Our Ref: 29N.PA0043 P.A.Reg.Ref:

Your Ref:

Deirdre Carroll 31 Cameron Square Kilmainham Dublin 8

9th October 2015

Dear Madam,

Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.

An Bord Pleamila has received your recent submission in relation to the above mentioned proposed development and will take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed.

The Board will revert to you in due course with regard to the matter.

Please sign and return the enclosed page to the Board at your earliest convenience.

Please be advised that copies of all submissions I observations received in relation to the application will be made available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County Council and at the offices of An Bord Pleanala when they have been processed by the Board.

If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.

Yours faithfully,

kieran Somers Executive Officer Direct Line:O l-873 7107

Encls.

ADHOC/PA0043/01

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Tcil (01) K5X KI!HI Tel

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---M l\larlhnruugh Street,

Dublin I.

~ . , •

. , . ..

Deirdre Carroll,

31 Cameron Square,

Kilmainham,

Dublin 8.

The Secretary,

An Bord Pleam3la,

64 Marlborough Street,

Fee: -

Dublin 1. Receipt No: f, 13) Z.2... ~

= -02 October 2015.

Re: Planning application reference PL29N.PA0043, St. James Hospital, Dublin 8.

Dear Secretary,

We are making this submission in relation to the proposed Health Infrastructure

Development comprising the National Paediatric Hospital, Innovation Centre and

Family Accommodation Unit at St. James Hospital Campus, and Satellite Centres

at Tallaght and Connolly Hospitals, and future development plans as laid out in

the 'Draft site capacity study' for St. James campus.

As parents of two young children, we fully recognise and support the need for a

state of the art children's hospital providing first-rate clinical services on one

1

Jl' 1(

campus. As good neighbours of St. James' hospital for over a decade, we

appreciate and respect the operation and efficient running of a modern hospital

on our doorstep. Our objection to the planned development centres on three

primary aspects: (1) It is a gross overdevelopment of the current site, with

inadequate space for future development as outlined in the submitted plans; (2)

The planning application is different from the planning site notice (2) The

infrastructure is incapable of supporting this development, and it will lead to

traffic gridlock; (3) It is an entirely inappropriate development for a Zone2

residential neighbourhood. We will address these issues in detail, along with the

considerations detailed by Mr. Kevin Moore in the Inspector's report (PL

29N.PC0158).

Instead of the proposed development, we respectfully suggest that the new

National Paediatric Hospital be developed at Connolly Hospital, and that a

satellite centre (if required) be developed at the St. James' site. As identified in

the 'Dolphin Report', Connolly Hospital is a more appropriate location for the

National Paediatric Hospital, and has space for future expansion. This will also

facilitate appropriate service delivery of adult services, as approved for the St.

James site. -AN BORD PLEANALA

TIME BY ------1 -U 'L OCT 2015

2 L1'R•DAil1tJ PROM __ ""''

-~_...

Pb.

Another viable alternative is the Coombe site, which has more than twice as much

area for developing the new National Paediatric Hospital. It has the added

advantage of a co-located maternity hospital on site.

We appreciate the urgent need for development of a new National Paediatric

Hospital, especially in light of the delay caused by a previous application. We

believe that acting in haste will not serve the nation's children well, however, and

note that ~~ ... while any avoidable delay should be minimised, it is more important

to choose the right site which meets essential criteria over the long-term (say 50-

100 years) than one which is merely the fastest in the short-term .... " (Dolphin

Report, p.42).

~ ,..,..._,j

1--A-N-B~O~R-::D-;P:7"L:;EA~N~P.&J' LA 1'1ME B'V ____ _,

3

-0 I OCT 1.015

LiR·Ofl.iED _____ rROM ____ ., l

PL

Table of contents

(a) Overdevelopment of the current site: .............................................................................................. 5

(b) The planning application is different from the planning notice ..................••....•...................•.......... 9

(c) The local infrastructure cannot support this combined development: .......................................... lO

(d) The proposed development is inappropriate for a Zone2 residential zone: .................................. 14

(e) The inspector's Report .................................................................................................................... 23

Appendix 1-Public site notice for planning permission ........................................................................ 30

Appendix 2 .............................................................................................................................................. 32

Appendix 3 .............................................................................................................................................. 35

Appendix 4 .............................................................................................................................................. 45

AN aoRO PLE.ANALA aY ___ ., 1lME---~·

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4 PL

(a) Overdevelopment of the current site: The plans for development of the St. James's site include a 'draft plan for future

development' as detailed in section 3a of the Architectural Reports, entitled 'St.

James's Campus- Draft Site Capacity Study'. The current planning application is

based on this blueprint for the development of St. James's site, and although it

does not ~~ ... purport to be a development plan for the campus .. '', it seeks to show

11 •••• an indication of its potential capacity .... ". It is therefore central to the current

application. We believe that rather than indicate its potential capacity, this draft

plan clearly indicates the limitations of the current St. James's site, not only for

future development, but as a site for the planned National Paediatric Hospital. It

also raises fundamental questions as to the continued provision of adult services

at St. James's, which is the primary designation of the site. Presentation of this

draft plan raises questions about (a) the planning process, (b) the assumptions

and methodology on which the plan is based, and (c) the provision of healthcare

services in the state.

A number of key questions arise:

(1) What will happen to adult services at St. James hospital if this plan goes

ahead? Where will adult services be located as approved for this site?

Where will adult outpatient services be located? No detail has been _ ...-- ""CC"'

AN soRDPu:.Ai~At.A ev ___ _, ----5 o I- OCI 2U1S

LTR·OAlt!b ~ ~1\~M PL

provided for provision of adult services (including decanting, etc.) whilst the

various developments of sites A to H of the Draft Site Capacity Study is

being carried out.

The Dolphin report {attached) highlighted a significant risk that the " .... new

children's and maternity hospitals will consume most of capacity for

expansion of adult hospital.. .. " {Dolphin report, p.69). This is completely

ignored in the present application.

{2) What is the projected cost of this development, and what are the plans to

fund it? No cost estimations are provided, and no provision for funding has

been made under the National Development Plan or other alternative

source1• Additionally, no details of funding have been provided for

equipping the various hospitals and units.

(3) This draft plan represents a gross overdevelopment of the St. James site.

The indicative layout illustrates the extent of development required for the

three hospitals within the campus. This indicates that further 6 and 7 storey

buildings with basement levels will be required. There is no indication of

,_ . = :-"bo\t-A 1

Apart from an announcement of €650 million to fund the National Paediatric HosJ:I, no cost projections or sources of finance have been provided. liM -- -- -

6 o '= OCT l.~\15

L1R•DAtllf:l __ ~~lltlM ...,..,.,._._, .fl: ...... . _.,_ .. :: : .. .

site coverage and no three dimensional analysis. The study relies on plot

ratio assessment only (the plot ratio expressed is 2.22, which is in the upper

bound permissible), indicating that the campus is barely capable of

achieving the quantitative extent of development required within the

standards of the Dublin City Development plan with little room for further

expansion or enhanced public realm. In order for the campus to

accommodate the development of three hospitals, the remainder of the

site will be as intensively developed as the proposed Paediatric hospital

portion of the site (see following section).

(4) An indication of the extensive nature of development of the site is that

plans project multiple uses for the same plots of ground. For example, the

'meadows' area originally functions as a 'garden space' for sick children. In

plans detailed in 6.1.1. 'NCH Expansion', this site is earmarked for 'buildings

4 to 6 stories' in height' on ground " ... designed initially as garden space .... ".

2 The St. James site is zoned Z15 in the Dublin City Development Plan, the objective of which is '7o protect and provide for institutional and community uses and to ensure that existing amenities are protected." Under this zoning "buildings for the health, safety and welfare of the public and Medical and related cofWdtants:.ar.e - ~-

permitted in principle, with "car park ancillary to main use" open for consideration. The qul ntitative me asures to ~: t- N[J., r-J..., assess the scale of development include Plot Ratio, Site Coverage, Building Height and dista1ces1~hi~ved betweenGy new and existing residential areas. The indicative plot ratio of Z15 land is 0.5- 2.5 in the Du nJ Cltfeevelopment~ ----·"

Plan. n /. ac { ?.U1~ 7

PL · ·· ~ ~ ~, ,. .. __ ..... ~

(5) 'Plans' for development of sites A to H (as listed in section 6 of the draft

capacity plan) are extremely ambitious, and suggest that the site coverage

will greatly exceed that permitted under the Dublin City Development Plan.

Given the reservations around the capacity of the existing site

infrastructure to facilitate development of the National Paediatric Hospital,

it is unrealistic to suggest that the site can be developed as proposed.

Whilst the proposal briefly considers phasing options, it does not detail

how this future development can be carried out with a fully functioning

adult hospital and National Paediatric Hospital on site. (Given traffic

considerations alone, it is inconceivable that a construction project of this

magnitude could proceed with these clinical services on site) .

..,........,.~~

F N BORD PLk.Ai-i~U-\ A BY

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(b) The planning application is different from the planning notice

The publicly displayed site notice (see appendix 1) is incompatible with the

present application, which is for an 8 storey building. We believe this

inconsistency in the present planning application raises fundamental questions

about the capacity of the St. James site for the proposed development, and for

further expansion plans as detailed in the 'Draft Site Capacity Study'.

Source: Ceannt Fort Residents Association.

AN BORD PLEANALA TIME BY ___ -t

9 o "i OCT 2015

LTR·OATtO -~ FROM ---"1 PL - ·-· ~

(c) The local infrastructure cannot support this combined development:

The site will be accessed by two roads, the Old Kilmainham road and the South

Circular Road. These roads are already operating at full capacity and come to a

standstill at rush hour in the morning and in the evening. They are particularly bad

during wet and freezing conditions, and it is not uncommon, for example, for both

roads heading Westwards to be at a complete standstill, with minor roads (such

as Brookfield road) similarly blocked. We contend that the traffic assessment

detailed in the Environmental Impact Study is flawed, both in terms of

methodology and conclusions.

Methodology: The methodology consists of a count of vehicles in and around

these roads at various times of the dal. This is informative, although it does not

provide an accurate assessment of the flow of traffic. {The numbers of cars

leaving and arriving at various hours does not inform us of the traffic

flows/blockages/jams). We believe this is a significant deficiency, and does not

provide a realistic of the traffic problems on site4•

3 As presented in chapter 6 of the Environmental Impact Study and appendix. 4

For example, the Dolphin report noted a significant " ... risk of traffic congestion near th Riai}O.ga~..Q!q~lprj2..i::ANAL report p.69). TIME BY

10 o 2 ocr 201s

LTR·OATED r.'ROM ~L ----~

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Additionally, the authors do not consider the cumulative effect of additional

traffic on these already congested roads. Without prejudice to this objection, we

request that the NPHDB conduct realistic modelling of likely traffic flows,

indicating 'worst case' and 'best case' scenarios. We also request that the NPHDB

provide detailed contingency plans for dealing with traffic during emergency

conditions such as adverse weather events.

The projected traffic plans are that " ... no more than 27% [of staff] will travel by

car and that this will fall to 23% on completion of the future maternity hospital..."

(Chapter 6, Environmental Impact Study, 6-95).

This appears highly optimistic given present car usage of staff (77% of staff at

Crumlin drive to work; 78% of staff at Tallaght Children's hospital drive to work;

57% at St. James and 35% in Temple St.). There is no national or international

evidence to support this assumption.

Furthermore, " .. .It is envisaged that the staff modal split would reduce from 27%

by car to the campus following the completion of the new children's hospital to

23% by car following the construction of the Maternity Hospital ' including the

retention of the outpatient department on campus ... " and further that " ..... should

the expansion of the campus development as set out in the Dra~~te CapaGity _ AN 80~ 1.) PL. ANALA

TIME ey 11 ----~

0 l OGT ~~i~ I.TR•OATGD r.~eM Pt. ~=:_J --

Study be fully realised then that staff modal split would reduce to 18% ..... " (P. 24,

3a St. James Campus, Draft Site Capacity Study, Architectural Reports).

Parking: The required car parking on campus is inadequate to support this level of

transport. In addition, it is also noted that 11 ... the future maternity hospital would

require in the region of 120 patient/visitor car parking spaces. It is proposed that

these spaces are provided by reducing the number of staff spaces within the

campus ... " (6-95). Reducing the ratio from 1 space per 2.8 staff to 1 space per 5.8

staff members is highly optimistic (6-94).

The NPHDB appear to agree that there is inadequate parking provision in the new

development. The authors note that " ... free on-street parking on the local streets,

increases the attractiveness of driving .... " (6-46). This suggests that the NPHDB are

urging staff to park on the local streets to alleviate the lack of on-site parking.

Sewage and water: The application does not clearly identify capacity in respect of

sewage. It is incorrect to state that " ... The St James's Campus and surrounding

area are well served by potable water supply ... " (section 5.4.3 'Potable Water

Supply', Draft Site Capacity Study). The water pressure in Cameron Square is very - --='-:=•

poor, and at times no water comes out of the tap when turned i'o~Owater·LJ\NALA TIME BY ___ _.

12 a t. m;r '~1o LTR·OATEO ~...._... rRGM~-1"11 PL ---

•

pressure is intermittent and unreliable, affecting appliances as well as immediate

needs. We respectfully request that Dublin City Council Drainage Division and

Irish Water be required to provide a detailed plan as to how sewage and water

services will be developed to cope with the added development, along with

provisions for disruption as the new facilities are being built. We also request that

the Dublin City Council Drainage Division and Irish Water be required to prove

sustainability of the services, including funding.

L--~-=":::O>ro~--=--::. --= AN BORu PLEANALA

TIME BY ------~

o f. ocr 2~i~ 13

LTR·DATEO FROM ?L --- ----1

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..

(d) The proposed development is inappropriate for a Zone2 residential zone:

The relevant guiding planning document is the current Dublin City Development

Plan 2011-2017. The proposed development by reason of its inappropriate scale,

bulk, mass and layout materially contravenes the Development Plan, and as a

result is likely to seriously and adversely detract from the residential amenities of

Cameron Square.

Cameron Square land is zoned as Zone 2: To protect and I or improve the

amenities of residential conservation areas which are more environmentally

sensitive zones. The scale and form of development as proposed is contrary to the

development plan guidance and has a detrimental impact on the amenity of

Cameron Square.

This will be particularly detrimental in relation to our home, both to the East

facing boundary and to the South facing boundary. This much is acknowldeged by

the overshadowing analysis in Chapter 13 of the Environmental Impact Study:

Microclimate: "Point 9, as seen in Plate 13.9 below, is located on the south facing

patio door of a single storey extension at No. 31 Cameron Square. No. 31

Cameron Square is at the south eastern corner of Cameron Square and as such is

the closest property in Cameron Square to the proposed development and likely ttMc ___ _

14

- 1

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to experience the greatest impacts on Daylight and Sunlight" ..... (13-35 micro

climate).

This analysis is disingenuous. It grossly understates the extent of overshadowing,

overlooking and sunlight blocking of the proposed National Paediatric Hospital to

the East. It also uses inaccurate measurements.

A cursory look at the plate below indicates that our house is going to be

detrimentally affected by the proposed development, both to the East by the

34.95m Paediatric hospital, and to the South by the proposed 12.6m Family

Accommodation Unit. Additionally, a new road is proposed to run directly up to

our boundary fence on the East side. Not only will this have a severe effect on the

health of our youngest son who has asthma, but the added noise and pollution at

all hours of the day and night will severely affect the health of our whole family.

AN B;.k'- '-t:..:J·do\~..A P TIME ____ BY ___ ._...l

15 0 2 OCT 2u15

LTR·DATED FROM ---11

PL

Distance from ground floor of

proposed development to gable wall

Accommodation unit

12.6m high

Source: "Plate 13.9: Aerial view of No 31 Cameron Square~~ Environmental Impact Study Chapter 13: Micro climate 13-35

Height: The proposed National Paediatric Hospital has a roof height of 34.9Sm

and 37.95m to chimney height. Accordingly, the roof height exceeds the

permitted development plan height of 28m by 6.95m, and if permitted would

materially contravene the Dublin City Development Plan 2011-2017.

The Dublin City development plan requires a separation of 22m between 2 storey

dwellings in order to protect their amenity. This standard is applicable in this

context. This standard is not met in relation to our home, which according to the

drawings is 18.9m from our gable wall. Furthermore, this distance is a minimum

distance, and greater distances should be provided where buildings exceed two

storey in height. TIME

16 U t OCT 2 3 LTR·DATED F

---ROM PL ·---li·

The proposed development will dwarf the height of our main living area and

kitchen (2.9m). As we spend over 90% of our waking hours in this room, this will

be detrimental to the amenity of our residence.

In addition, the proposed Family Accommodation Unit will be constructed on our

East facing boundary. We will be overshadowed and overlooked on two sides.

Overlooking: The proposed National Paediatric Hospital will overlook our garden

and main living area. The lodged drawings indicate that it is proposed to locate

balconies and glass fronted corridors immediately to the East of our home at a

height in excess of 25m above the level of our house. Without prejudice to this

objection, we ask that in the event of permission being granted: that the

proposed Paediatric Hospital be set back a minimum of 22m from the boundary

fence of our home, and that the height of the proposed Hospital be lowered to

the height permitted in the Dublin City Development Plan (28m). In addition, we

seek that the proposed Paediatric Hospital be stepped back, and that all windows

and balconies overlooking our home be glazed in obscured glass to prevent

overlooking of our garden and living area.

17

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i/ME BY ----s

0 '1. OCT 2u'l5

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Overshadowing: The patio doors of our main living area face due East, with our

other windows and patio doors facing due South. At present we receive direct

sunlight at 7am. The Shadow plans produced in the Environmental Impact Study,

Chapter 13 Micro climate, section 13.1.1.8 (and reproduced in appendix 2)

indicate that there are significant and severe overshadowing implications of the

new proposed National Paediatric Hospital for the residents of Cameron Square,

and our house in particular. These shadow plans support the comment of an

NPHDB representative at a drop in session in June 2015, when he remarked that

" ..... you will be lucky to receive sunlight by midday .... ". The overshadowing

implications are likely much more severe than presented in Chapter 13 Micro

Climate, as the shadow plans produced are only for the equinoxes (21st

March/September), and do not provide an accurate assessment of the loss of light

year round. Without prejudice to this objection, we request that the NPHDB

provide detailed shadow plans for each hour from 7am to 7pm for a full year on a

weekly basis to provide an accurate assessment of overshadowing at all times of

the year. We request that this also includes shadow plans for the proposed Family

Accommodation Unit. We believe that our right of light is denied for an East

facing window under the Prescription act 1832. This is a serious infringemen! on = - c , ~

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18

development/improvement, particularly for such a long duration. This is a

completely unnecessary measure, and we request that in the event of permission

for this development being granted, that our right of way through the 51 steps

not be interrupted.

In addition, we have serious concerns regarding security due to the huge increase

in pedestrian traffic and footfall of unrelated persons in and around our homes.

Air quality and pollution: The new road which is planned to run along our

boundary fence will result in a significant increase in NlO pollutants, which will

have a detrimental effect on the health of our youngest son who has asthma. In

addition, if permission for this development is granted, there will be a huge

number of construction vehicles passing by the boundary fence of our home (as

413,000 cubic metres of soil and materials are due to be moved off site, along

with construction materials being moved on site, the construction plan envisages

that 420 HGVs and LGVs per day will pass by our home).

The dirt, noise pollution and air pollution will only be 12.Sm from the main door

of our home. It will have a detrimental effect on the health of our family.

AN BORtJ PLl::ANALA

20 TIME BY ----

D 1. ocr 2L .~

We are also concerned that a complete environmental assessment has not been

conducted of the buildings to be demolished to the East of our home. In

particular, we are concerned that there is a significant amount of asbestos, and

that our garden will be contaminated by asbestos dust. We are afraid that the

health of our family will be put in danger by the pollution from demolition.

Light pollution: There will be a very significant light pollution from the National

Paediatric Hospital and the new road running along our boundary fence. The new

hospitable building has down lighters along the perimeter of the building and at

all the entrances. Also each of the roof gardens is to be lit up. Lighting at roof

garden level consists of Type H In-ground up-light luminaire LED, dimmable with

colour change capability. Reference drawing no. NPH-EARUP-DR-XX-ST-1002 for

details.

Lighting is proposed along the new road which runs right along our perimeter

fence. This consists of Type A along road - both sides 6m pole top luminaire LED,

100% DLOR, dimmable. This will floodlight our main living area at all times after

dark, and floodlight our childrens' bedroom which is at the rear of our home. It

will make it impossible for our children to get to sleep at night. _.

AN BORD PU:.f.\NAJ.A TtME ____ BY ___ FJ

21 u 1. OCT 1Ul~

t.iR~OAii:O ~ \ RIJM ___ .., __ .,._.....-~

Planned excavations for the National Paediatric Hospital: The drawings lodged

to an Bard Pleanala indicate that a hollow approximately 27m deep has to be

excavated in order to build the National Paediatric Hospital. This massive planned

excavation is extremely close to our home (less than 25m), and there is no

information contained in the planning documents as to how the construction firm

intends to secure this deep pit in order to prevent serious subsidence of our

property.

We are extremely worried that the engineers have provided no information

whatsoever on this point, and this engenders a complete lack of confidence about

the engineering and structural aspects of the proposed development. Without

prejudice to this submission, we request that the NPHDB be required to provide

detailed plans as to how the excavation is to be secured in order to prevent

subsidence to our home and nearby houses. We also request that the NPHDB be

required to insure us against subsidence and structural damage arising from the

proposed development.

Noise: Without prejudice to this objection, we are extremely concerned at noise

levels if permission for this development is granted. Along with heightened noise

levels from construction traffic and works (pile driving etc.), pumps will be

\,; /.. ~.. ..... j

22 r j \ L.1 tvUto\ •1- • :; ~l ill ..

required 24 hours a day for drainage of the excavation. As our childrens' bedroom

is at the back of the house, they will be unable to sleep with this constant noise.

(e) The inspector's Report

With respect to the inspector's report (attached in appendix 3), we would like to

address the considerations raised by Mr. Kevin Moore in section 7:

• Alternative sites

We contend that the NPHDB have not provided a detailed assessment of

alternative sites as intended by the planning inspector.

• Justification for the siting, scale, functioning and form of the overall scheme in

planning and environmental terms.

We contend that the NPHDB have not provided adequate justification for the

overall scheme in planning and environmental terms. In particular, the NPHDB

have not provided justification for the location of a National Paediatric Hospital in

a city centre location which is surrounded by a congested road network.

ANSORD

23

• The constrained nature of the St. James' Hospital site and capacity for tri-

location (children's hospital, adult teaching hospital and maternity hospital).

The NPHDB have not addressed the constrained nature of the St. James site,

particularly in relation to tri-location. The indicative plot ratio is at the upper

bound of that permissible by the Dublin City Development Plan.

• The ability to accommodate the future growth I expansion of these

developments individually and cumulatively.

The constrained nature of the site is evident in the proposed multiple use of plots

of ground (for example, the 'garden space' for children will be used to build a '4

to 6 storey building' in the following phase of development). There is no available

plot of land adjoining the site for further expansion, compared with Connolly

Hospital, for example, which has ample land for expansion.

• The developments now and into the future in the context of a new Master Plan

for St. James' Hospital complex.

These developments have not been considered by the NPHDB. For example, what

are the provisions for expansion of adult health services at St. James, as approved

,_ -r- ~ 0-H . ,. 24

,.,,.,t. U'L Ot~ t I

lr,

l..iR·OAiED_ rP.ONI

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for the site? What are the implications for adult health services whilst the

National Paediatric and New Maternity Hospitals are being built on site?

• Construction and demolition impacts - developing the project, decanting and

the functioning of the established hospital campus throughout this phase.

No detail is provided as to the amount and type of materials in the buildings to be

demolished. For example, what is the amount of asbestos on site? No detail is

provided as to how the future building programme will proceed with a fully

functioning children's and adult hospital on site.

• Satellite Centres - their need and applicability in the context of a national and

regional strategy relating to same.

The original aim of the National Children's Hospital is for ' ... the provision of a for a

state of the art children's hospital providing first-rate clinical services on one

campus ... '. The present application is contrary to that guiding principle. Proposals

for satellite centres suggest that the St. James site is insufficient for the

development of the National Paediatric Hospital.

... p;:& - , TIMe: ___ y-

UI- \t.,' \ 25

• The ability to accommodate the Satellite Centres at Connolly and Tallaght

hospital sites, inclusive of their context within the Master Plans for these hospitals

and the environmental and planning impacts thereon.

This has not been comprehensively considered in the plans lodged with An Bord

Pleanala.

• The outcome in the event of one or both Satellite Centres failing to acquire

planning permission or failing to be developed.

No consideration has been given to this possibility.

• Traffic and transportation - routing, access, modes, car parking.

We have highlighted the inadequacies of the St. James site in relation to traffic

and transportation.

• The Coombe Hospital and its developability to accommodate the proposed

future maternity hospital.

• The relocation of the Rotunda Hospital to Connolly Hospital, Blanchardstown

and the ability to accommodate same in the context of the Connolly Hospital

Master Plan.

26

The NPHDB have not provided serious consideration or analysis of the Coombe

Hospital or the Connolly Hospital sites as alternatives to the St. James site, as is

clear from the absence of detailed plans.

• Visual and streetscape impacts on the local and wider environment.

These impacts have not been given adequate consideration.

• Impacts on residential amenity - height, design, scale, structural impacts on

adjoining residential properties.

This is completely inadequate. For example, no consideration has been given to

potential subsidence impacts on neighbouring properties. Overshading analysis

has only been done for two days of the year. Scalar aspects have been ignored, as

witnessed by the distances between the proposed development and

neighbouring properties (which is less than that prescribed in the Dublin

Development Plan).

TIMe. • Public consultation. ---

0. =i L OCT t J ~

Public consultation consisted of a number of 'drop-in' sessio ~"@.tgwhich toea~ :d A

1 ..... -·· d~OM Pl... ...

residents were presented with photo-montages of the propose ' Cf~velopilfent. -27

We were repeatedly denied plans or detailed discussion about the proposed

development.

Condition surveys of our properties were ostensibly undertaken for our

reassurance (see appendix 4). These surveys were withheld from us despite

repeated emails to Ms. Rhonda Evans. They were then passed on to a third party

without our permission, either express or implied. When we telephoned the

surveyor, Mr. Seamus Mulligan of ABL surveyors, he informed us that he had

passed on the condition survey to 0' Connor Sutton Cronin and that he would not

be providing us with a copy. In addition, he stated that 'a PR company would be in

touch with us'. The NPHDB have since gone back on a promise to engage an

independent engineer.

We have been good neighbours of St. James hospital for many years, and we are

proud of our hospital. We have had a friendly, cooperative relationship at all

times. We are extremely disappointed at the adversarial, antagonistic,

disrespectful and combative attitude adopted by the NPHDB. It is unnecessary,

unhelpful and does not bode well for the future.

0 1 QGi !il .~

28 LTR·DAiEO ...:;--.-.·· t:lltlM _.._----=:...~ PL. --·· --·---- .........,.

........... ___. .....

We conclude that the St. James site is not suitable for the proposed development

on the grounds that it is a gross overdevelopment of the current site, with

inadequate space for future development, both for the new paediatric and

maternity clinical services and the adult services currently on site. The local

infrastructure is incapable of supporting this development, and it will lead to

traffic gridlock. The proposers have not given due consideration to the issues

raised by Mr. Kevin Moore in his Inspector's report. We respectfully request that

An Bord Pleamila refuse planning permission for the proposed development, and

that the NPHDB consider alternative sites for a state-of-the-art children's hospital

on one campus, such as Connolly hospital or the Coombe site.

We thank you for considering our submission.

Yours sincerely,

Deirdre Carroll.

o Z QC1 7 '

PRQM LTR·f:)"'iE~·:s:i...,~====-:. ~:P--~1

29 Pl

30

Appendix 1 - Public site notice for planning permission.

• A,_...... .. .,..., • Anew • A range

es's Hospital ·ng the diVersion

-u " l • ... I I

·-

31

llt;NOnC

AN DORD PLEANAUI PLANNIN!l & Dl Vf. LOPMEHT ACTS 2.l00-ZD1

MmCI! OF DIRECT PLANNING APP AnoN TO AN IIORD PLEANI.LAIN UinCT 01' A ~l'SeiC: INFflt.UlliUCTlHUI D VELOPMEHT

DUIIUN COY COUNCIL, FINGAL COUNTY COUNCIL AND SOUTH DilL UN CCIUin'Y ~

Appendix 2

Source: Environmental Impact Study, Chapter 13: Micro Climate Fig. 13.36, p.13.57

32

0 L UL.

AI Proposed

Source: Environmental Impact Study, Chapter 13: Micro Climate Fig. 13.36, p.9.58

33

34

AJProposd Source: Environmental Impact Study, Chapter 13: Micro Climate Fig. 13.3-6, p.13.59 ··-·-

~ FV 1 11N,c____ -----~---

0 "L OCT ~_, 5

LTR·DAIED r:F.OM -----t Pl ·---__:;=.--\

Appendix3

--------------------------------------------------------PL 29N.PC0158 An Bord Pleanala Page 1 of 10

An Bord Pleanala

Inspector's Report Proposed Development

Construction of a Proposed Integrated National Paediatric Hospital Project, Dublin.

Prospective Applicant: National Paediatric Hospital Development Board

Planning Authorities: Dublin City Council

South Dublin County Council

Fingal County Council

Nature of Development: Health Infrastructure

Inspector: Kevin Moore

_ PL 29N.PC0158 An Bord Pleamila Page 2 of 10

35

l.TR•QAiGO~,.--

•

1.0 PRE-APPLICATION CONSULTATION 1.1 A request to enter into pre-application consultations in relation to the proposed National

Paediatric Hospital development was received by the Board on 22,..,May, 2013 in accordance with section 37B of the Planning and Development Act, 2000, as amended by the Planning and Development (Strategic Infrastructure) Act 2006. The Board's representatives met with the prospective applicant on the following dates:

'" 20 June,2013 "' a May, 2014

30'"0ctober, 2014 17'"November, 2014 a"' April, 2015

"' 23 June, 2015 "' 6 July, 2015

1.2 The Board's representatives had a further meeting on a"' December, 2014 with representatives of Dublin City Council.

1.3 The essential question put to the Board is whether the proposed development would or would not be considered strategic infrastructure within the meaning of section 37A of the Act.

2.0 THE PROPOSED DEVELOPMENT

2.1 The original proposed development submitted to the Board for pre-application consultations on 22,.., May 2013 comprised the construction of a 384-bed inpatient and 54-bed daycare National Paediatric Hospital at St. James's Hospital, James Street, Dublin a. This development was the subject of discussion at the first pre­application consultation meeting on 20"' June, 2013. At a second meeting on a"' May 2014 the prospective applicant made a submission which referred to the development as comprising the construction of a 384-bed inpatient and aS-bed daycare hospital with two satellite centres - an increase in the number of daycare beds and the provision of two remote centres at Tallaght and Blanchardstown Hospitals providing emergency care units, each dealing with approximately 20% of emergency cases within the Greater Dublin

36

___ PL 29N.PC0158 An Bord Pleanala Page 3 of 10 May 2014. Therein reference was made to an Outline Construction Management Plan and to consideration of the use of a largely vacant HSE site on Davitt Road, lnchicore as a main contractor's temporary compound associated with the proposed development. At a further meeting on aApril, 2015, the prospective applicant referred to the inclusion of a family accommodation unit as part of the proposed development. At the meeting of 23June, 2015, the prospective applicant introduced a research and innovation centre as part of the overall project.

Area. Further to thismeeting, the prospective applicant senta letterto the Board which Ill

was received on 30 May 2014.Therein reference was made to an Outline

Construction ManagementPian and to consideration of the useof a largelyvacant HSE site on Davitt Road, lnchicore asa main contractor'stemporarycompoundassociated with the proposed development. At a

"' further meeting on 8 April, 2015, the prospective applicant referred to the inclusion ofa family accommodation unit aspartofthe proposed development. Atthe meeting

rd

of23 June, 2015, theprospective applicant introduced aresearch and innovation

centre as partof the overall project.

"' 2.21t is noted that the prospective applicant, in the letter received on30 May 2014, sought the Board's agreementthat the composite projectat thattime of the new children's hospital and the two satellite centres constitute strategic infrastructure development and can be handled as a single planning application and with a single Environmental Impact Statement.ltwas further requested if guidance could be given on whether it isappropriate to include the planningfor the contractor's compound with the application for the children's hospital and satellite centres or whetheritshould be submitted in isolation to Dublin City Council's PlanningDepartment.The Board, by letter issued on 24 .. June, 2014, stated thatitconsidered it would be appropriate for the proposed satellite centresto be treated as integral elements of theproject forthe purposes ofanyformalplanningapplication and that, in respect ofthe proposed temporaryconstruction compound, there would be no objection to its inclusion in the planningapplication. 2.3The proposed developmentnowcomprises: •A 473bed children's hosoitalat St.James'sHospital campus. Dublin8.forminqa 7-storeystructure over three basement levelson a site of 4.85hectares,comprisingapproximately 122,727 square metres grossfloor area (exclusive of approximately 30,000 squaremetres ofbasementcar parking), •A Children's Hospital Satellite Centre at Connolly Hospital campus,Bianchardstown, Dublin 15,comprisingapproximately 5,000squaremetres gross floorarea and forminga 3-storey building to thefront ofthe existingstructure,

PL 29N.PC0158An Bord PleamilaPage3of10 ____________ _

-------------------PL 29N.PC0158 An Bord Pleanala Page 4 of 10

37

• A Children's Hospital Satellite Centre at Tallaght Hospital campus, Dublin 24, comprising approximately 4,500 square metres gross floor area and forming a 3-storey extension to the existing 4-storey building,

• A Children's Research and Innovation Centre, comprising approximately 3,000 square metres gross floor area and 4-storeys in height, at St. James's Hospital campus, Dublin 8, adjoining the existing Trinity Centre for Health Sciences and with frontage onto James's Street,

• A 52 bed Family Accommodation Unit at St. James's Hospital campus, Dublin 8, comprising approximately 4,400 square metres gross floor area adjoining the proposed new hospital and forming a 3-storey I part 4-storey structure, and

• A temporary Construction Compound, Davitt Road, lnchicore, Dublin 8, constituting approximately 0.8 hectares of an 8.0 hectare plot.

2.4 The new Children's Hospital is proposed to provide tertiary and quaternary care on a national basis, and in some specialities on an all-island basis. It is proposed that it would provide in-patient care and all surgery. The satellite centres are proposed to provide secondary care, namely urgent care (41%) and outpatient care (14%), for the Greater Dublin Area. The new Children's Hospital is proposed to link with local and regional paediatric centres via an integrated national clinical network.

2.5 The proposed Children's Research and Innovation Centre would be co-located with existing academic facilities on the St. James's Hospital campus.

2.6 The Family Accommodation Unit would be located adjacent the new Children's Hospital and would provide essential facilities for parents and siblings of sick children with extended hospital stays.

2.7 The temporary Construction Compound would be located on HSE lands approximately 1.6km south-west of St. James's Hospital campus and would be used as a staging and storage area for building construction materials.

2.8 There would be approximately 1,000 car parking spaces to serve the new Children's Hospital. It is intended that 675 of these would be for visitors,

___ PL 29N.PC0158 An Bord Pleanilla Page 5 of 10

38

with the remaining 325 for staff members. Up to 400 cycle parking spaces are proposed. In addition to the established vehicular entrances at James's Street and South Circular Road at the St. James's Hospital campus, a new entrance would be added at Mount Brown.

2.9 Regarding consideration of the composite project of the above referenced components, I acknowledge firstly the Board's previous acceptance of the National Children's Hospital, the satellite centres being integral elements of the project, and the inclusion of the construction compound in any forthcoming application. I also acknowledge the new elements of the project since that determination, namely the research and innovation centre and family accommodation unit. I submit that the functions of these elements demonstrate they are integral to the overall project. Furthermore, I note the proposed siting of the relevant structures within the St. James's Hospital complex in the vicinity of the location for the proposed National Children's Hospital structure. I advise that it would be appropriate for these proposed developments to be treated as integral elements of the project for the purposes of any formal planning application for the National Paediatric Hospital Project.

3.0 LEGISLATIVE PROVISIONS 3.1 Strategic Infrastructure Development

Section 37A(1) of the Act states:

39

An application for permission for any development specified in the Seventh Schedule shall, if the following condition is satisfied, be made to the Board under section 37E and not to a planning authority. Section 37 A(2) of the Act: That condition is that, following consultations under section 37B, the Board serves on the prospective applicant a notice in writing under that section stating that, in the opinion of the Board, the proposed development

___ PL 29N.PC0158 An Bord Pleanala Page 6 of 10

. '

would, if carried out, fall within one or more of the following paragraphs, namely-( a) the development would be of strategic economic or social importance to the State

or the region in which it would be situate,

(b) the development would contribute substantially to the fulfilment of any of the objectives in the National Spatial Strategy or in any regional planning guidelines in force in respect of the area or areas in which it would be situate,

(c) the development would have a significant effect on the area of more than one planning authority.

The Seventh Schedule of the Act is amended by section 78 Planning and Development (Amendment) Act, 2010 to include: Health Infrastructure 4. Development comprising or for the purposes of the following: -A health care facility providing in-patient services, but excluding a development which is predominantly for the purpose of providing care services within the meaning given to that term by section 3 of the Nursing Homes Support Scheme Act 2009.

3.2 Environmental impact Statement Section 37E(1) of the Act states:

40

An application for permission for development in respect of which a notice has been served under section 378(4)(a) shall be made to the Board and shall be accompanied by an environmental impact statement in respect of the proposed development. ______________________________ _

--------PL 29N.PC0158 An Bord Pleanala Page 7 of 10

4.0 NATIONAL AND REGIONAL POLICY 4.1 There are no objectives in either the National Spatial Strategy (2002-2020) or the

Regional Planning Guidelines for the Greater Dublin Area (201 0-2022), which relate specifically to a national children's hospital and/or its siting at the St. James's Hospital complex.

5.0 THE QUESTION OF STRATEGIC INFRASTRUCTURE DEVELOPMENT 5.1 Section 37 A(2) of the Act sets out the conditions under which Seventh Schedule

development is considered to constitute strategic infrastructure for the purposes of the Act.

5.2 Having regard to the nature and extent of the National Children's Hospital, the prospective applicant considers that the proposed development falls within paragraph (a) of that section of the Act, being of strategic economic or social importance to the State. I concur that the proposed development would, if carried out, fall within paragraph (a) of section 37A(2) of the Act having regard to the following: (a) The proposed development would be of strategic social importance to the state

and the region, providing national tertiary paediatric care and secondary paediatric care for the Greater Dublin Area;

(b) The proposed development would not contribute substantially to the fulfilment of any of the objectives in the National Spatial Strategy (2002-2020} or the Regional Planning Guidelines for the Greater Dublin Area (201 0-2022};

(c) In acknowledging that the development would have an effect on the area of more than one planning authority, it may not be reasonable to determine such impact to be significant having regard to the nature, extent and context of such applicable related developments to the National Children's Hospital itself.

_ PL 29N.PC015B An Bord Pleanala Page 8 of 10

41

.... .

6.0 RECOMMENDATION 6.1 Having regard to the record of the pre-application consultations between An Bard

Pleanala and the prospective applicant, I recommend that the Board decides that: 1. The proposed development constitutes Strategic Infrastructure

Development under the meaning of Section 37 A of the Planning and Development (Strategic Infrastructure) Act, 2006 (as amended), as it would fall within paragraph 37 A (2) (a) of the Act; and

2. An EIS is required to be prepared under Section 37E (1) of the Planning and Development (Strategic Infrastructure) Act, 2006 (as amended).

7.0 CONSIDERATIONS RELATING TO PROPER PLANNING AND SUSTAINABLE DEVELOPMENT

7.1 I note that the Board, under section 37B(3)(c) of the Principal Act, may provide advice to prospective applicants as to what considerations, related to proper planning and sustainable development or the environment, may, in the opinion of the Board, have a bearing on its decision in relation to an application. The following are regarded as relevant considerations relating to proper planning and sustainable development in this instance which the prospective applicant was informed of during the pre­application consultation process:

• Alternative sites

• Justification for the siting, scale, functioning and form of the overall scheme in planning and environmental terms.

• The constrained nature of the St. James' Hospital site and capacity for tri-location (children's hospital, adult teaching hospital and maternity hospital).

_ PL 29N.PC0158 An Bard Pleam31a Page 9 of 10

42

• The ability to accommodate the future growth I expansion of these developments individually and cumulatively.

• The developments now and into the future in the context of a new Master Plan for St. James' Hospital complex.

• Construction and demolition impacts- developing the project, decanting and the functioning of the established hospital campus throughout this phase.

• Satellite Centres - their need and applicability in the context of a national and regional strategy relating to same.

• The ability to accommodate the Satellite Centres at Connolly and Tallaght hospital sites, inclusive of their context within the Master Plans for these hospitals and the environmental and planning impacts thereon.

• The outcome in the event of one or both Satellite Centres failing to acquire planning permission or failing to be developed.

• Traffic and transportation- routing, access, modes, car parking.

• The Coombe Hospital and its developability to accommodate the proposed future maternity hospital.

• The relocation of the Rotunda Hospital to Connolly Hospital, Blanchardstown and the ability to accommodate same in the context of the Connolly Hospital Master Plan.

• Visual and streetscape impacts on the local and wider environment.

• Impacts on residential amenity- height, design, scale, structural impacts on adjoining residential properties.

• Public consultation.

·Miscellaneous- archaeology, architectural heritage, impact on infrastructure (underground services).

_ PL 29N.PC0158 An Bord Pleamila Page 10 of 10

43

B'(­i.~-

\) L o~-'

8.0 PRESCRIBED BODIES

8.1 The following is a schedule of prescribed bodies considered relevant for the purposes of Section 37E(3)(c) of the Principal Act:

(a) Minister for Arts, Heritage and the Gaeltacht (b) Minister for Communications, Energy and Natural Resources (c) Dublin City Council (d) Fingal County Council (e) South Dublin County Council (f) National Roads Authority (g) Irish Water (h) An Chomhairle Ealaion (i) Failte Ireland 0) An Taisce (k) Heritage Council (I} Inland Fisheries Ireland (m} CIE (n) Railway Procurement Agency (o) National Transport Authority (p) Minister for Transport (q) Health Service Executive

Kevin Moore

Senior Planning Inspector

July, 2015

44

... ....

45

Appendix4

ABL •• surveyors • r

1,-June 2015

Dear ~meron Square resident

Re; ProPGSecl New ChUdren's Hospbl, st. James Hospiml campus. Du1111n I

At recent ensasement RSSions between t"- tutlonal Paediatric Hospital Development lolld (NPHDB) and residents from Cameron Square, concerns were raiAd by a number of raldents 1ft

relation to any possible lmpects construction of NCH mJaht have on their homes. The NPHDI offeree~ to canv out condition Inspections of thelt PfOpertles ahud of anv p~apoad construction wortc on the above project. In response to this request we write to advise that AIL SUrwyots Ud. Chartered Building Surveyors Mite been appointed to c.ny out SCedules of Condition ~~ ahead of any proposed construc:tlon work on the above projeCt, which is sub)lct to ....,. of PJ.nnlng Permission.

NPHDB are offertna residents and bulldll'll owners. whose homes/properties are .....,.,. • ..., adjacent to the proposed works, the opportunlty to have a visual concfition survey arrild CM1t an the exterior and Interior of their property. The survey propolld is allandlnl pnautlonMy...., canfed out In advance of works commenc:lnl with no cost to the owner/oa:upler.

The purpose of the lnspectlan Is to record the ex1st1n1 structural condition of your IJfOI*lY ._ lntern.lly and extarnally. A Schedule of Condition Report lndudlftl pho_.phs. ...._ .. • be prepared and a COPV of this will be Issued to the relevlnt praperty ocnrr'er/OwMr fir dlllr review and Information.

We would antldplte that the lftSPidlon wiD lll&e approxlrnltelv Z-3 houri • Cll.,l•• • ,._ property.

we Intend to commence work on CIIMrDn SqUIN on w.ek co~ the a-~ Jll5 _. would be .,.ateful If you could make canllct with me on my mollie ....., 017..- • lrJf email ktmu••hlwn!nOI'SJc at your lllt'llelt corMnlence to lfNIIII a IUitalllt tlllt _..._fit ouf' surveyors to cany out the •MY·

Ia .. your co apl :adel' In this matter and look ron.rd 1D ..._ ... ,_.

We apprec ~ ..

vours sincerely,

I II,_ Mull~ OB73506G

----· ?L ..• •