Deirdre Carroll,

31 Cameron Square,
Kilmainham,
Dublin 8.
The Secretary,
An Bord Pleanla,
64 Marlborough Street,
Dublin 1.

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 childrens hospital providing first-rate clinical services on one
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 Inspectors 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.

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 nations 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 50100 years) than one which is merely the fastest in the short-term. (Dolphin
Report, p.42).

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:.......................................... 10

(d)

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

(e)

The inspectors Report .................................................................................................................... 23

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

Appendix 2 .............................................................................................................................................. 32
Appendix 3 .............................................................................................................................................. 35
Appendix 4 .............................................................................................................................................. 45

(a) Overdevelopment of the current site:

The plans for development of the St. Jamess site include a draft plan for future
development as detailed in section 3a of the Architectural Reports, entitled St.
Jamess Campus Draft Site Capacity Study. The current planning application is
based on this blueprint for the development of St. Jamess site, and although it
does not purport to be a development plan for the campus.., it seeks to show
. 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. Jamess 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. Jamess, 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

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
childrens 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
1

Apart from an announcement of 650 million to fund the National Paediatric Hospital, no cost projections or
sources of finance have been provided.

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..

The St. James site is zoned Z15 in the Dublin City Development Plan, the objective of which is To 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 consultants are
permitted in principle, with car park ancillary to main use open for consideration. The quantitative measures to
assess the scale of development include Plot Ratio, Site Coverage, Building Height and distances achieved between
new and existing residential areas. The indicative plot ratio of Z15 land is 0.5 2.5 in the Dublin City Development
Plan.

(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).

(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.

(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 day3. 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.

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

For example, the Dolphin report noted a significant risk of traffic congestion near the Rialto gate (Dolphin
report p.69).
4

10

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 Childrens 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 childrens 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 Draft Site Capacity
11

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 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 Jamess 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 on. Water
12

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.

13

(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 / 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
14

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.

15

Distance from ground floor of

proposed development to gable wall
of family home 18.9m
Proposed National
Paediatric Hospital
34.95m high

Proposed Family
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 34.95m
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.
16

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

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 infringement on

18

the amenity of our residence, and it contravenes the aim of Zone 2 .To protect
and / or improve the amenities of residential conservation areas.
It will negatively impact our lives and our health, as we grow fruit and vegetables
in our garden. It will be impossible to continue growing our food due to the
severe deterioration in sunlight, and therefore complete amenity of our residence
will be removed.

Increased traffic and parking: Our amenity of our residential area will be further
detrimentally affected, both during construction and if permission for this
development is granted, by additional traffic and parking. Access to the road
network is essential to access schools for our children, and to access shops and
other amenities. The added traffic will impose time constraints on normal
activities, along with added danger for children and old people.
There will be added difficulties for us to park outside our own homes, as hospital
staff and construction traffic park in Cameron Square at will.

Access: We are concerned that the steps from Cameron Square to Old
Kilmainham Road will be closed off for over a year for development. We contend
that there is no need for the NPHDB to acquire the 51 steps for
19

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 N10 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 12.5m from the main door
of our home. It will have a detrimental effect on the health of our family.

20

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.

21

Planned excavations for the National Paediatric Hospital: The drawings lodged
to an Bord Pleanla 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

22

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 inspectors Report

With respect to the inspectors 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.

23

 The constrained nature of the St. James Hospital site and capacity for trilocation (childrens 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 / 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

24

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 childrens 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 Childrens Hospital is for the provision of a for a
state of the art childrens 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.

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).

Public consultation.
Public consultation consisted of a number of drop-in sessions at which local
residents were presented with photo-montages of the proposed development.
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 O' 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.

28

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 Inspectors report. We respectfully request that
An Bord Pleanla refuse planning permission for the proposed development, and
that the NPHDB consider alternative sites for a state-of-the-art childrens hospital
on one campus, such as Connolly hospital or the Coombe site.

We thank you for considering our submission.

Yours sincerely,
Deirdre Carroll.

29

Appendix 1 Public site notice for planning permission.

30

31

Appendix 2

Source: Environmental Impact Study, Chapter 13: Micro Climate Fig. 13.36, p.13.57
32

Source: Environmental Impact Study, Chapter 13: Micro Climate Fig. 13.36, p.9.58
33

Source: Environmental Impact Study, Chapter 13: Micro Climate Fig. 13.36, p.13.59

34

Appendix 3

______________________________________________________________________________ PL
29N.PC0158 An Bord Pleanla Page 1 of 10

An Bord Pleanla
Inspectors 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 Pleanla Page 2 of 10

35

1.0 PRE-APPLICATION CONSULTATION

1.1 A request to enter into pre-application consultations in relation to the proposed National
nd
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
Boards representatives met with the prospective applicant on the following dates:
th
20 June, 2013
th
8 May, 2014
th
30 October, 2014
th
17 November, 2014
th
8 April, 2015
rd
23 June, 2015
th
6 July, 2015
th
1.2 The Boards representatives had a further meeting on 8 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
nd
consultations on 22 May 2013 comprised the construction of a 384-bed inpatient
and 54-bed daycare National Paediatric Hospital at St. Jamess Hospital, James
Street, Dublin 8. This development was the subject of discussion at the first preth
th
application consultation meeting on 20 June, 2013. At a second meeting on 8 May
2014 the prospective applicant made a submission which referred to the
development as comprising the construction of a 384-bed inpatient and 85-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
______________________________________________________________________
________ PL 29N.PC0158 An Bord Pleanla 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, Inchicore as a
main contractors temporary compound associated with the proposed development.
At a further meeting on 8April, 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.

36

Area. Further to thismeeting, the prospective applicant senta letterto the Board which
th
was received on 30 May 2014.Therein reference was made to an Outline
Construction ManagementPlan and to consideration of the useof a largelyvacant
HSE site on Davitt Road, Inchicore asa main
contractorstemporarycompoundassociated with the proposed development. At a
th
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.
th

2.2It is noted that the prospective applicant, in the letter received on30 May 2014, sought
the Boards agreementthat the composite projectat thattime of the new childrens 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.Itwas further requested if guidance could be given on whether it isappropriate to
include the planningfor the contractors compound with the application for the childrens
hospital and satellite centres or whetheritshould be submitted in isolation to Dublin City
th
Councils 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 childrens hospitalat St.JamessHospital campus, Dublin8,forminga 7storeystructure 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 Childrens Hospital Satellite Centre at Connolly Hospital campus,Blanchardstown, Dublin
15,comprisingapproximately 5,000squaremetres gross floorarea and forminga 3-storey
building to thefront ofthe existingstructure,
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 A Childrens Hospital Satellite Centre at Tallaght Hospital campus, Dublin 24,

comprising approximately 4,500 square metres gross floor area and forming a 3storey extension to the existing 4-storey building,
A Childrens Research and Innovation Centre, comprising approximately 3,000
square metres gross floor area and 4-storeys in height, at St. Jamess Hospital
campus, Dublin 8, adjoining the existing Trinity Centre for Health Sciences and
with frontage onto Jamess Street,
A 52 bed Family Accommodation Unit at St. Jamess Hospital campus, Dublin 8,
comprising approximately 4,400 square metres gross floor area adjoining the
proposed new hospital and forming a 3-storey / part 4-storey structure, and
A temporary Construction Compound, Davitt Road, Inchicore, Dublin 8, constituting
approximately 0.8 hectares of an 8.0 hectare plot.
2.4 The new Childrens 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 Childrens Hospital is proposed to link with local
and regional paediatric centres via an integrated national clinical network.
2.5 The proposed Childrens Research and Innovation Centre would be co-located with
existing academic facilities on the St. Jamess Hospital campus.
2.6 The Family Accommodation Unit would be located adjacent the new Childrens 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. Jamess 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 Childrens
Hospital. It is intended that 675 of these would be for visitors,
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with the remaining 325 for staff members. Up to 400 cycle parking spaces are proposed. In
addition to the established vehicular entrances at Jamess Street and South Circular
Road at the St. Jamess 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 Boards previous acceptance of the National Childrens
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. Jamess Hospital complex in
the vicinity of the location for the proposed National Childrens 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:
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 37A(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
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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:
An application for permission for development in respect of which a notice has been
served under section 37B(4)(a) shall be made to the Board and shall be
accompanied by an environmental impact statement in respect of the proposed
development.___________________________________________________________
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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 (2010-2022), which relate
specifically to a national childrens hospital and/or its siting at the St. Jamess
Hospital complex.
5.0 THE QUESTION OF STRATEGIC INFRASTRUCTURE DEVELOPMENT
5.1 Section 37A(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 Childrens 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 (2010-2022);
(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 Childrens Hospital
itself.
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6.0 RECOMMENDATION
6.1 Having regard to the record of the pre-application consultations between An Bord
Pleanla and the prospective applicant, I recommend that the Board decides that:
1. The proposed development constitutes Strategic Infrastructure
Development under the meaning of Section 37A of the Planning and
Development (Strategic Infrastructure) Act, 2006 (as amended), as it would
fall within paragraph 37A (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
(childrens hospital, adult teaching hospital and maternity hospital).
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 The ability to accommodate the future growth / 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).
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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 Ealaon
(i) Filte Ireland
(j) An Taisce
(k) Heritage Council
(l) 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

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Appendix 4

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