Our Ref: 29N.

PA0043
P.A.Rcg.Ref:

An Bord Pleamlla

--~

Your Ref:

Oliver Curtin and Sarah Farrelly

590 South Circular Road
Kilmainham
Dublin 8
6th 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 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 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 Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

Encls.
ADHOC/PA0043/0 1

~ I
Gl.ln r\Unu IK'Hl :'.75 17~ LnC.tl!
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llaik r\th;LCliath I

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Our Ref: 29N.PA0043

P.A.Reg.Ref:
Your Ref:

Paul O'Neill
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 Pleamila reference number in any correspondence or telephone contact with
the Board.
Yours faithfully,

Encls.
PA08.LTR

Tcil (Ul I H~K XliM I Tel

Glau \ititiil l!l'lii1H 17~ LuC'all
t>-1 SrJill Matulbhritlc
n..itc Atha Clmth I

L.uthrc0111 Gtc:l\:iin """ plc;lllOII;t ac \\cb

Kinmhpht"l hnrtiCii plc;utaht ic Em.til

1>-1 :\l:trll~uuugh Street.

Duhlin I

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 information 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:Ol-8737107
Ends.
ADHOC/PA0043/02

Tcil ((Ill !15N NIIKI1d

Gt Aiti1iil 1!11XI ~75 175 l.nCc11

1>1 Sr;iid M.cmlhhritlc.

ll:u)c ,\tha Cliath I

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1>1

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Duhhu I

~l:orll~ornu~h

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 information 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,

M1\ ~

' t fn Somers

: cutive Officer
Direct Line:Ol -8737107

Encls.
ADHOCIPA0043/02

'leiI ~0 II K~H K((Ml Td

(ilau \1tni1l IX'IO ~7'i 17'i LnC.1I
l>l Sra~tl ~l;ttulhhmk
Boil~ ,\tl~a Choth I

Luthrl!an Gn:a-,.un \\ '' '' p!c.m.11.1 u.: \\cb

Riumhph"'l lxml "plcon,,la 1c lma1l

1>-1 1\l;ullxruu!!h Su~cl

Duhhn I

Our Ref: 29N.PA0043

P.A.Reg.Ref:
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 information 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 1-873 7107
Encls.
ADHOC/PA0043/02

'li:il till I H~N lWKI Tel

Gliu t\iuull IX'IO 2H 17~ LnCall

(w '\r.ill r.lamll>hndc
ll.ulc \1h.o Ch.olh

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ltonrnhpht"l hnnl<"rkmala oc Em:ul

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Oliver Curtin & Sarah Farrelly,

AN BORO Plf=ANALA
Received:

Fee:

r (0

Gsc

Receipt No:

590 South Circular Road,

(~

cc

Kilmainham,

(3 \3 ll ( ~

Dublin 8

The Secretary,
An Bard Pleanala,

AN BORD PlEAN
TIME

64 Marlborough Street,
Dublin 1.

BY

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LTRDATEO
FROM
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Planning Application Reference PL29N.PA0043, StJames Hospital,

Dublin 8.

Dear Sir/Madam,
We write in relation to the to the above planning application to detail the concerns that we
have about the proposed development. Our family home at No. 590 South Circular Road is a
minimum of 30m to the west of the proposed development site and accordingly we have a
particular interest in any proposals which may represent a threat to our established
residential amenities. We enclose a cheque made payable to An Bard Pleanala in respect of
the prescribed fee for making a submission outlining our objections to the application.

Objections;
The following are the basis of the objection to the current planning submission design.

1. Overshadowing and privacy

The current design incorporates a series of wards described as 'fingers' which protrude from
the main seven story building. Each of these fingers having an elevation height of 12.6m.
This fa~ade is uniform along the East side of the development facing onto South Circular
Road and Brookfield Road. However the "Family Accommodation Unit" is closer to the road
and its elevation height is 16.1m. (Please see drawing NPH-A-BDP-PL-ZZ-00-3204-SECTIONSCC-DD) This will have a direct impact on the overshadowing and privacy of the residents
along this end of South Circular Road and Brookfield road. (Please see drawing NPH-A-BDP-

PL-00-FA-2100). The height of the building is substantially higher than the existing one on
the site. This part of the development will have;

The height of the building goes against the Dublin City Council Development Plan
where it states that "All high buildings must be of the highest architectural quality

and should aim to have a slenderness ratio of 3:1 or more and regard for the existing
urban form, scale and character, and the built heritage of the area". When viewed
from the south the Family Accommodation will have a ratio of 1:1. 15.9m wide and
16.1m tall.

A negative impact on the privacy of residents of South Circular Road, Brookfield

Road, Brookfield Street and Cameron Square. The main building block has lower
level finger wards that limit the 'harshness' of the height on the surrounding area.
The Family accommodation unit height is much 'harsher' than the existing buildings
on the site.
fa~;ade

The Family Accommodation unit breaks the continuity of the

Circular Road and Brookfield Road.

facing South

This building's height and finish is not in keeping with this historical area of Dublin
and will reduce the character rather than enhance it.

We request that the Southern part of the 'Family Accommodation Unit' be reduced to an
elevation height of at least 12 meters from ground level. This is to keep the building in line
with the buildings of the surrounding area. And to align the building with the Dublin City
Council Development Plan which references a ~SJjlel!J
_n~dlge!Jrn~~~~~~=:-~-~--.

RDPLEANALA
____
BY
-----~

2. Impact of traffic caused by this proposed devel pment This is a residential area with many young families an
to the hospital. The significantly increased volume

I OCT 2015

~h~8~11~ni gtf~~ the ent ance

~l

elo me will

generate will indeed negatively impact on our daily lives and make our living s1 uation
worse. We are concerned with additional strains that access to the proposed hospital will
cause in our neighbourhood. This traffic will not only be at peak hours when employees
enter and leave the complex, which we currently contend with. We understand, but do not
know how it will work in practice, that no more than 728 of the approximate 6,000 staff in
the combined StJames and National Children's hospitals will be expected/allowed to drive
(728 parking spaces available for staff).

That level of parking that will be provided is

considerably less than the existing levels provided in James and in each of the three
Children's Hospitals. However, overall it amounts to a reduction of a mere 244 staff parking
spaces that is meant to mitigate the additional traffic generated by the 350,000 patients
that will be treated in the proposed hospital.

That means approx. 1,900 sick children

coming into the site per day, and we do not expect the majority of them to use Public
Transport.

As we all know, this area is at maximum capacity during the rush hour periods at present
and this development is proposing rush hour conditions in the area during most of the day
for most working days. We are concerned of the impact that this level of traffic will have on
urgent cases and emergency vehicles trying to get to StJames' Adult Hospital as well as the
proposed National Children's Hospital on the site.
a. Construction Phase Traffic
Per Section 6 of the EIS there are estimates for the lorry movements that will pass our house
to travel to the junction of SCR/Bulfin Road/Suir Road during each of the 3 phases of
construction. As our home is very close to the traffic lights for the entrance to the hospital,
we are very concerned with the noise and vibration that will be caused by waiting trucks at
the junction. Per the information provided, the volume of lorries will be in the region of;

520 per day for the first 4 months (includin

460 per day for the next 2 months,
690 per day for the next 18 months
570 per day for the next 21 months (at a m nimum) _

ocr 2o1s

LTROATED
We object to this level of development on the si. ~~-~==~~~~~~~ s or LGVs
will pass and wait outside our house. It is worth noting, that based on t e estimates
provided over 111,000 of those are to remove the earth from the site to build the very
substantial basement that will be required for this proposed development. We consider
this to be an indication that the proposed buildings are much too large for the constrained
site due to its inaccessibility. The level on this road is due to the inability of these trucks to
leave the proposed new entrance at Mount Brown.
b. Operational Traffic
Section 6 of the EIS - Pg 132 states that the expected level of additional hospital traffic will
be in the region of 300 - 400 traffic movements per hour. The majority of these will be via
the Brookfield Road Junction (as the replacement junction at SCR & Brookfield). This is a
very significant number of additional vehicles on the road - in the region of 1800 to 2400
per day. We contend that the road network in this neighbourhood cannot sustain this level
of additional traffic and will seriously hinder the access to St. James' Adult Hospital A&E
Department for emergency vehicles.

We request the National Ambulance Service attend the oral hearing to explain how their
service will operate in practice during this development and in the future operational
phase.

3. Parking issues for the resident community

Disc parking is in operation in our immediate area from Monday to Saturday, with free
parking on Sundays and at present it can prove difficult to obtain parking near one's house.
Currently, during Visiting Hours in St James'Hospital quite a number of people park on our
streets. This problem regarding the adequacy of parking is acknowledged by the NPHDB
who suggest in Page 22 of the Non-Technical Summary "The extension of the existing onstreet pay parking system in agreement with the local residential community, where
required"
They also suggest that the prices in our areas should be increased. This tacit acceptance
that they are not providing adequate parking is totally unacceptable to the parents of the
sickest children of our country. This fact, further reinforces our belief that this site is not the
appropriate site for the National Children's Hospital and should be refused planning
permission.
As an example there is major issues surrounding the on-street parking around the Crumlin
Children's hospital. This has had a negative impact on t
this area.

AN BORD PLEAN .

ALA

TIME

BY
------~

. . ' ocr 2015

4. Health & Safety Issues.

LTRDATED
a. Aspergillus/legionnaires Disease

PL

-----

The planning application discusses the possible presence of Aspergi us

e site.

The application states that "While dust from construction activities tends to be deposited
within 200 m of a construction site, the majority of the deposition occurs within the first SO
m (as shown in Table 12.11). There is no mention in the report as to how any potentially
adverse impact is going to be mitigated for properties outside of the boundaries of the site.
We live 12.9metres from this site and this is a very worrying feature for us. This is
particularly of concern as the excavation works will be taking place over 18 months at a
minimum. We would like to know what specific mitigation actions are planned for the
safety of local residents for the duration of this excavation work.
b. Vermin Control
Due to the extent of the excavations that have to occur as part of this proposed
development, together with the redirection of the Drimnagh Sewer on the StJames' campus
we have a serious concern regarding the disruption of rats and their dispersion into the local
area - i.e. our roads, gardens and houses. This is not covered at all by the developers and

we require same to be controlled, due to the impact this may have on our children. We
request that this matter be addressed by the developer with a view to reducing the impact
on the local area. We also request that this issue be monitored by Dublin City Council.
We also request that Dublin City Council be required to clean the leaves from this road on a
weekly basis during the autumn as there will be an increased risk of vermin infestation due
to this disruption.
c. Sewage
We are concerned that the facility is going to add significant pressure on the local sewage
facilities. The cost of relocating the Drimnagh Sewer is not covered in the budget for the
National Children's Hospital. We have concerns that any disruption to this service will have
serious impacts on our facilities. We would request that Dublin City Council Drainage
division and Irish Water be requested to affirm the plans for the rerouting of the Drimnagh
Sewer and that the successful completion of this should be a condition of further work being
carried out on the site.
d. Flooding
We are also concerned about the area identified as the entrance to the Basement Car-park
and the fact that there are three underground levels at this site. The area identified as the
entrance has flooded twice in the past 7 years and is an area that is recognised as being
subject to flooding. We do not

'ti ation to future events of a similar nature in the

AN BORD PLEANALA

plans for this

TIME

-----1

BY

e. Future Traffic

- 1 OCT 2015
We are also very concerned

ith the traffic that will be

LTROAT~D

FROM

. nerated by this additional

development. The situation s descnbee ahove a~!M-~mpossible even before the

Pl
Maternity Hospital and the ex
s' Hospital Master plan are
taken into consideration.

When all these additional movements in and out of this

constrained site are taken into consideration, it will not be possible for the two access
roads, one of which was built in the 1700s and the other in the 1800s, to deal with the
traffic required for the transport of patients. Is not acceptable that the health of future
generations of our sickest children and our expectant mothers are put at risk by the granting
of this planning permission on this site when other more suitable sites are available in our
city.
As stated in the Non-Technical Summary Page 26 Section 7.2.2 "Following the construction
of the new children's hospital, it is acknowledged that the surrounding street network will
continue to experience traffic queuing and delays at some periods through a typical week
day. The mitigation proposals included as part of the Transport Strategy for the StJames's
Hospital campus and the new children's hospital will ensure however that the increase In

traffic levels and associated impact during these periods are kept to a minimum". We do
not see these mitigation proposals and again suggest that there is no way that we can
mitigate for the requirements of sick people to be brought to hospital by either car or
ambulance.

5. Considerations requested should this development be allowed.

Without prejudice to the objections raised elsewhere in this submission, we request that in
the event of a grant of permission that the following conditions be attached to its decision: a. To mitigate the issue of light;
We request that the Southern part of the 'Family Accommodation Unit' be reduced to an
elevation height of at least 12 meters from ground level. This Is to keep the building in line
with the buildings of the surrounding area. And to align the building with the Dublin City
Council Development Plan which references a Slenderness Ratio of 3:1
b. To mitigate the issue of traffic;
A full and open review of a traffic plan must be presented to the residents of the
surrounding areas.

We request the National Ambulance Service attend the oral hearing to explain how their
service will operate in practice during this development and in the future operational
phase.
AN BORD PLEANALA
TIME

BY
-----~

- f OCT 2015
LTRDATED
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