Our Ref: 29N.

PA0043
P.A.Reg.Rcf:

An Bord Pleamila

Your Ref:

Triona Murphy
Tallaght Hospital Action Group
19 Woodale Green
Ballycullen View
Dublin 24
30th September 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 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 all submissions I observations received in relation to the application will be made
available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County
Council and at the offices of An Bord Pleaoala when they have been processed by the Board.
If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above
mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

Wl &~&,..._~
\' Kieran Somers
Executive Officer
Direct Line:O 1-8737107
Encls.
ADHOC/PA0043/01

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9/28/2015
Triona Murphy.
Tallaght Hospital Action Group,
19 Woodale Green,
Ballycullen View,
Dublin 24.

AN BORD PlEAtl4~ .

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TIME

The Secretary,
An Bord Pleanal~
64 Marlborough St,
Dublin 1.

BY

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29 SEP 2015
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Dear Sir/Madam,
Please find enclosed our submission in regards to the planning permission sought by the
National Paediatric Hospital Development Board and the fee of so euro as required.
Case reference: PL29N.PC0158
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.

Receipt No:

Yours sincerely,

Triona Murphy.
Tallaght Hospital Action Group

Bo~d

Ple.anala
submission

Health Infrastructure Development comprising National

Paediatric Hospital, Innovation Centre and Famiiy
Accommodation Unit at St James' Hospital Campus,
SateUite Centres at Tallaght and Connolly and Construction
Compound at Davitt Road, Dublin.

Case reference: PL29N.PC0158

Triona Murphy

28/09/2015

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Bord Pleanala submission.

The Tallaght Hospital Action Group, (THAG), is a community
organisation formed in 1991 to lobby actively for the building of the
AMNCH Hospital at Tallaght .The action group has a variety of members
from the broad Tallaght and catchment area .We are not affiliated to any
party political organisation. Many of our members are also part of other
community groups involved in promoting and expanding community
facilities in Tallaght and the surrounding areas, and some have extensive
experience of participation in planning processes either in professional or
voluntmy capacities. We were present throughout all the Bord Pleanala
oral hearings for the failed Mater site proposal and made written and oral
submissions. During the last 20 years TIIAG has been involved in tiying
to expand and improve the facilities the Hospital provides to an ever
increasing population in its catchment area We are not architects,
planners or medical professionals. We, ARE, however parents and
grandparents and as such we are as well qualified as any to point out the
inadequacies in this project. We now find ourselves making a submission
again to the Bord about the proposed 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.

In opposing the planning pennission, our arguments fall under four

headlines:

l.Site issues at the James Campus relating to the Model of Care and
need for expansion
2. Car parking for the entire campus.
J.Lack of designated funding for parent accommodation.
4. Consultation.

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1. Site issues at the James Campus relating to the Model of Care and
need for expansion
In making our submission it is appropriate to lay out the previously
published plans for how the hub and spoke plans for children's hospital
services. In Oct 2007 Rawlinson Kelly & Whittlestone Ltd (RKW)
published its report on the planning of the integration of paediatric
hospital services in the Dublin area (appendix 1). We can presume that
the National Paediatric Hospital Development Board (NPHDB) used the
population analysis in this report as the bed capacity of the James'
campus matches the bed capacity numbers in this report. This report
however laid out in clear tenns the services which should be provided at
what were then called Urgent and Ambulatory Centres and are now
simply referred to as "satellite centres". RKW's recommendations state
that 28 day case capacity would be required at the Tallaght Campus, 23
consulting rooms for outpatients and 5 operating theatres. It oudined the
need for Ambulatory and Urgent Care Centres to relieve the pressures
and unwarranted visits to the tertiary hospital and used attendance
numbers for day case surgery, outpatient attendances and ED
presentations to back this case. It highlights that while all first
attendances in outpatients in general surgery, paediatrics and psychiatry
should be at the Tertiary hospitals many second and subsequent
appointments should be held in the Ambulatory care centres. It draws on
the examples of international best practise which universally states that
care is best provided as closely to home as possible where it is safe to do
so.
RKW supported its decision to locate an Urgent and Ambulatory Centre
at Tallaght with population data
It was evident from the maps that the areas of highest paediatric
population in 2021 are grouped in 4 zones North East including North County Dublin

North West including Dublin 15, Dublin 11 and County Meath

South West including Dublin 22, Dublin 24 and County Kildare

South East including South East County Dublin and Wicklow.

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This model of care was re-iterated in the Frank Dolphin report in June
2012.(appendix 2) It states that Secondmy care which required specialist
paediatric input as inpatient or outpatient should be provided at urgent
care centres linked to the tertimy children's hospital - examples include
gastroenteritis with dehydration (inpatient care) or troublesome asthma
(outpatient care).
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THAG would also like it noted that the Irish Associ
~~ergen~~O
Medicine in 2007(appendix 3) stated that the opw.llU:IItK:o~.lt'ergeney
M_ __,
Department service provision would not be best serv~ri~=M~=====::::::::d
fully functioning ED department for Children. They stated that
approximately 120,000 children attend the three existing Paediatric EDs
each year. Therefore, any Emergency Department obliged to receive all
children requiring ED care would have to expect to receive similar
numbers. Indeed, this number may rise as the population of the greater
Dublin region continues to grow.

..
There has been an increase in paediatric attendances in the UK in recent
Years, which shows no signs of abating. Quote taken for the report on ED
attendances in the UK from the independent research facility in the UK
QualityWatch "There has been a sizable increase in the number of A&E
attendances, from 16.5 million in 2003/04 to 21.7 million in 2012/13, a
rise of32 per cent. However, more careful inspection of the data revealed
that this rise was almost exclusively acting on minor A&Es (for example,
urgent care centres, minor injwy units and walk-in centres). Although
attendances at major A&E departments had also been increasing, this was
at a much lower level Gust 13 per cent between 2003/04 and 2012113)"
See appendix 4 for link to full report
A single Dublin paediatric ED would see nearly twice as many patients as
any existing ED in the country. It must be designed, built and resourced
in line with current best practice and have the ability to be future-proofed
for the inevitable increase in attendances over time.

Inter alia, the KPMG report on Maternity services (appendix 5)

reconunended were that the Coombe Hospital should be relocated to the
Tallaght site. Again detailed population analysis was produced for the
location of mothers attending the Coombe. I quote the report "Almost
60% of births originate in Kildare, Wicklow and south Dublin. This
represents approximately 13,440 births in 2006." And that for maternity,
the demographics clearly support the development of a maternity service
at Tallaght Hospital. Almost 20% of the Coombe's activity originated
from Kildare. This area is predicted to grow and therefore a service in
Tallaght Hospital is the best option for women from this area." It should
also be noted that in the 2008 KPMG report St James Hospital was out
ruled for the Coombe because the travel times for the vast majority of
Mothers (who attend the Coombe) was deemed to be too long. It
highlighted that in a majority of cases the travel times would be in excess
of 60 minutes as opposed to a majority accessing Tallaght campus in 30
minutes.

The planning applications for the Satellite Centres have been included
with the main hospital development. This shows that much of the
previous (and agreed) model of care has been ignored. We can see that
minimal outpatient care will be provided at Tallaght and
Blanchardstowns Hospitals. There will be no day case surgery or any
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inpatient beds at either location. Therefore all tertiary, lJdjr~

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inpatient activity and Emergency Department presentations will be

provided at the James' Campus. The NPDB will assert that parents and
children should and will attend the local satellite centre for minor injuries
and illnesses. This in effect is asking parents to triage their own injured
and sick children. We have seen, in Ireland, in the adult hospital situation
that when local smaller hospital EDs have been downgraded that there is
a substantial increase in the larger hospital EDs. When faced with a sick
child parents will travel to the ..main" hospital and will bypass the
satellite centres. Once current paediatric hospital care has been removed
(i.e. Our Lady's Hospital Crumlin, Temple Stand the National Children's
Hospital in Tallaght) it will be impossible to re-instate. In researching for
this submission I have failed to find any hospital in Ireland that has NOT
increased bed capacity in the last 10 years. Tallaght Hospital, when
planned, was to have a 700 inpatient bed capacity. In 1998 it opened with
520 beds. Today the bed capacity in Tallaght Hospital is 721 beds.The
Dolphin Report (appendix 2) stated that the optimal expansion capacity
should be in excess 20o/o. International best practise states that expansion
capacity should be excess of25%. Neither are achievable at the James
Campus.It must also be noted that James Hospital is a tertiary centre for
many adult specialities. Adult hospital capacity will need expansion
capacity also. The proposed maternity hospital planning application has
not been included here. Birth rates in Ireland remain the highest in the EU
and shows little sign of slowing. Therefore it can be presumed that in the
future the capacity for maternity services will require room for expansion.
There quite simply put is not available space at this campus to future
proof, for even, the only children's hospital in the Greater Dublin area.

2. Car parking for the entire campus.

We have previously outlined the extent of the services which will need to
be delivered at the tertiary children's hospital planned for James' hospital
campus. We know that car parking for sick children and their parents will
be highlighted in many objections to this planning. It is disingenuous of
the NPDB to suggest that parents will avail of public transport to access
the new hospital. All reports from the existing children's hospitals and
indeed internationally show that the majority will travel by car. Indeed in
many cases which the NPDB do not highlight is that in many cases there
is little choice for parents of very sick children. These children may be
immuno suppressed and/or need to bring medical equipment e.g. oxygen,
wheelchairs etc with them to hospital. The NPDHB indeed seem to forget
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that in many cases more than one child will need to be transported to the
Hospital i.e. siblings and/or in the case of twins, triplets etc. As we have
previously stated St James is the tertimy hospital for many adult
specialties including care of the elderly, a variety of cancers etc. While
discussing car parking it is vital to look at car parking for the campus in
its totality.
The extent of car-parking that is proposed with the new hospital is
inadequate and the overall number of car-parking spaces which is
intended to be provided for the site to cater for the demands of the
existing hospital, proposed children's hospital & future maternity hospital
falls well short of requirements & would result in insufficient car-parking
for patients and extremely limited car-parking for staff of both the
existing and new hospitals.
Quote from traffic report (chapter 6 EIS submission) from NPHDB states

"The quantum of parking provided on campus will be capped at

approximately 2,000 spaces, serving both staff and visitor/patient
parking needs."
Car parking for staff must also be included. It is presumed in planning
that staff will travel by public transport. No surveys have been completed
to determine whether staff that will move to the new hospital have the
capacity to access public transport. We know that many paediatric nurses
working in Tallaght Hospital live outside ofDublin and therefore will
drive and park at the new hospital. It is fair to presume that staff from
temple St and Crumlin will be in a similar position.
Quote from traffic report (chapter 6 EIS submission) NPHDB goes on to
say "The car parking strategy involves the transfer of parking from

staff to visitors/ patients as the hospital continues to expand. The

additional travel needs of staff will be catered for through the
Smarter Travel Programme which will be supported by the
Government's continued investment in public transport projects in
the Greater Dublin Area (i.e. 'Swiftway' BRT Network, DART
Underground, Lucan Luas, etc)."
Again the THAG would like to stress that this is based on supposition and
not fact!

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Media reports that staff should car pool are ill advise<L unfeasible and not
a solution to this obvious problem.
The additional traffic volumes that would be created by the new
children's hospital and maternity hospital in this location will further
increase traffic congestion on the immediate roads adjacent to the
hospitaL in particular at the Rialto gate. This congestion would have a
knock-on effect on the surrounding road infrastructure which already has
difficulty in coping with existing traffic volumes.
Patients and staff of the existing and new hospitals would be forced to
seek on-street parking on the roads in the vicinity of the hospital, due to
the inadequacy of on-site car-parking as result of the new development
and this would further add to the traffic congestion in the area.
Comparisons to current car parking at the existing children's hospitals
used to suggest adequate parking in this proposal are disingenuous. There
are vast areas of on street parking surrounding Crumlin Hospital. In
Tallaght the adjacent shopping centre provides large numbers of
additional car parking space. Temple St Hospital, of course, has little or
no assigned car parking. Again I quote the Dolphin report which stated
that 1,000 car parking for children's hospital alone car parking would be
required.
We are expected to believe that 2,000 car parking spaces will
accommodate all patients and visitors to the James St Hospital campus
and this is before the proposed tri-location on site of the Coombe
Maternity Hospital.

3. Lack of designated funding for Parent Accommodation.

The current provision of parent accommodation is provided in Our

Lady's Hospital in Crumlin by the staff and volunteers of Ronald
McDonald House.Such accommodation provides vital supports for
parents of sick children. The charity is entirely dependent on fundraising
and does not receive any state funding.

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We note from the Ronald McDonald House Charities Ireland Website
(appendix 6) that extensive fundraising has begun to fund the 53 bed
parent accommodation to be based in the St James Campus. The webpage
estimates that up to 10 million euro will be required to fund the project.
The parent accommodation will continue to be run by the charity and its
ongoing funding needs will come from their fundraising endeavours. We
question then why this is present on the NPHDB planning application. It
would appear that this portion of the project will not be government
funded but funded via the charity.The NPHDB will have no part or parcel
in the running of this house and as such the planning application should
be rights be made by the charity. As parents and grandparents ourselves
it is very disappointing that this parents accommodation is not state
funded and maintain that it should be. It is disheartening and could be
said to be dishonest to see the planning permission included with the
main hospital as if to suggest that there is state support for it.

4. Consultation.
We hear much from the NPDHB about how widely they have "consulted"
parents and staff about this new project. We have had some contact with
the residents groups surrounding the St James Campus and we know how
disappointed they have been in this regard. We have read commentmy
from Jonathan Irwin(CEO Jack and Jill Foundation) about his similar
concerns. THAGs experience is no different. Ms Hardim~ as was the
case in the past, agreed to meet with us in person and we are grateful for
that. At this meeting we were "informed" as to the health care that would
be removed from Tallaght Hospital and what would remain.

In the government publication entitled REACHING OUT Guidelines on

Consultation for Public Sector Bodies (2004) (appendix 7) it states:

uconsultation for the purpose of these Guidelines means a

structured public engagement which involves seeking, receiving,
analysing and responding to feedback from stakeholders. "

This was not the form of consultation we would contend that took place
and indeed replicates our last dealings with the NPHDB. It is again

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disingenuous for the NPHDB to say that it has consulted widely .It is truer
to say they have simply informed widely.

Appendix 1.
http://www.hse.ie/englservices/publications/Hospitals/High Level Frame
work Brief, National Paediatric Hospital. Part l.pdf

Appendix 2.
http://www.newchildrenshospital.ie/wpcontent/uploads/20 15/08/Dolphin Group ReP-ort-1 .pdf

Appendix 3.
http://www.iaem.ie/images/stories/iaem/publications_position_statements
/2007/iaem_position_paper_ on_provision_of_ems_for_children_in_the__g
da_following_development_ of_ a_ single_national_ tertiruy_paediatric_hos
pital_150607.pdf

Appendix 4
http://www.health.org.uk/sites/default/files/QualityWatch_FocusOnAEAt
tendances.pdf

Appendix 5.
http:/llenus.ie/hse/bitstream/10147/69303/1/MatemityReport.pdf

Appendix 6.
http://nnhc. ie/wp-content/uploads/20 15/06/RMH C-Ireland-Annua1Report-2014.pdf

Appendix 7.
http://www.taoiseach.ie/eng!Publications/Publications_Archive!Publicati
ons_20 11/Better_Regulation_ Archive.html
Triana Murphy,
Chairperson,
Tallaght Hospital Action Group,
19 Woodale Green,
Ballycullen View,
Dublin 24.

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