive location and detailing of ramps, although careful consideration will be needed where ramps would conflict with important details such as plinths, skirtings, panelling and architraves. The minimum possible disturbance should take place to historic floors and any permitted works which impact on important fabric should be readily reversible. It must also be remembered that ramps can be unsuitable and potentially dangerous for a large number of people with ambulatory difficulties and so their use can be inappropriate. 18.3.7 Platform lifts can be used to overcome changes in level and may be preferable to a ramp where the difference in level is relatively large. However, the appearance of these devices can be obtrusive in sensitive interiors. Where a platform lift is to be installed, the installation should not involve the demolition or alteration of parts of important stairs or landings and the works should be readily reversible. Emergency egress 18.3.8 It is important that the applicant adequately address the need for emergency egress for the disabled user. This may require alterations to the historic fabric of the building. Where there is access to upper floors of a protected structure for users with disabilities, there may be a requirement for the provision of refuge areas, alternative escape stairs, fireman’s or evacuation lifts, and the like. Consideration must be given to how these will impact on the character and fabric of both the interior and exterior of the protected structure and, where relevant, the character of an ACA. 18.3.9 Where the impact of the requirements for emergency egress would require unacceptable alterations which would adversely affect the character of the protected structure, the planning authority should encourage the applicant to seek alternative, more appropriate solutions. 18.4 Surface Finishes 18.4.1 The surface finishes of ramps and pathways are of great importance to people with mobility impairment and the finish chosen should satisfy safety requirements. The type of finish can also have a considerable impact on the protected structure and its setting. Where new surface treatments are to be installed, the texture and colour of materials should be appropriate to their location and to the requirements of all users. 18.4.2 Traditional finishes such as cobbling, setts and gravel can be unsuitable for wheelchair movement, the movement of children’s pushchairs and ambulant people with varying levels of mobility. Where these surface finishes exist within the setting of a protected structure or in an ACA, efforts should be made to provide accessible routes through them with a minimum disruption to the historic landscaping. Accessible routes can be provided by replacing part of the existing surface with paved pathways of a complementary material, such as stone flags. Short routes across cobbling or setts can be made accessible by increasing the amount of mortar in the joints to prevent the trapping of wheels. This solution can have a large impact on the appearance of the hard landscaped surface and may not always be appropriate. Stair lifts can be obtrusive when used in a historic context, even where the stair contains just a few steps. If the special interest of a staircase or flight of steps would be adversely affected by the visual and physical impact of such an installation, alternative solutions should be explored
Source Department of Arts, Heritage and the Gaeltacht: Architectural Heritage Protection: Guidelines for Planning Authorities (2011) · Licence the publisher's termsText read from the publisher’s PDF; tables, maps and drawings do not survive as text, and page numbers are the PDF’s (its first page is 1). Check the original before relying on a passage.