Retention application for unauthorised development at Tailors Hall???

A touch of Schadenfreude there?

Well, schadenfruede is enjoyment obtained from the troubles of others.

I am more exercised by what appears to be the double standards of others, especially as they style themselves as ‘Ireland’s National Heritage Organisation’.

Heaven forbid that arguments about crass commercial considerations (such as revenue which would be lost if an unauthorised use was refused permission – -in this case retention permission) should influence the purity of planning decisions (except, apparently, where it concerns US?).

Interesting, if unsurprising.

@publicrealm wrote:

:rolleyes:

A notification of decision to grant pp for retention for unauthorised use in Tailors Hall has been issued by DCC (3642/09).

Is it possible that An Taisce has been holding weddings and dances in Tailors Hall without planning permission?

Might this impact on the setting or fabric of a protected structure? Might it have impacts on adjacent amenity? (I imagine AT would have predictable views on this if a nasty commercial owner was applying.)

The planning application asserts that they have pp for ‘community use’ (?) (but their planning application form does not record this permission).

Quis custodiet ipsos custodes?

Happily the matter has been appealed by a concerned citizen – so the Board will have an opportunity to adjudicate on the matter. (It appears that AT have also appealed – presumably against the €57k or so in development contributions?

Tailors Hall was designed and built as a place of assembly. Holding weddings and dances in a purpose built place of assembly, from time to time, would seem to be pretty consistent with it’s original use.

Maintaining appropriate uses is central to proper upkeep of older buildings, especially Protected Structures.

Why is there even a planning issue about this?

. . . and how in the hell is Dublin City Council entitled to squeeze €57k out of the deal? . . . . when they did nothing to protect this building in the 70s except knock down everything around it.

@publicrealm wrote:

Re: Retention application for unauthorised development at Tailors Hall???

Oh what a hoot!!

Except that the An Taisce planning application is for retention of an established use. This was required due to changes in licensing laws in relation to holding of small dances/private events.

The Tailors’ Hall is as gunter alludes to actually purpose built for these type of small theatrical events and concerts, which have taken place in it for more than 300 years. The application is to permit continuation of this use into the future.

It’s a licensing issue rather than a development issue.

The individual who appealed the decision to An Bord Pleanala is also apparently unaware of this …

Nice of the corpo to extort €50K out of a charitable organisation. They should go after other no-marks like the De Paul Trust who have singer songwriters around the odd night in their hostel or the indie kids running that new Exchange all ages rock venue/meeting place in Temple Bar:rolleyes:

@Devin wrote:

Oh what a hoot!!

Except that the An Taisce planning application is for retention of an established use. This was required due to changes in licensing laws in relation to holding of small dances/private events.

The Tailors’ Hall is as gunter alludes to actually purpose built for these type of small theatrical events and concerts, which have taken place in it for more than 300 years. The application is to permit continuation of this use into the future.

It’s a licensing issue rather than a development issue.

The individual who appealed the decision to An Bord Pleanala is also apparently unaware of this …

it is indeed an established use. In fact my wife wanted to have our wedding reception there until I reminded her of her 3 friends redundant in the most part due to interminable ABP dithering over vexacious AFT appeals (allegedly)

Obviously the individual in question is a misguided idiot in Devin’s AFT mistyeyedness but

There are 2 other scenarios of course

Perhaps this poor ignorant soul is just carrying out the AFT maxim of read application, object, read grant, appeal. He has learnt at the hands of the masters – why shouldn’t they be hoist by their own petard

Alternatively he may live nearby and be thoroughly sick of noise pollution and disturbance. In which case he is using legitimate means to further his ends within the wonderfully democratic planning system

in any event I’m willing to suggest that this will be out of ABP with a positive outcome within the allocated time period – unlike anything else in the vacinity

To be clear about this – this only became a planning issue because of the making of applications to court for licences after recent changes in the law regarding alcohol/dancing at community licensed premises.

No new works or use are proposed.

Tailors Hall costs a lot to keep up, north of €100,000 has been spent on the hall in the recent past on fire safety systems and architectural conservation including restoration of historic windows, rainwater goods and stonework which has been partially funded by voluntary contributions raised by An Taisce and by them overseeing conservation grants projects.Events such as weddings contribute immensely to the coffers for maintainance, without the correct (updated) licenses these cannot take place.

Perhaps this poor ignorant soul is just carrying out the AFT maxim of read application, object, read grant, appeal. He has learnt at the hands of the masters – why shouldn’t they be hoist by their own petard

An Taisce actually object on approximately 3% of planning applications – recent history, particularly in Dublin has shown that ABP have upheld AT’s concerns and most recently ABP seem to be doing DCC’s planning function for them – ref Arnott’s/Carlton sites.

Alternatively he may live nearby and be thoroughly sick of noise pollution and disturbance. In which case he is using legitimate means to further his ends within the wonderfully democratic planning system

He doesn’t, and I’m not aware of any noise complaints. This is a basement venue after all.

The ‘concerned citizen’ is no stranger to An Taisce….(Id quot circumiret, circumveniat.)

in any event I’m willing to suggest that this will be out of ABP with a positive outcome within the allocated time period – unlike anything else in the vacinity

It is a simple administrative matter, not a complex development matter, why wouldn’t it be?

it is indeed an established use. In fact my wife wanted to have our wedding reception there until I reminded her of her 3 friends redundant in the most part due to interminable ABP dithering over vexacious AFT appeals (allegedly)

I’m sorry to hear about the 3 friends, but I’m not sure if you can really hold An Taisce responsible for overambitious overdevelopment and the associated property bubble collapse. If anything An Taisce has been warning how unsustainable the property boom was for years. Sure wasn’t the developer mantra, landgrab, make derelict, and apply for the biggest f-off tower you could regardless of plot ratio, setting, zoning or economic necessity.

Anyway, just to be cheeky that 55k needs to be raised somehow – donations gladly recieved I’m sure…(by way of ‘apology’ @publicrealm?;) )

http://realex.antaisce.org/

wearnicehats, the first version of your scheme got a pretty poor reception when it was put up here on archissek in 2007.

Maybe an image of the revised scheme should be reposted in this thread to see if people think an appeal against it was “vexatious”.

@publicrealm wrote:

. . . . . especially as they style themselves as ‘Ireland’s National Heritage Organisation’.

leaving the baggage aside for the moment, most people [who are not actually in the An Taisce bubble] recognise that heritage and conservation in this country is like an asylum where none of the doors lock. At any moment something truely daft can come down the corridor.

I’ve used the phrase ‘conservation community’ before, but there isn’t really a conservation community here, just a loose collection of oddballs and misfits festering in isolation and indignantly firing off invective at the greedy developers and the bastards in planning who don’t get it . . . or is that just me?

If we could get our act together, act like a genuine community, people who share common purpose in guarding and protecting our heritage and environment [built and natural], we could sort this place out in no time, but how do you reach people like historians, who will spend ten years researching a book on a lost building rather than try and save the building, or archaeologists who painstakingly dig up vital information only to bury it again in unpublished reports, or the aforementioned An Taisce whose public utterances are nearly always – arrogant put-downs- and almost never – positive lessons.

This is not just an image problem, Conservation and heritage could be one of the engines that pulls this country out of it’s quagmire, if we all just met once in a while and worked out a strategy.

@Devin wrote:

wearnicehats, the first version of your scheme got a pretty poor reception when it was put up here on archissek in 2007.

Maybe an image of the revised scheme should be reposted in this thread to see if people think an appeal against it was “vexatious”.

happy to stand over anything – wouldn’t have the first clue where it is but you obviously know so repost away. not sure what you mean by images though

Smithfield resi states “most recently ABP seem to be doing DCC’s planning function for them – ref Arnott’s/Carlton sites”. of course they have – I’ve said it before – if you’re a planner on a hiding to nothing on a contentious scheme and you know someone in the mix – AFT for example – is a cast iron apellant then you can grant away with impunity – let someone else sort out your shit. that’s the system.

An Taisce whose public utterances are nearly always – arrogant put-downs- and almost never – positive lessons.

Gunter, I accept that they can be read this way, positive lessons are all very well but they usually come after the battle is lost, and they are quickly forgotten –

Who else is actually fighting the battle for heritage in this country?

Local Authorities? Largely more interested in development contributions.
The Heritage Council? Never get involved in planning, yet to see them make submissions on Development plans for example.
Dublin Civil Trust? – They do great work, (and with the greatest respect Graham) but don’t make planning appeals or get involved in enforcement etc (as far as I know unless this is under the radar. Georgian Society likewise.
DoE? Hardly, Gormley cannot marshall his troops to make sure national monuments are not slated for demolition!
Bord Failte – “Conservation and heritage could be one of the engines that pulls this country out of it’s quagmire” do they see that tourist come to Ireland for precisely this reason and tourism is a competitive advantage for ireland. No – which is why they are more supportive of urban ferris wheels and tax breaks for mega hotels than conservation.

An Taisce is flawed. It is flawed by lack of money, time and resources and is largely reliant on donations and volunteers. But Ireland would be significantly worse off without it. And unlike the golden circles of property development, state body boards, and the political merry-go-round. It is a reasonable €45 a year to join, get involved and help. 🙂 I would love to see the people you mention prick the An Taisce ‘bubble’ and become involved. I would also love to see a more structured community have a voice BEFORE planning is granted – at the moment An Taisce is the only national organisation filling that void.

let someone else sort out your shit. that’s the system.

Look where it has got us. Change is coming to [strike]America[/strike] Ireland… we live in hope.

@wearnicehats wrote:

happy to stand over anything – wouldn’t have the first clue where it is but you obviously know so repost away.

You’re perfectly entitled to come on the internet and gripe over someone .. that’s what it’s for. But I think where it gets a bit stretched is where you can do this about AT due to their appeal against your scheme – as you have in three threads – but disassociate yourself from the scheme in question at the same time.

……… btw I’d be pretty confident no one would think AT’s appeal against that scheme was “vexatious”, “read application, object, read grant, appeal” or any of those things ….

@Devin wrote:

You’re perfectly entitled to come on the internet and gripe over someone .. that’s what it’s for. But I think where it gets a bit stretched is where you can do this about AT due to their appeal against your scheme – as you have in three threads – but disassociate yourself from the scheme in question at the same time.

……… btw I’d be pretty confident no one would think AT’s appeal against that scheme was “vexatious”, “read application, object, read grant, appeal” or any of those things ….

https://archiseek.com/content/showthread.php?t=7435

probably this thread you’re referring to?

You’ll find that when I refer to the redundancies it isn’t my company or scheme so it is not my place to post its identity

That’s the other beauty of the net of course …. a username and talk about what happened to you in the 3rd person.

@Devin wrote:

That’s the other beauty of the net of course …. a username and talk about what happened to you in the 3rd person.

you see Devin you never fail to bite. Your blood pressure will not be so high if you simply realise that a huge proportion of architects despair at the system and see AFT as being as faceless obdurant and unapproachable as the mindlessly erratic ABP it lies in bed with.

It is laughable that the planning process demands that you meet and liaise with the LA but, when the decision is taken from them, no further discussion is allowed. Actually, it’s not laughable it’s completely insane.

@wearnicehats wrote:

Your blood pressure will not be so high

Lol!!!

Look man my point is stop prentending all this stuff you’re suddenly posting (this & other thread) re AT & ABP is not because YOUR scheme on HT was appealed.

Same with the guy who posted this thread – a planning consultant for a completely OTT celtic tiger scheme on Fleet Street significantly changed following appeal by AT

get a life the lot of yis!!!!

This is last comment I’m making in this thread ….. better things to be doing 🙂

faceless obdurant and unapproachable

As described usually by those who would wish AT to be a part of the golden circle, partial and easy to pull the wool over the eyes-able (gullible, I suppose). Compare the definition of ‘obdurant’ with ‘judicial’. What qualities are you looking for in a watchdog? Trust me all the stragems have been tried in the past….

• Drop in for a cosy chat to discuss your latest scheme so that you can later say you ‘consulted with An Taisce’.
• Extract the tiniest positive statement from a damning planning observation and trumpet AT’s “redevelopment in this area is to be welcomed” leaving out the bit about the 25 material breaches of the development plan.
• Make a donation and hope that your monster scheme gets conveniently ignored (not gonna happen)
• Do flashy presentations doing the rounds of all sorts of development boards, councillors, community groups, press the flesh, smile and then express outrage when AT comment – “but we consulted extensively”
• Make headline grabbing statements “economic terrorists!” “Obstructing Job Creation!!”

The hard truth is this. In relation to planning An Taisce doesn’t represent anyone except the Development Plan. That is to say it insists that the legally binding contract that was made between the people and those who administer their local area is upheld by legal process. If that seems faceless, obdurant and unapproachable, well what can I say. Should AT wear nice hats at Oral Hearings to make it seem friendlier?

ABP it lies in bed with

careful now…
http://www.collierbroderick.ie/Articles/HRUpdate-0210-Irish-Blogger-Settles-Libel-Case-For-100k

@Smithfield Resi wrote:

careful now…
http://www.collierbroderick.ie/Articles/HRUpdate-0210-Irish-Blogger-Settles-Libel-Case-For-100k

That’s a bit uncalled for isn’t it?
We’re all friends here, no need for (substantiated) threats.
This thread is getting saucy though; play on!

@Smithfield Resi wrote:

Who else is actually fighting the battle for heritage in this country?

No Resi, there are other people who fight that battle, mostly at a local level and often without the benefit of any leadership or guidance from anyone. There are even some people within the various local authorities who fight for heritage in what must be very difficult circumstances.

Even though many individual battles are won, I think the war is still being lost, because broader allegiences are not being formed across the whole body of people who share the same concerns about heritage, but who perhaps do not have the planning know-how to mount effective campaigns, or who are simply untapped as a resource on account of the insidious nature of many residents associations.

@Smithfield Resi wrote:

I would love to see the people you mention prick the An Taisce ‘bubble’ and become involved. I would also love to see a more structured community have a voice BEFORE planning is granted – at the moment An Taisce is the only national organisation filling that void.

Ok. one solution is, we all join An Taisce and with everyone inside the tent, pissing out, we could put out the fires of development for years.

Another solution would be to put in place a some kind of umbrella group, under which all shades of heritage opinion, from militant ATs on one side to gentle academics on the other, can feel comfortable and useful. A conference once or twice a year could be convened to review progress, re-energise the troops and hammer out strategies for elevating heritage to the position we all know that it should have.

An Taisce does an enormous amount of good work, but it’s fire fighting methods don’t foster broad support among the wider community who don’t always see things in terms of back or white.

@Smithfield Resi wrote:

The hard truth is this. In relation to planning An Taisce doesn’t represent anyone except the Development Plan. That is to say it insists that the legally binding contract that was made between the people and those who administer their local area is upheld by legal process.

Legalese is the lowest form of argument. We will never communicate the value of heritage to the broader community if we rely of the footnotes of zoning objectives to win planning battles.

no need for (substantiated) threats.

Retracted. Fair point. Should have been one of these after 😉 It was meant as a lighthearted Father Ted-like threat(!?)

@gunter

Very fair assessment, I should clarify I meant by “Who else is actually fighting the battle for heritage in this country?” I meant nationally, there are hundreds of community groups and individuals who do so much.

Another solution would be to put in place a some kind of umbrella group, under which all shades of heritage opinion, from militant ATs on one side to gentle academics on the other, can feel comfortable and useful. A conference once or twice a year could be convened to review progress, re-energise the troops and hammer out strategies for elevating heritage to the position we all know that it should have.

I agree. Irish Environmental Network works well in this regard, can you see such a broad-church organisation for the built environment? I’d like to explore this further. Archiseek beers?? When and where?? Heritage pub?

Legalese is the lowest form of argument. We will never communicate the value of heritage to the broader community if we rely of the footnotes of zoning objectives to win planning battles.

In the interim however, the legal argument is often the only resource when it is frankly the broader community that doesn’t give it a thought until it is too late. Boiled Frog syndrome.

Take for instance 16 Moore Street – the endless struggle to have the importance of that site recognised and fully protected and yet today, despite all the publicity, education, protesting, interviews, reports, surveys, oral hearings, questions in council, scandals.

Today it is in serious danger of eventually being condemned by neglect. And that sums up how important we as a nation take our heritage. If you don’t like that example, insert another or another, you know that its a story repeated up and down this country.

You might not be aware, but An Taisce were recently asked to appear before a Joint Committee on the Environment. The debates makes for interesting reading … I leave you with that for now…

http://debates.oireachtas.ie/DDebate.aspx?F=ENJ20090901.xml&Page=1&Ex=H3#H3

@Smithfield Resi wrote:

http://www.collierbroderick.ie/Articles/HRUpdate-0210-Irish-Blogger-Settles-Libel-Case-For-100k%5B/url%5D

I merely meant that they are each equally as unappraochable as the other given that neither can be consulted. What I wrote perhaps read as the 2 being “in League” with each other which is obviously a ludicrous suggestion

my main gripe is not against AFT per se (Devin just seems to bring out the worst in me)but the whole process that castrates a LA and leaves development, and design teams (and fees) in limbo for years. As unacceptable in terms of development as many may view Dunner’s scheme for Ballsbridge, for example, is it really also acceptable to keep someone hanging on for 2 years before totally refusing the whole thing?

is it really also acceptable to keep someone hanging on for 2 years before totally refusing the whole thing?

Isn’t that the point of development plans and zoning? I’m sure he would have had permission long ago if the development proposed was within the zoning objectives. On the other hand, why shouldn’t someone who picks a figure out of the air for what he’ll pay for a site (with everyone shaking their heads at the time and saying that’s stupid money) and then rides roughshod over the zoning, context and local sentiment for the area in proposing something totally inappropriate.

Why shouldn’t the ‘system’ give that applicant a pretty bloody hard time.

Or do you consider development plans optional?

______________________________________
Archiseek beers?? When and where?? Heritage pub?

Should I start a thread??

@Smithfield Resi wrote:

Isn’t that the point of development plans and zoning? I’m sure he would have had permission long ago if the development proposed was within the zoning objectives. On the other hand, why shouldn’t someone who picks a figure out of the air for what he’ll pay for a site (with everyone shaking their heads at the time and saying that’s stupid money) and then rides roughshod over the zoning, context and local sentiment for the area in proposing something totally inappropriate.

Why shouldn’t the ‘system’ give that applicant a pretty bloody hard time.

Or do you consider development plans optional?

______________________________________
Archiseek beers?? When and where?? Heritage pub?

Should I start a thread??

Noooooo – under our current system he should have had a decision within 42 weeks. Can you actually fathom that timescale – 42 weeks!!!!! utterly nuts. In the thread shown above I cut it to 22 without being overly crazy (despite what Devin thinks)

Anyway I don’t consider DPs optional but ABP are getting paid to do a job – why don’t they do it? Rather than a flat “no” why not have a system where ABP stipulate in their Direction an acceptable quantum of development / height profile that would inform a new application – Thereafter all objections with regard to overdevelopment / height etc would be disregarded and the LA’s decision on a second application would be final should all ABP stipulations be met

The inspector’s report is not an acceptable document for this as, likely as not, the final ABP decision overturns it

Not everyone is a crazy developer. Not everyone breaks a development plan or submits insane schemes. Some people do quite the opposite but because anyone can object and because of the system they can be tied up for a year, paying interest on loans all the time.

@Smithfield Resi wrote:

An Taisce actually object on approximately 3% of planning applications – recent history, particularly in Dublin has shown that ABP have upheld AT’s concerns and most recently ABP seem to be doing DCC’s planning function for them – ref Arnott’s/Carlton sites.

]

just out of interest – any idea what that percentage is when you ignore any development under 1000sqm?

@wearnicehats wrote:

just out of interest – any idea what that percentage is when you ignore any development under 1000sqm?

take, for example.

in 2008 there were 59,154 planning applications across the country. 3% of this is 1774

of these, however, only 8,291 were of a non domestic or agricultural nature

Let’s assume that AT object to 1% of the domestic schemes (I’m probably being generous) that means that 1200 of the objections are of the non-domestic type or – aren’t statistics great – that AT object to 14% of commercial schemes. This figure would be more in keeping with the experiences of archiects in that field

Hats

You are only proving the veaxtious nature of the appeal taken in this case by turning it into a discussion on planning stats; I am disapointed that you have chosen to as I normally find what you say to make a lot of sense.

I feel a lot of sympathy for AT on this particularly the development levy angle; as landlord of Tailors Hall the council had the ability since 1986 or to assert a deviation from the user clause in the lease however they concurred that consent for this use did in fact exist. From that time there has been regular and occaisional use of the venue for private hire events.

When one looks back at the amount of money AT has saved the city by taking this building off their hands surely the money should be going in the other direction towards the latest round of refurbishment.

This really is a case of getting severly punished by a hurler in the ditch for dotting an i; no doubt sense will prevail with the i dotted.

Great discussion everyone.
I agree with a few of the last few lines in Wearnicehats last post. Surely anytime the board overturns their inspectors recommendation ABP should be obliged to account for their thinking and issue their own detailed report. At least then there is greater clarity for a new design strategy for any second applications. This would also ensure the Board members become more accountable and reduce the potential for any undeclared design/ development bias or conflict of interest.

(Wasted time, fees and interest payments? Thats the risk a developer takes – the rewards can be significant but if it was so easy then everyone would be doing it —- like a lot of the nation was up until recently!

Surely anytime the board overturns their inspectors recommendation ABP should be obliged to account for their thinking and issue their own detailed report

Agreed.
Would love to read the one for the Clarence!

@PVC King wrote:

Hats

You are only proving the veaxtious nature of the appeal taken in this case by turning it into a discussion on planning stats; .

Actually, I was just challenging the 3% figure along the lies, damned lies and statistics front.

I think what I’ll do is gather together all my thoughts rationally and post on a new thread for all and sundry to shoot at – I’ve no problem sticking my head above the parapet

@wearnicehats wrote:

take, for example.

in 2008 there were 59,154 planning applications across the country. 3% of this is 1774

of these, however, only 8,291 were of a non domestic or agricultural nature

Let’s assume that AT object to 1% of the domestic schemes (I’m probably being generous) that means that 1200 of the objections are of the non-domestic type or – aren’t statistics great – that AT object to 14% of commercial schemes. This figure would be more in keeping with the experiences of archiects in that field

Err.. that 3% (and where does it come from?) figure is not necessarily all objections. Speaking for Limerick, we made I would say less than half a dozen submissions on planning applications each year over the last 4/5 years. And not all of those were objecting to the developments but also consisted of submissions commending some aspects of developments and suggesting ways in which the application could be made better.

@wearnicehats wrote:

Noooooo – under our current system he should have had a decision within 42 weeks. Can you actually fathom that timescale – 42 weeks!!!!! utterly nuts. In the thread shown above I cut it to 22 without being overly crazy (despite what Devin thinks)

Anyway I don’t consider DPs optional but ABP are getting paid to do a job – why don’t they do it? Rather than a flat “no” why not have a system where ABP stipulate in their Direction an acceptable quantum of development / height profile that would inform a new application – Thereafter all objections with regard to overdevelopment / height etc would be disregarded and the LA’s decision on a second application would be final should all ABP stipulations be met

The inspector’s report is not an acceptable document for this as, likely as not, the final ABP decision overturns it

Not everyone is a crazy developer. Not everyone breaks a development plan or submits insane schemes. Some people do quite the opposite but because anyone can object and because of the system they can be tied up for a year, paying interest on loans all the time.

I would have to ask the obvious here but who would you restrict the ability to make submissions on planning to? And given that those making submissions, whether neighbours or whoever have for the most part no vested commercial benefit in a negative outcome what is the problem with giving them time to make their submissions. They aren’t professionals who are getting paid to work full time on them.

Guys,

An Taisce is a heritage organisation with planning expertise and has adopted a role of scrutinising and challenging the planning applications of others. As such it must be seen to set proper standards in its own applications, regardless of the merits of the individual application.

If the answer to Publicrealms questions is that AT’s planning application wrongly stated that they had permission for community use on two floors of the building – then surely they should withdraw their application and submit a correct one? (An incidental benefit of this might be that DCC would not impose the levy second time round)

From a quick read of the file it appears that they did not in fact have the permission they claimed – and that the use was in fact unauthorised?

They also appear to suggest that this claimed ‘permission’ means that other similar uses in the building benefited from the exempted development regulations – but the exempted development regulations do not apply to unauthorised uses – and AT must know this??

Time to clarify imho.

@wearnicehats wrote:

Actually, I was just challenging the 3% figure along the lies, damned lies and statistics front.

I think what I’ll do is gather together all my thoughts rationally and post on a new thread for all and sundry to shoot at – I’ve no problem sticking my head above the parapet

https://archiseek.com/content/showthread.php?t=8069

@Fairfield wrote:

Time to clarify imho.

Fairfield – I checked myself in DCC this morning.

It’s a retention application for unauthorised development (in an historic protected structure entrusted to the care of An Taisce), erroneously stating that permission exists for ‘community use’.

Extract from AT’s Online Planning Guide:
http://www.antaisce.org/builtenvironment/FAQ/PlanningGuide/tabid/196/language/en-US/Default.aspx

APPLICATIONS FOR RETENTION

Retention applications go through the planning process in precisely the same way as normal applications. The difference is that if they are refused (either by Local Authority or by An Bord Pleanala), the development is still unauthorised and we (An Taisce that is)generate an Enforcement file.

I look forward to their ‘generating an enforcement file’ (in the highly unlikely event of a refusal)!

Their ‘Planning Guide’ also states that:

From the DATE OF SUBMISSION of the application (not validation) everyone, including An Taisce, has 4 weeks in which to make submissions on the application.

I didn’t know that – I thought it was 5 weeks.:D