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Our Ref: 29N.

PA0043
P.A.Reg.Ref:
Your Ref:

Jean Early & John Lane


11 McDowell Avenue
Ceannt Fort
Mount Brown
Dublin 8
8th October 2015
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.

Dear Sir/Madam,
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 be advised that copies of aU 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 Pleamila 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 Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

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\.Ki~ran Somers

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&x~cutive Officer "'-.
Direct Line:01-8737107
Encls.
ADHOC/PA0043/0 1

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Our Ref: 29N.PA0043


P.A.Reg.Ref:

An Bord Pleamila

Your Ref:

Paul 0 1Neill
National Paediatric Hospital Development Board
C/0 G.V.A. Planning & Regeneration
Floor 2, Seagrave House
19-20 Earlsfort Terrace
Dublin 2
5th October 2015
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.
Dear Sir,
Enclosed for your information is a copy of submission(s) received by the Board in relation to the above mentioned
proposed development.

If you have any queries in relation to the matter please contact the undersigned officer of the Board.
Please quote the above mentioned An Bord Pleam11a reference number in any correspondence or telephone contact with
the Board.
Yours faithfully,

Encls.
PAOS.LTR

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Our Ref: 29N.PA0043


P.A.Reg.Ref:
Your Ref:

Chief Executive Officer


Dublin City Council
Civic Offices
Wood Quay
Dublin 8
5th October 2015
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.
Dear Sir/Madam,
Enclosed for your infonnation are two copies of submissions received by the Board in relation to the above mentioned
proposed development.
Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.
If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the
above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

eran Somers
cutive Officer
Direct Line: 0 1-8 7371 07
Ends.
ADHOC/PA0043/02

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Our Ref: 29N.PA0043


P.A.Reg.Ref:
Your Ref:

Chief Executive Officer


Fingal County Council
County Hall
Main Street
Swords
County Dublin
5th October 2015

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.
Dear Sir/Madam,
Enclosed for your infonnation are two copies of submissions received by the Board in relation to the above mentioned
proposed development.
Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.
If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the
above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

~
~Somen~
: cutive Officer
Direct Line:O 1-87371 07
Encls.
ADHOC/PA0043/02

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Our Ref: 29N.PA0043


P.A.Reg.Ref:

An Bord Pleanala

Your Ref:

Chief Executive Officer


South Dublin County Council
County Hall
Tallaght
Dublin 24
5th October 2015

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.
Dear Sir/Madam,
Enclosed for your infonnation are two copies of submissions received by the Board in relation to the above mentioned
proposed development.
Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.
If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the
above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

ran Somers
cutive Officer
Direct Line:O 1-8737107
Encls.
ADHOC/PA0043/02

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AN BORD PLEANALA
TIME \6 : Z.K IV,~=~

0 2 OCT 2015

Jean Early & John lane


11 McDowell Ave,
Ceannt Fort, Mount Brown,

----------- ---

Dublin 8.

301h September 2015


The Secretary
An Bord Pleanala
64 Marlborough Street
Dublin 1

AN BORD PLEANALA
Received: A

t-b l1
0

Fee: -ES'o.DO
Receipt No:

J3 I 3 12- I b

Case reference: PL29N.PA0043

Health Infrastructure Development comprising National Paediatric Hospital,


Innovation Centre and Family Accommodation Unit at StJames' Hospital
Campus, Satellite Centres at Tallaght and Connolly and Construction Compound
at Davitt Road, Dublin.
Dear Sir or Madam

Please find attached a copy of our submission in relation to the proposed application
Pl29N.PA0043.
We would appreciate the opportunity of clarifying and expanding on the attached report at
an oral hearing.

The relevant fee of 50 is enclosed.

Yours Sincerely

Jean Early, MRIAI

Jean Early & John lane

NCH PLANNING APPEAL Ref# Pl29N.PA0043

. ..
., '

Contents

1.0

SUMMARY

2.0

ZONING & DEVELOPMENT PLAN..

3.0

TRANSITION WITH RESIDENTIAL ZONE

10

4.0

TRAFFIC & SITE ACCESS

11

5.0

CAR PARKING

15

6.0

HELICOPTER LANDING PAD

16

7.0

SCALE, HEIGHT & FORM

17

8.0

CONSTRUCTION IMPACT

22

9.0

IMPACT ON RESIDENTIAL AMENTITIES

22

10.0

SITE EXPANSION

23

11 .0

FUTURE SITE MASTER PLAN

24

12.0

PROPOSED OPEN SPACES

24

13.0

DOLPHINS REPORT & ALTERNATE SITES

24

14.0

COMMUNITY GAINS

25

15.0

RESIDENTS PARTICIPATION

25

16.0

AN BOARD PLEANALA INSPECTORS REPORT:

26

17.0

CONCLUSION

29

18.0

APPENDIX# 1

32

Rev A
27 September 2015

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6

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NCH PLANNING APPEAL Ref## Pl29N .PA0043

Jean Early & John Lane

Case reference: PL29N.PA0043


Health Infrastructure Development comprising National Paediatric
Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght and Connolly and
Construction Compound at Davitt Road, Dublin.
1.0

SUMMARY

We are residents of Ceannt Fort (Zone Z2 Conservation area) and would like to state
that we are in favour of a project which will brings together three existing children's
hospitals: Our Lady's Children's Hospital Crumlin, Temple Street Children's
University Hospital and the National Children's Hospital at Tallaght Hospital under
one roof as it benefits the entire country and most importantly the Children of the
Nation.
However our concerns relate to the proposed St James Hospital location as the
proposed scheme is way over sized for the available site and will have a detrimental
impact on our neighbourhood from both a planning and amenity point of view,
building heights, site density and traffic volumes. Our concerns include, but are not
limited to, restricted access, noise pollution, helicopter Pad, transportation, limited
parking, no Maternity Co-Location, lack of expansion space on site and the
misinformation given to the general public in relation to this scheme
This Planning Application is egregiously misleading to the General public, to the local
neighbours, the Minister of Health and to An Board Panela. Throughout the design
process and as part of this application the Design Team and The National Paediatric
Hospital Development Board has continually referred to this project as being 7 stories
high (above 3 Basement levels) when it is in fact 8 stories high (above 3 Basement
levels).
We believe that The National Paediatric Hospital Development Board have been
wilfully and deliberately negligent by talking down the scale I extent of the scheme
and telling the general public and An Board Pleanala Inspector, Kevin Moore, that the
scheme Is only 7 stories high (with a 3 storey basement) and publishing same on
their web site. The submitted Planning documentation refers to a 7 storey building at
its highest in the Environmental Impact Statement (EIS). Even Minister Leo
Varadkar's own web page and his public launch, along with many interviews, all refer
to the New Children's Hospital as a 7-Storey Building.
Because the general public and neighbours read this they have been directed to
deliberate untruth. Thus all notification for this hospital including press statements
and Ministers statements are fatally flawed and contrary to the provisions of the
planning statue and regulations .

rr
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Jean Early & John Lane

NCH PLANNING APPEAL Ref I# PL29N.PA0043

We would ask, as a minimum, that the planning process be restarted with


truthful information regarding the height of the facility and that all publication
material be withdraw and corrected, including Minister's statements.
Because of the misleading information regarding total building height, we have
no faith in The National Paediatric Hospital Development Board planning
submittal and would ask "what other untruths lie within this planning
application?"
See a copy of the building sections as submitted below with each floor level where
we have added the number of each floor in red.

SKETCH1

SKETCH2

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Jean Early & John lane

NCH PLANNING APPEAL Ref# PL29N .PA0043

1.1

2.3

Extract from the Pre Planning Consultation with An Board Pleanala:


Inspectors Report Ref PL29N.PC0158 by Kevin Moore dated July 2015

The proposed development now comprises:

A 473 bed children's hospital at St. James's Hospital campus. Dub lin
8, forming a 7-storey structure over three basement levels on a site of
4.85 hectares, comprising approximately 122,727 square metres gross
floor area (exclusive of approximately 30,000 square metres of
basement car parking),

A Children's Hospital Satellite Centre at Connolly Hospital campus,


Blanchardstown, Dublin 15, comprising approximately 5,000 square
metres gross floor area and forming a 3-storey building to the front of
the existing structure.

PL 29N.PC0158

An Bord Pleanala

Pace 3 oflO

See Appendix # 1 for references In the EIS, The NCH Website, Public Site Notices,
Minister of Health Website (Leo Varadkar) and various Interviews all stating the
building is 7 stories.

Rev A
27 September 2015

PageS

Jean Early & John Lane

NCH PLANNING APPEAL Ref II PL29N.PA0043

For reasons outlined below we would propose that a swap is done and that the
satellite unit proposed for Connolly Hospital site is constructed at St James Hospital
and the new NCH is relocated to the greenfield Connolly site which offers unlimited
site expansion potential with no enabling works requirements. This site has a low
planning risk as set out in The Dolphin Report, Further assessment of planning
issues in relation to proposed sites: Report submitted to Dr. James Reilly T.D.,
Minister for Health, by Simon Clear and John Martin: 19 October 2012.

Alternately, if the Government are set in keeping the site in the city centre I Dublin 8
the entire NCH Building could move to the Coombe site as there is adequate land for
development, parking, future expansion, contractors compound and more importantly
an existing functioning Maternity Hospital. This site also got rated as a low planning
risk in the Dolphin Report.

2.0

ZONING & DEVELOPMENT PLAN

Ceannt Fort Residential Estate is zoned Z2 under the current Dublin City
Development Plan 2011-2017 which states "To protect and/or improve the amenities
of residential conservation areas"
St. James Hospital site is Zoned Z15 under the current Dublin City Development Plan
2011-2017 which states "To protect for institutional, educational, recreational,
community, green infrastructure & health uses. "
Chapter 3 of the EIS Section 3.5.1.2 states: In relation to Z2 zoned lands it is the
policy of Dublin City Council to ,.... protect the special character of the city's
conservation areas through the application of the policies, standards and guiding
principles on building heights", and to protect and conserve the special interest and
character of Architectural Conservation Areas and Conservation Areas in the
development management process.
Ceannt Fort is a 100 year old housing estate which is referenced during the 1916
risings, when Eamonn Ceannt and his Comrades were located on the adjacent site of
the current St James Hospital and where fighting occurred at both the current Rialto
Gates and the proposed CRJC Building over looking James Street. The Ceannt Fort
Estate, formally known as the McCaffery Estate, was the first public housing estate in
the country designed by Architect TJ Byrne. Next year is the Centenary of the 1916
rising and the Ceannt Fort Community will be heavily involved in the celebration of
the 1916/2016 centenary anniversary. We are of the opinion that the proposed
development does NOTHING to protect the special character of our estate as
required under the development plan.

f ~soROPLEANALA

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NCH PLANNING APPEAL Ref# PL29N .PA0043

2.1

Jean Early & John Lane

SITE BOUNDARIES

We wish to question the site boundaries as set out for this proposed development.
The boundary, per the drawings, conflicts with the planning compliance schedule as
referenced in section 2.2 below. There is a lack of clarity as to what area sizes are
relevant. Currently the area of the red line on the site plan is larger than the areas
used in the planning calculations and the planning report. Could the board please
determine what is the legal and validated document we should assess the figures
against?

2.2

PLOT RATIO

The Plot ratio for St. James Hospital site under the current Dublin City Development
Plan 2011-2017 is to be between 0.5-2.5.
The submitted Planning Report Section 15.4.1.2 Policy Compliance (Table 8 Policy
Compliance Schedule) states:

"The new children's hospital building, including the family accommodation unit
(excluding the Children's Research and Innovation Centre), measures 92,031sq.m.
(above ground) on a site of 48,350 sq.m., which results in a plot ratio of 1.90.
If the basement areas were included the floorspace figure would rise to 122,472
sq.m. and give a plot ratio of 2.5. It should be noted, however, that as a measure of
density, plot ratio is concerned with volume and is designed to control the bulk and
mass of buildings, therefore, it relates primarily to those areas that are above ground
level"
We contend that as the basement (all 3 levels) is ground level for part of the site at
Mount Brown it MUST be included in the calculations giving the ratio of 2.5 which is
the maximum allowed and does not facilitate any future expansion which will make
the plot ratio non compliant. See Photo below

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# Pl29N.PA0043

The Plot Ratio for the CRIC Building was not included in the Planning Documents.

2.3

SITE COVERAGE

The maximum allowable site coverage for St. James Hospital site under the current
Dublin City Development Plan 2011-2017 is 50%
The submitted Planning Report Section 15.4.1 .2 Policy Compliance (Table 8 Policy
Compliance Schedule) states:
MResiduaf ground floor area is 20,305sq.m. which gives a site coverage of 42%"

The raised Meadow Gardens needs to be included in this figure (future site
expansion area) as from the image below it is raised and should be noted as part of
the site coverage which would increase the published figure.
The black line below denotes the ground foot print of the buildings including the
elevated Meadow Garden.

The Site Coverage for the CRIC Building was not included in the Planning
Documents.

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

2.4

OPEN SPACE

The Open Space requirements for St. James Hospital site under the current Dublin
City Development Plan 2011-2017 is 25% open space.
The submitted Planning Report Section 15.4.1 .2 Policy Compliance (Table 6 Policy
Compliance Schedule) states :
"Ground floor open space area is 9,000sq.m. with accessible open space at all levels
at 13,000sq.m., or 27%, with a total of 22,000sq.m. of open space at all levels"

We note that the open spaces as calculated in the planning submittal appear to take
in the Luas track I park which is not currently in the owner ship of StJames Hospital.
When Phase 2 gets constructed the open space of the Meadow Garden will
disappear.
The Open Space for the CRIC Building was not included in the Planning Documents.

2.5

BUILDING HEIGHTS

The current maximum allowable height for St. James Hospital site under the current
Dublin City Development Plan 2011-2017 is 7 stories /26M above ground level.
The proposed scheme is for an 8-storey building above ground level with an overall
height to the top of the ridge level of 34.95m (Ordnance Datum 55.95), almost 7
meters taller than currently allowed in the Development Plan. The stacks on top of
this structure add another 3 meters to the height.
When you measure the building from Mount Brown, the new proposed site entrance,
the building rises to 11 stories above the existing houses along the street as level
B02 (the basement level 3 stories below the Ground floor level 00) is aprox 1.2m
above the existing street level. From Mount Brown , this will mean the development is
aprox. 46m tall. Currently the scheme is set back from the street but once the
Hospital expansion space is developed over the Meadow Garden, the building will
loom 10 or 11 stories above street level.

_oc
PROPOSED
EXPANSION eroo
FotHCH

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N .PA0043

3.0

TRANSITION WITH RESIDENTIAL ZONE


The Development Plan, Section 15.9 TRANSITIONAL ZONE AREAS states ~that the
land-use zoning objectives and control standards show the boundaries between
zones. While the zoning objectives and development management standards
indicate the different uses permitted in each zone, it is important to avoid abrupt
transitions in scale and use zones. In dealing with development proposals in these
contiguous transitional zone areas, it is necessary to avoid developments which
would be detrimental to the amenities of the more environmentally sensitive zone.
For instance, in zones abutting residential areas or abutting residential development
within predominately mixed-use zones, particular attention must be paid to the use,
scale, density and design of development proposals and to landscaping and
screening proposals in order to protect the amenities of residential properties."
We consider that this development does not take this into consideration. Along the
perimeter of the site existing trees, which were identified as aiding to the transition
between the smaller buildings allowed for in 2009, are no longer accommodated in
the plans. The abrupt changes of scale to the new Hospital and its adjacency to the
low rise housing stock means this criteria has been ignored. For example see the
before & after view of O'Reilly Avenue.

O'Reilly Avenue After

O'Reilly Avenue Before

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

4.0

TRAFFIC & SITE ACCESS


At the moment the local road network is at capacity. The additional traffic
generated by both the construction works and the new development, once
operational, will push the roads to the limit. It is not unusual for the traffic to be at a
standstill during rush hours especially when there are concerts in IMMA,
Kilmainham where local road closures are imposed.
4.1 ST. JAMES MAIN HOSPITAL ENTRANCE
All traffic going to St. James Hospital will in future have to enter & exit James
Street thus increasing the traffic flow on in James Street and Mount Brown and
adding to the flow in James Street and the area in general. Has this been taken
into account in the traffic planning module as the figures in the report don't seem to
reflect this?
Junction 13: St James's Hospital Main Entrance

'=
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As stated in the planning application there will be no through traffic between the
New Children's Hospital and St. James Hospital, except for Buses and
Ambulances. The consequence of this is that ALL traffic for Dublin South I South
East will have to exit St. James Hospital and turn left onto Mount Brown and
towards the junction to proceed onto the Canal via Suir Road (where they will meet
the construction traffic for the NCH during the construction phase). This traffic will

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

be additional to the existing daily traffic and will also encounter the traffic entering
the NCH car park on Mount Brown. This will increase the traffic on Mount Brown.
AU traffic leaving St. James Hospital for the N4IN6 will now have to turn right onto
James Street and left at the junction of James Street I Bowe Lane I Stephens Hill
(Crossing the Luas Line) and go on to the Concolbert Road Chapelizod bypass
and on to the N41N6.
The total number of patients attending St. James Hospital per their annual report is
400,000 annually. The projected figure for the new Children's Hospital is 368,438
annually. The total figure for both hospitals will be 768,438 annually. That's three
quarter of a million people into this confined area of the city. The above figures
exclude visitors to both hospitals and do not include the planned Maternity Hospital
and significant increase in patient treatment proposed as a result of St. James
Hospital proposed expansion plans as set out in this application.

4.2 CEANNT FORT ENTRANCE

The new proposed Left turn only lane from the main entrance to St. James Hospital
main entrance is going to be detrimental to the Residents of Ceannt Fort who will
be trying to enter I exit the estate. Currently there is usually a break in the traffic
when the Luas enters the hospital site as the tram traffic lights turn red to stop the
cars. If this new filter Jane is added at St James entrance there will be no break in
the traffic to allow cars in and out of this established entrance. We would request
that a more detailed analysis of the traffic count is developed as the figures in the
report don't reflect this change in traffic routes.

4.3 TRAFFIC COUNTS


See the appeal lodged by SCR I Kilmainham Residents for an analysis of the traffic
data.
The cumulative impact of other large developments in the area has not been
considered in relation to traffic such as Diageo, new student housing and other
major developments in the area. We would request that an expert on traffic attends
the oral hearing to provide certainty with this application in relation to the traffic.

4.4 NO BUS LANES


StJames Hospital is the only city centre hospital which has NO BUS LANES on its
approach to either entrance which could facilitate ambulance access. As the
existing road network is so narrow there is no chance of installing same either.
A local resident recently took this photo of an ambulance trying to travel durin th
rush hour t~affic along Mount Brown (close to the pr

!NJlfA

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Jean Early & John Lane

NCH PlANNING APPEAL Ref# Pl29N.PA0043

September 2015. In this instance the only way the ambulance could get through
the traffic, which was at a standstill, was for the cars to mount the narrow footpaths
to give it access to the St. James Hospital Site.

PHOTO 4: Ambulance trying to pass traffic (which Is at a standstill) at Mount


Brown 17th September 2015 @4.16pm

4.5 PROPOSED ENTRANCE TO MOUNT BROWN I CONSTRUCTION ACCESS

We would like to request that a traffic expert attends the oral hearing to provide
certainty with this application in relation to the carrying capacity and cumulative effect
the new site entrance will have on this application. This proposed entrance will serve
the new energy centre located in the basement and it is hard to see how the large
trucks shown on the Basement plan drawing no. NPH-A-BDP-Pl-82-00-1201 can turn into
this entrance in one swing. It isn't possible for a large delivery truck to turn in while
one is exiting and this should be shown on the drawings. We believe that the existing
buildings on either side of the new entrance present a restricted view to the street.
This entrance is also the main entrance for cars entering I exiting the car park and
these cross over with the trucks and the pedestrians. There is currently no proposal
to have any signals at this entrance. This is going to be problematic for cars trying to
ex!t from the existing roads which are close by leading to Ceannt Fort and Brookfield.

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NCH PLANNING APPEAL Ref II Pl29N.PA0043

Jean Early & John Lane

The road at this location is liable to flood and is considered a high flood risk area.
The local houses along this street can no longer get insurance to protect against
flood damage. Should there be another flood there is a good chance that the
proposed basement may get flooded, as this is the location of the proposed energy
centre, which will be powering up both NCH & SJH we would have to question the
wisdom of locating an Engery Centre underground in a flood risk area?
Bad and all as the new entrance will be when operational how will this narrow
entrance cater for the construction traffic which is scheduled to enter I exit from this
route? The volume of construction traffic proposed in the EIS reports will have the
road at Mount Brown at a standstill.
The seperate services drawings submitted as part of this application show the new
gas mains located at this entrance with a gas skid located along the foot path to
the left hand side of the ramp. Due to the size and location of the new proposal the
existing site gas mains are to be dug up and relocated. This will add schedule
delay and cost impact to the project.
The existing water mains on site serving SJH also has to be diverted. A new water
mains for SJH plus a separate supply for the NCH, both with their own dedicated
water meters, are also to be located at the new entrance ramp connecting with the
public water mains along Mount Brown Road .
The existing Driminagh sewer which runs through the site has to be diverted to
accommodate the new NCH footprint. This new connection will also be located at
the new Mount Brown ramp exit on the main road. New connections are also
proposed on Mount Brown Road for the new sewers accommodating the both the
NCH and the diverted SJH drainage.
The question is how can all of these service elements be constructed while at the
same time a site construction access is operational to construct the building at this
narrow entrance? Has a detailed constructability review been held and just what
schedule impact will this have on the project?
How will the required road closure be accommodated during these road works?
Has the impact of the additional cars been accounted for from the St. James
entrance as the internal through road will be closed during this period?

AN soRO PLEANALA
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02 OCT 20\5

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Rev A
27 September 2015

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f~---.

Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

PROPOSED WATER MAIN CONNcnON

NEWGASSIUO
on Cone. Plinth
wll!l Pallsadt! '"'""

BELOW GROUND
RAMP

; ~. .
l----

NEW Anenuatlon tank

4.6 ACCESS TO THE CRIC SITE


During the construction phase the problem arises of entry to the CRIC site. This has
not been addressed fully. The options for building material-carrying trucks are limited.
Either the trucks access the site via the main James St entrance, hugely disruptive to
normal patient access, or an entry is forged in the gap at the limit of the proposed
structure at James St and the boundry wall of No.1 McDowell Avenue, which is
located at a bend in the road and will block the line of vision for cars exiting Ceannt
Fort.

5.0

CAR PARKING
Car parking on the St. James Hospital site is already beyond capacity.

Section 2, Table 2.2, of the Design Report states that there will be 48 no Disabled
Parking Spaces and 952 no car parking spaces (Total 1000) provided as part of
this Development. The reality is that there are only to be 420 NEW spaces as part
of the development as an existing 540 spaces currently serving StJames Hospital
and the Trinity Research Centre are to be removed as part of the demolition works
required to prepare the site to receive the new National Children's Hospital. This is
wholly in adequate to service the proposed new development and will impact the
functionally of the existing hospital. But of even great concern is the effect on the
local residents in our estate who currently have h .Q!!1Ls.tafLand-'ltisitor:s=a~iling-

AN BORD PLEANALA
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02 OCT 2015

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FROM_

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Jean Early & John Lane

NCH PLANNING APPEAL Ref## PL29N .PA0043

of free parking in our streets blocking access to houses and taking the residents
parking spaces.
We are currently plagued by staff and visitors to the hospital parking on our streets.
As it is such an old estate the streets are very narrow and can't take the capacity of
the additional cars. The streets are so narrow that Dublin City Council have said
that paid I residents parking cannot be put in place.
St James Hospital currently has aprox. has 4,500 staff and the new Children's
Hospital will bring an additional 2,300 staff to the site. Applying the standard
parking needs of a modern hospital, the St. James site before factoring in the
parking needs of an onsite maternity hospital, Trinity Research and Educational
facility, relocation of St. Luke's hospital and the expansion of the adult hospital as
indicated in the Site Capacity study submitted by the NPHDB requires in excess of
6,000 parking spaces to accommodate staff, visitors and patients. Dublin City
Council has limited the total number to 2,000 spaces for the entire site due to the
inadequacy of the local road network.

Of great concern to us also is the proposed new entrance from Mount Brown to the
proposed Basement Carpark as the roads are busy at the best of times along here
and won't be able to take the additional cars waiting to turn in I out of the proposed
new entrance. See Section 5 above.
The traffic plans are completely unrealistic: Page 24 of the Draft Site Capacity
Study: ~ ... 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 ... w and further that "..... should the expansion of
the campus development as set out in the Draft Site Capacity Study be fully
realised then that staff modal split would reduce to 18%.....". Where do these
figures generate from? It should be noted that currently 77% of staff at Crumlin
hospital bring their cars to work. Many live beyond the Luas line and the Luas is
currently packed during peak rush hours.
75% of children attending hospital for specialist consultant care come from outside
the MSO. They account for half of day cases and one third of all admissions. These
are the sickest children of all and yet these are the children that will be most
inconvenienced if the New Children's Hospital is built in James'. Emergency access
is also compromised for children coming by ambulance as the difference of 20
minutes in traffic can be the difference between life and death

6.0

HELICOPTER LANDING PAD


We have a genuine concern in relation to the proposed location of the new
Helicopter Pad and its proximity to the adjacent residential units because of the
noise and the light pollution during night operations. It is recommended that
Helipads are best located at Ground Level but because of the over development of
the site there is no free space at ground level. The site proposed for the helicopter
pad is on the roof of the fourth floor, right in fron!l.
. ~~~~~~~~~~rv~

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be scary for the kids at night) and adjacent to the overhead wires for the Luas
below. By locating the heliport above ground level only helicopters with
Performance Class 1 capability are permitted to land at or take-off from elevated
heliports.
The provision of Rescue and Fire Fighting Services (RFFS) at elevated heliports is
mandatory. We are aware of Dublin City Fire Brigade concerns regarding attending
an emergency situation at sites above ground level as their access is compromised
at that location.
As the helipad is located in a congested area we note the requirement for sufficient
open space in case a forced landing is required. This has not been provided in the
current scheme. All the above will add to the project costs.
Can the NCH confirm that the Heliport is designed to the standards outlined in
OAM No. 08/00 (Irish Aviation Authority)? How many flights are proposed weekly?
Could a member of the Irish Aviation Authority attend the oral hearing to provide
certainty with this application?

7.0

SCALE, HEIGHT & FORM

7.1 New Children's Hospital (NCH)


This Development will have a significant impact on the quality of life to the local
residents living beside the development especially those living in Ceannt Fort. It
also has a negative impact on the residents of SCR, Brookfield Road, Cameron
Square, Faulkner Terrace, St John Terrace, Old Mount Brown, Rialto and St
James Walk.
The bulk and masking of the buildings completely over shadow the dwellings and
will ruin the existing quaint character of our beautiful estate. All houses will be
completely over looked and will have no privacy at all. Of even greater concern is
the proposed construction of a 3 storey basement and the possible structural
damage it will have on the adjoining properties. As well as the basement, it is
proposed to reroute the existing Driminagh sewer along with the existing
drainage to the existing Adult Hospital, existing ESB power supply, existing gas
mains along the rear of O'Reilly Avenue. The new drainage required to serve the
NCH will also be located here as will the new underground, 3m high, service
tunnel to link to the existing Energy Centre.
The existing main hospital road is to be rerouted and shall run along the rear of
O'Reilly Avenue. This will serve as the main access to the current Adult A&E
along with the New Children's Hospital A&E. It is also the proposed route for
Dublin bus and passengers on the top deck will be able to see into the rear of the
houses.
At the public reviews the size and l_ocation of the proposed expansion sites over
the Meadow Garden arid the A&E drop off area was never discussed. A

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AN BORO PLEANALA
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27 September 2015

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02 OCT 2015
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PL.

Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

proposed 6 storey structure in this area will completely block off the day light to
the houses on O'Reilly Avenue and Cameron Square.
These and further issues shall be addressed as part of a future joint Residents
observation.
Note: Clinical & Medical Argument against Tri-location shall be subject of a
separate observation by qualified Medical Professionals.

7.2 New Research Centre (CRIC)

In the Dublin City Council Development Pan 2011-2017 the prosed CRIT
site along with our street of houses on McDowell Avenue are located in "a
zone of Archaeological Interest"
This development is to be located to the rear of our house on McDowell Avenue
in Ceannt Fort. No consideration appears to have been given to the design which
shoehorns these oversized buildings into this ancient and historical site. We are
incensed to see that in the Archology report there is no reference to the part
these buildings played in the 1916 rising (as occupied by Eammon Ceannt) and
that no consideration was made to incorporate part of the existing fa~;ade fronting
James Street in to the proposed design.
No consultation with the Residents prior to lodging the application took place as
the first time the drawings were ever revealed publicly was on Thursday 6th
August 2015 prior to lodging the application the following Monday 1Oth August
2015.
Section 3.1 of the Design Report states
"The design of the building has been developed in response to the site
context, the proposed integration with the surrounding buildings and the
requirements of the brieF
This is absolutely NOT the case when you look at the scale and adjacency of the
domestic houses that this development over shadows. The proposed
development is only located 1.89m from the existing boundary wall and less than
5m from the gable wall to house no. 1 McDowell Avenue. There is also an infill
building built against the boundary wall. Apart from complete loss of privacy, as
windows on 3 levels overlook the properties, there is also the issue of loss of
light due the massing and scale of the proposed building. The proposal shows
that the gas cylinders, waste tanks, labs waste etc is all to be located between
the new buildings and the existing houses. This is not acceptable due to the risk
of explosions and the additional noise that will be generated due to waste I gas
. delivery & collection.

AN BORO PLEANALA

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27 September 2015

02 OCT 2015
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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

The existing boundary wall between the site and the houses along McDowell
Avenue is an historical artefact and must be protected. There is great concert
that this could be damaged during the basement excavation works. There is no
reference in the report as to how they plan to mitigate against this. This wall is
over 200 years old and was the boundary wall to the South Dublin Union
separating it from Cut Throat Alley which is now the rear gardens to McDowell
Avenue.
The proposed new pedestrian access off James Street is, arso a grave cause of
concern as it opens up the rear of the houses to the general public and is a
security risk.
Many of the residents living in #1-7 McDowell Avenue work shift hours and how
can this be accommodated during construction?
No Conditioning Survey was offered to the residents of McDowell Avenue which
is surprising as these properties have a higher risk of structural damage due to
the proximity of the development than the houses along Cameron Square &
O'Reilly Avenue.
These and other issues have been addressed as part of a McDow.ell Avenue
Residents observation submission.

Photo # 1:Existing view of CRIC site from James Street

Rev A

27 September 2015

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Jean Early & John lane

NCH PLANNING APPEAL Ref II PL29N.PA0043

ANBORO

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Photo # 3: Former Entrance to St James Hospital

Photo .# 4: Existing wall & part of school house which are proposed to be
demolished to make way for a 3 storey building with modern cladding.

Rev A

27 September 2015

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Jean Early & John Lane

NCH PLANNING APPEAL Ref I# Pl29N.PA0043

7.3 Family Accommodation Unit (FAU)


This development is to be located at the current Rialto entrance. There are
serious concerns from the residents on Brookfield and SCR roads in relation to
overlooking.
The following FAU Drawings are missing their North points:
FAU Site Plan Dwg No NPH-A-BDP-PL-00-FA-1100
FAU Level 00 plan Dwg No NPH-A-BDP-PL-00-FA-1200
FAU Level 01 Floor Plan Dwg No NPH-A-BDP-PL,-01-FA-1201
FAU Level 02 Floor Plan Dwg No NPH-A-BDP-PL-02-FA-1202
FAU Level 03 Floor Plan Dwg No NPH-A-BDP-PL-03-FA-1203
FAU Level 04 Floor Plan Dwg No NPH-A-BDP-PL-04-FA-1204
FAU Level LG Floor Plan Dwg No NPH-A-BDP-PL-LG-FA-1205
If these drawings had been lodged with the Local Authority, Dublin City
Council in their current state, I believe the Planning Application would have
been invalidated.

7.4 Tallaght Hospital Satellite Unit


Why are the board going to the expense of building a "new" Satellite Unit when
they could easily use the existing Children's Hospital Building on site for this
purpose saving millions of Euros in the process?

7.5 Connolly Hospital Satellite Unit


We would propose that the function, scale and size of the Satellite unit is more
appropriate to the current NCH site at StJames Hospital as per our comments
above.
7.6 Davitt Road Construction Compound
We are most concerned at the additional impact the traffic on the roads will have
on the local residents due to the off-site location of the Contractors compound.
If there was sufficient site capacity at St. James Hospital there would be no need
to have the expense and logistical nightmare of an off-site Contractors
Compound. Both the Coombe site and Connelly Hospital site, as referenced in
our introduction, would have the capacity to host the Contractors Compound
thus saving costs and schedule due to added travel times. These concerns have
been addressed as part of a SCR Kilmainham Residents observation
submission.
A new Apartment development has just got planning permission beside this site
at Davitt Road . Have any allowance been made to the traffic calculations as this
development will be on site during the period that all the NCH traffic will be to
and fro from the site.
:

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8.0

CONSTRUCTION IMPACT
These and other issues have been addressed as part of the local Residents
observation submission and will be developed for the oral hearing.

9.0

IMPACT ON RESIDENTIAL AMENTITIES


9.1 Day light
The proposed new buildings on the StJames Campus do impact the existing
housing adjacent to the various developments. The loss of light will severely
impact the resident's quality of life as well as increase their utility bills as it will
be necessary to use more artificial lighting. The single shadow study done for
the main NCH does not show the true impact as a single day in September
was selected and this would not illustrate the worst impact. Ref. Appendix 4:1
Overview of Long List Design Options
No similar study, using a visual model, was done for the houses at McDowell
Avenue which will be in shade due to the proposed CRIC building. We would
ask that his be carried out at monthly intervals for 12 months of the year.

9.2 Settlement & Damage to housing


Could the Board explain why some houses had a survey and others were
ignored? What Is the Boards legal obligation in relation to same? Is there a
conflict of interest in appointing the Structural Engineers for the project to take
on these surveys?

9.3 Noise
The noise generated during construction will be unbearable to the local
residents if current form is anything to go by. So far as part of the site survey
piling works have taken place after normal working hours as have drain
surveys. The generation of extra traffic caused by an off-site Contractors
compound will add to this problem. The Board have noted on some plans the
location of noise monitors but we wish to know how will the residents be able
to access the data from them? Should the noise level exceed the permissible
allowed what action will be taken and by whom?

9.4 Light pollution


The proposed scheme involves lighting up the site like a Christmas tree.
The new Hospital Building has down lighters along the perimeter of the
building and at all the entrances. Also each of the roof gardens are 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-E-ARUP-DR-XX-ST-1002 for details.
Lighting is proposed along the new road which runs behind tl:le rear of houses
at O'Reilly Avenue. These consist of Type A along road- both sides 6m pole
top luminaire LED, 100% DLOR, dimmable:;,-----~~~~-:-,

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27 September 2015

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Jean Early & John Lane

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Reference Drawing no. NPH-E-ARUP-DR-XX-ST-1001. The new proposed


boundary wall is aprox 2m high so light will shine over this wall into the rear
of the houses on O'Reilly Avenue.
The lighting scheme to the to courtyard of CRIC Buildings consists of Type L
8m pole top luminaire LED, controlled light distribution, dimmable & Type B
4m pole top luminaire LED, 100% DLOR, dimmable. These will shine into the
rear of the adjoining dwellings on McDowell Avenue over the existing back
garden wall.
Ref Drawing no. CRIV NPH-E-ARUP-DR-XX-RB-1001.
The elevated Helipad will also contribute greatly to the light pollution when in
use.

9.5 Traffic
See Section 4.0 above
There is currently no Taxi Rank in St James Hospital as this was removed
about 5 years ago.

9.6 Vermin infestation


Residents have grave concerns that once the works start on site demolition,
rerouting the sewers and the basement construction there will be an invasion
of rodents and other vermin into the adjoining residences and in to the adult
hospital buildings causing a genuine health risk to the public and patients. We
have not seen anywhere in the documents how the board plan to control this
and what mitigating procedures are planned to be put in place. This is
currently a major issue for the residents close to the MISA building which is
under construction on the St. James's Hospital site. Dublin City Council are
fighting a losing. battle in attempting to deal with this issue as they are so
under staffed.

9.7 Aspergillus/Legionnaires Disease


We would like to know what specific mitigation actions are planned for the
safety of local residents as well as hospital patients for the extended duration
of this excavation work. Also, as an Asthma sufferer, what plans are in place
to limit the dust on site?

10.0

SITE EXPANSION
The proposed site expansion of min 20% will severely impact the current building
design both functionally and visually as the current design does not lend its self to
expansion. But worse than that will be the detrimental impact it will have on the
adjoining houses and the Residents quality of life as basically the site capacity is
too small. There would be serious constructability issues too for both the patients in
the NCH, the adult St. James Hospital and the local residents as the current
proposed construction entrance will by then be operational as a main access route
to the basement car par for patients and visitors. This access also is the
acc~s to the new proposed FM (Facility Managem
r9
~ll:Jlti.U

.
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27 September 2015

0 2 OCT 2015
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FftOM

Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N .PA0043

underground at the lowest basement level. This FM facility serves the entire St
James Campus not just the NCH. The Meadow Garden, on which a 6 I 7 storey
structure over is surrounded on 3 sides by the main road which serves the entire
campus, main bus route and access to both the children's and adults A&E .
We note that there are no plans to increase the parking by 20% due to the lack of
space on site again supporting our argument that the site is unsuitable and too
small for its proposed use.
11.0

FUTURE SITE MASTER PLAN

We note the future development plans included in this document relating to the
development of St. James's Hospital. We question the correctness of building the
National Children's Hospital in a constrained site that will be a construction site for
many years to come. The size of the proposed development for St. James's Adult
Hospital, identified as part of this submission is indeed staggering. It will lead to
several years of construction activity, and based on the lorry movements planned
for this phase, the level of construction traffic that will be generated and the
resultant pollution around this site will be immense. We do not consider this a
suitable environment for sick children or the adult patients in SJH.
The St James's Campus - Draft Site Capacity Study outline the phasing and
identifies a number of proposed sites for future development. The majority of these
involve demolition of existing and the relocation of current services I departments to
facilitate the new build. Only 45% of the existing building stock will be retained
under this scheme (mostly because they are protected structures) which means
that St James Hospital plans to rebuild itself on the back of the NCH. While the
Hospital has future expansion plans , including increasing building heights I density,
there is no real scope to extend the on-site parking nor has site access been
addressed along with the additional traffic which will be generated.

12.0

PROPOSED OPEN SPACES


StJames's Campus - Public Realm Strategy deals with the proposed public spaces
including some that are not within the site boundary or site ownership. Surely this is
not allowed? Surface car parking, which is already at crises point on campus has
now been removed to facilitate "green spaces" under this scheme.

13.0

DOLPHINS REPORT & ALTERNATE SITES


It must be pointed out that at no stage was St James Hospital or any other Hospital
site selected in the report recommend as the preferred option. When weighted
against the other hospital St James rates very poorly and has a significant risk in
terms of planning which was one of the worst ratings . This has been reduced to a
moderate risk by incorporating the site proposed for the new Maternity Hospital at
the time which completely blows away the concept of co-location. Currently in order
to fit the future Maternity Hospital on site it will be necessary to demolish and
relocate the Adult Out-Patients Department off site which impacts the current
patients. We would ask why was the most poorly rated site selected for this
hospital?

Rev A
27 September 2015

AN BORD PLEANALA
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Jean Early & John Lane

NCH PLANNING APPEAL Ref# Pl29N .PA0043

r-

' 1.

to.'

The site plan on which the Dolphin report for St James was based on. Site A
was to contain both the NCH & the Maternity Hospital as shown above. Site B
was available for future expansion and is now proposed to house the new
Maternity Hospital.

14.0

COMMUNITY GAINS
Appendix 5:1 MHarnessing the potential -maximising the community benefit from
the new children's hospital" this document is marked Draft. Are we to assume
therefore that there is no real intention to implement a Community Gains clause?

Why were the regeneration areas (not even located beside the hospital) only
considered for the youth employment opportunities? There are plenty of young and
not so young adults living adjacent to the proposed Hospital site who would
welcome such opportunities. There has been no offer of any item or support to the
local residents which would contribute in a positive manner to the general
community.
15.0

RESIDENTS PARTICIPATION
Our first contact from the NPHDB about the New Children's Hospital was a
pamphlet put through our door on the 20th June, 2015.

"

The Pamphlet was titled connect" and stated we want to hear your ideas and
concerns, The Next Residents Drop in Session was to be in the F2 Centre Reuben
Plaza, Dublin 8, 25th June 2015." Many residents attended on the 25th June and
were met by John Pollock, Phelim Devine, Eilish Hardimar an~CJ#'BORD'PL.:A NALA

TIME_ _ _ _ BY_ _ _

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27 September 2015

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N.PA0043

the NPHDB Team. This was the first time we had seen the Presentation Boards
and the Proposed Design at the F2.
The information provided was light in content and there was no site drainage
information available including the proposed diversion of the Driminagh sewer. No
drawings were available to show the design of the new Research Centre (CRIC) or
the Family accommodation unit (FAU). The 30 views shown had no contextual
content and did not include any local residences in the images so that the true scale
of the development wasn't clear to the general public or local residents. As
mentioned above we were told that the building was 7 stories high. As there were
no building sections or elevations available (they were all cut off at the set back to
the main building so the height wasn't visible) we, the Residents, took their word at
face value.
A second public meeting was scheduled by the NPHDB in the F2 Centre Reuben
Plaza, Dublin 8, 6th August 2015. Again no drainage information was shown but
there were drawings for both the CRIC building and the FAU. As the planning was
to be lodged 2 days later this presentation could not be considered a public
consultation (more a show and tell) as there was no opportunity to change any
drawings or documents based on the resident's comments and requests.

We resent all the statements made by the NPHDB referencing the


consultations with the public as they were in our opinion just a PR exercise.

16.0

AN BOARD PLEANALA INSPECTORS REPORT:


An Inspectors Report issued by An Board Pleanala (Ref PL29N.PC0158 by
Kevin Moore dated July 2015) was issued to summarise the pre planning
meetings held prior to this submission.
We feel that the following Inspectors requests were not addressed as part of this
submission.

Alternative sites
Alternate sites were NOT looked at as part of this submission. Instead
the Dolphin Report was referenced and the decision made by the
Government in 2012.
Chapter 4 Examination of Alternatives: As outlined above, the decision
on where to locate the new children's hospital and the two children's
hospital satellite centres, has been determined by the Government
following extensive research, assessment and analysis

Justification for the siting, scale, functioning and form of the overall
scheme in planning and environmental terms.
The Examination of Alternatives and thR
Report address this issue.

11 ,,...,;,..,,.,,

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Jean Early & John Lane

NCH PLANNING APPEAL Ref I# Pl29N .PA0043

As demonstrated above the building is too large for the capacity of


the site. It exceeds the height limits and is at the maximum allowed
Plot Ratio with no room for expansion.

The constrained nature of the St. James' Hospital site and capacity for trilocation (children's hospital, adult teaching hospital and maternity
hospital).
A Draft Site Capacity Study has been prepared with respect to St.
James's Hospital campus that addresses the ability of the site to
accommodate future development. This is submitted with this
application.
We have demonstrated in this and other local residents reports that
the site cannot accommodate these requirements.

The ability to accommodate the future growth I expansion of these


developments individually and cumulatively.
A Draft Site Capacity Study has been prepared with respect to St.
James's Hospital campus that addresses the ability of the site to
accommodate future development. This is submitted with this
application
We have demonstrated in this and other local residents reports that
the site cannot accommodate these requirements

The developments now and into the future in the context of a new Master
Plan for St. James' Hospital complex.
A Draft Site Capacity Study has been prepared with respect to St.
James's Hospital campus that addresses the ability of the site to
accommodate future development. This is submitted with this
application

In the Applicants Planning Report, Table 1, Page 4, they state


"A Draft Site Capacity Study has been prepared with respect to St.
James's Hospital campus that addresses the ability of the site to
accommodate future development. This is submitted with this
application"
This Draft Study is pre-empted with "This Draft Capacity Study does
not purport to be a development plan for the campus, but rather an
indication of its potential capacity.

Construction and demolition impacts - developing the project, decanting


and the functioning of the established hospital campus throughout
this phase.

An outline Construction Management Plan has been prepared and


is submitted with the application and the specific matter of the
existing hospital operations is addressed therein.
\ I ' I

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27 September 2015

See above for the construction issues we have grave concerns


about

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Jean Early & John lane

NCH PLANNING APPEAL Ref## Pl29N.PA0043

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


and regional strategy relating to same.
The Model of Care and need for the children's hospital satellite
centres has been clearly set out in the Children's Hospital Group
Report entitled 'The Clinical Case for the New Children's Hospital'
attached to this application

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.
Draft Site Capacity Studies have been prepared for both children's
hospitals satellite campuses and are submitted with this
application. These are submitted with this application.

The outcome in the event of one or both Satellite Centres failing to acquire
planning permission or failing to be developed.
The Model of Care and need for the children's hospital satellite
centres has been clearly set out in the Children's Hospital Group
Report entitled 'The Clinical Case for the New Children's Hospital'
attached to this application

This item has NOT been addressed


Traffic and transportation - routing, access, modes, car parking.
The Traffic and Transportation chapter (Chapter 6) of the E IS fully
addresses this issue.

We and the other local Residents do not feel this has been fully
addressed as for example no travel to work surveys have been
carried out yet in the existing children's hospitals.
The Coombe Hospital and its developability to accommodate the
proposed future maternity hospital.
A Draft Site Capacity Study has been prepared with respect to St.
James's Hospital campus that addresses the ability of the site to
accommodate future development. This is submitted with this
application

This item has NOT been addressed


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------~~~-:-'1

.
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27 September 2015

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02 OCT 20\5
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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N .PA0043

A Draft Site Capacity Study has been prepared with respect to St.
James's Hospital campus that addresses the ability of the site to
accommodate future development. This is submitted with this
application

This item has NOT been addressed

Visual and streetscape impacts on the local and wider environment.


A full landscape and visual impact assessment has been prepared
and is submitted as Chapter 14 of the EIS. The design of the
proposed development has had particular regard to visual impacts
throughout the design process

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


on adjoining residential properties.
The EIS and this Planning Report fully addresses the issues of
adjoining residential amenities

What Residential amenities?

Public consultation.
The public consultation process is outlined in the document entitled
'National Paediatric Hospital Development Board and the Children's
Hospital Group -Engagement Process' and is attached to this
application
See Section 16 above.

Miscellaneous- archaeology, architectural heritage, impact on


infrastructure (underground services).
All of these matters are addressed in full in the EIS

17.0

CONCLUSION

As per our Summary above we would ask as a minimum that the planning process
to be restarted with truthful information regarding the height of the facility and the
site boundary, and that all publications material be withdrawn, corrected. We
believe that the scale of the proposed St James site (NCH, CERIC & FAU)
constitute over development of the site.
We request that the matter of vermin control be addressed by the developer with a
view to constant monitoring in the local area. Standards should be put in place in
conjunction with the Environmental Health Service, and these should be agreed
with the local community before excavation commences. In addition, any sightings
identified locally should be addressed by the developer. This. c._,.,
~~..

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02 OCT 20\5

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Jean Early & John Lane

NCH PlANNING APPEAL Ref It PL29N.PA0043

by Dublin City Council for the duration of this development to ensure no risk to
public health in the neighbourhood.
We note that there is inadequate expansion capacity for this hospital, to allow it to
last for the next 100 years. The expansion space identified will use up the only
green space at ground level. We consider this site to be inappropriate for the
National Children's Hospital. Almost an (around 90%) children are brought to
hospital by car.
There are huge schedule and cost impacts associated with the p~oposed enabling
works which form part of this development just to get the site ready. Once ready the
current site does not offer sufficient land to provide adequate parking, construction
facilities, open green spaces and most importantly proper expansion opportunities
to future proof the development. The tax payers money wasted on preparing this
brown field site to construct the new hospital could be put to a much better use
such as new equipment for the hospital and associated facilities for the children and
their families.
For reasons outlined above we would propose THAT THE CURENT PLANNING
FOR the NCH at St James Site is refused and that a swap is done so that the
satellite unit proposed for Connolly Hospital site is constructed at StJames Hospital
and the new NCH is relocated to the greenfield Connolly site which offers unlimited
site expansion potential with no enabling works requirements. The Rotunda
Maternity Hospital is due to rlocate to tis site giving the perfect Tri Location
scenario. This site has a low planning risk as set out in The Dolphin Report, Further
assessment of planning issues in relation to proposed sites: Report submitted to Dr.
James Reilly T.D., Minister for Health, by Simon Clear and John Martin: 19 October
2012. This would also mean the Davitt Road Site Compound wouldn't be required
giving a further savings to the project. If the same design team is maintained it
would be the most efficient use of the tax payer monies as they have an in depth
knowledge of the brief and both sites.
Alternately, if the Government are set in keeping the site in the city centre I Dublin 8
the entire NCH Building could move to the Coombe site as there is adequate land
for development, parking , future expansion, contractors compound and more
importantly an existing functioning Maternity Hospital. This site also got rated as a
low planning risk in the Dolphin Report.
Finally there is the unanswered question of the elephant in the room : Why are we
merging 3 hospitals into 1 by constructing 3 hospitals (1 main plus 2 satellites) due
to site constraints imposed by locating the Hospital at St. James restricted site?

In order to demonstrate the carrying capacity of the alternate sites mentioned above
I've imposed the current NCH StJames Site plan on to both the Coombe site and
the Connolly Site (at the same scale) Figure# 1 & Figure# 2
As they say a picture paints a thousand words!

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Jean Early & John Lane

NCH PLANNING APPEAL Ref# PL29N .PA0043

Figure# 1
,. -

St. James Hospital Site & Coombe Hospital Site

....,

Figure# 2

____...

Connolly Hospital Site

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18.0

APPENDIX# 1

18.1

Extract from EIS Chapter 2: Description of the Development


2.4.1 New Children's Hospital Building

.. .

The bUilding v.;n vary in height from three storeys along Its western side bordering the South Circular Road,
to seven storeys In the centre or the site v.ith ltle overall he!Qht or !he building to ridge level or !he roof
structure iS up to 34.95m (Ordnance Datum 55 95) and up to 37 95m to the top of the nues on the roof
(Ordnance Datum 58 95m) above arevised ground level or Ordnance Datum 21m at the proposed entrances
The proposed storey heights are as foiJoY..s

18.2

219

Extract from the New Children's Hospital Web Site


http://www .newchlldrenshospital.ie/
Concept design for the new children's hospital is unveiled:
Key Facts about the building
7 storeys at 1ts highest pomt With the maJonty of the bu1ldmg sutmg at four storeys
42 beds 1n cr tJCal care un1t

18 neonatal cnt 1cal care un.ts


380 single 1n-pat1ent rooms

AN BORD PLEANALA
TIME_ _ _ BY_ _ _-1

02 OCT 2015
18.3

Extract from the Public Site notice:

LTRDATED;_-- F"'*---1

PL
"The proposed building will vary in height from three storeys with a recessed podium
level fronting onto South Circular Road and the internal access road (facing west I
northwest towards the rear of Cameron Square), to four storeys at the northern,
eastern and southern elevations. The proposed central oval-shaped ward pavilion
rises a further three storeys above the podium garden level with a plant area
enclosed in the roof space above (giving a total of seven storeys above ground level)
and additional exhaust flues rising from the roof structure at the northern and
southern extents of the ward block. "
This text is deliberately misleading and not informing the true fact that it in reality
consists of 8 stories above ground level.

18.4

Extract from Minister of Health Website (Leo Varadkar) interview Evening


Herald dated 11 August 2014
''The most devastating blow to the bid to amalgamate Ireland's three children's
hospitals on one campus was when a planning application for the Mater hospital site
was rejected in 2012.

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NCH PLANNI NG APPEAL Ref# PL29N.PA0043

Jean Early & John Lane

Mr Varadkar said that lessons had been learned from that process.
"It's a much bigger site - it's nearly three times the size of the Mater site. It doesn't go
any higher than seven stories, " he said.

18.5

Extract from Minister of Health Website (Leo Varadkar) web site


Design unveiled for new Children's Hospital : Leo Varadkar

"Key Facts about the new children's hospital (nch):


Seven storeys tall at its height with the majority of the building sitting at four storeys
380 single in-patient rooms including 93 day care beds

18.6

Extract from Minister of Health Website (Leo Varadkar) web site Press Release

Ireland is one step closer to having a new


world-class children's hospital as plans
are lodged with An Bard Pleanala

A four storey building - rising to seven stories at its highest point above ground s1ts comfortably within the existing St. James's Hospital campus, the first views of
the hospital being an oval pavilion set in a therapeutic rooftop garden. The garden
is an integral part of the design as it will give a tangible sense of this being a
spec1al place - one for children and young people, elevated above the world of
adults.

F
1

D2 OCT

.J

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