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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

    Dear Sir/Madam,

    Re:

    Health Infrastructure Development comprising National Paediatric

    Hospital, Innovation Centre and Family Accommodation Unit at

    St

    James' Hospital Campus, Satellite Centres at Tallaght Connolly

    Hospitals and Construction Compound at Davitt Road, Dublin.

    An

    Bord Pleamila has received your recent submission

    in

    relation

    to

    the above mentioned proposed development

    and will

    take

    it into consideration

    in

    its determinationof 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 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,

    ?IJ d ~ C { j c .

    ' q:..

    0'\1\

    . K i ~ r a n

    Somers j

    x ~ c u t i v e

    Officer '-.

    Direct Line:01-8737107

    Encls.

    ADHOC /PA0043/0 1

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    Our Ref: 29N.PA0043

    P.A.Reg.Ref:

    Your Ref:

    Paul

    0

    1

    Neill

    National Paediatric Hospital Development Board

    C/0G.V.

    A

    Planning Regeneration

    Floor

    2,

    Seagrave House

    19 20 Earlsfort Terrace

    Dublin 2

    5th October

    2015

    Dear Sir,

    Re: Health Infrastructure Development comprising National Paediatric

    Hospital, Innovation Centre and Family Accommodation Unit at St

    James' Hospital Campus, Satellite Centres at Tallaght Connolly

    Hospitals and Construction Compound at Davitt

    Road

    , Dublin.

    An Bord Pleamila

    Enclosed for your information is a copy of submission(s) received by the Board in relation

    to

    the above mentioned

    proposed development.

    Ifyou 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

    (.. Sr.ild Ma111lhhrftk.

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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

    Dear Sir/Madam,

    Re: Health Infrastructure Development comprising National Paediatric

    Hospital, Innovation Centre and Family Accommodation Unit at St

    James' Hospital Campus, Satellite Centres at Tallaght & Connolly

    Hospitals and Construction Compound at Davitt Road, Dublin.

    Enclosed for your infonnation are two copiesof submissions received by the Board in relation to the above mentioned

    proposed development.

    Please ensure that a copy ofeach submission

    is

    available for public inspection at the offices of he 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: 01 873

    71

    07

    Ends.

    ADHOC

    /

    PA0043

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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

    Dear Sir/Madam,

    Re: Health Infrastructure Development comprising National Paediatric

    Hospital, Innovation Centre and Family Accommodation Unit at St

    James' Hospital Campus, Satellite Centres

    at

    Tallaght Connolly

    Hospitals and Construction Compound at Davitt Road, Dublin.

    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 copyof 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 correspondenceor telephone contact with the Board.

    Yours faithfully,

    o m e n ~

    cutive Officer

    Direct Line:O 1-873

    71

    07

    Encls.

    ADHOC/PA0043/02

    I

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    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

    Dear Sir/Madam,

    Re: Health Infrastructure Development comprising National Paediatric

    Hospital, Innovation Centre and Family Accommodation Unit at St

    James Hospital Campus, Satellite Centres at Tallaght Connolly

    Hospitals and Construction Compound at Davitt Road, Dublin.

    An Bord Pleanala

    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 ofeach submission is available for public inspection at the offices of he 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 correspondenceor telephone contact with the Board.

    Yours faithfully,

    ran Somers

    cutive Officer

    Direct Line:O 1-8737107

    Encls.

    ADHOC/PA0043/02

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    N BORD PLE N L

    TIME \6 Z.K ~ ~

    3 1h September 2015

    The Secretary

    An Bord Pleanala

    64 Marlborough Street

    Dublin 1

    0 2OCT

    2 15

    Case reference: PL29N.PA0043

    Jean Early John lane

    11

    McDowell Ave,

    Ceannt Fort, Mount Brown,

    Dublin 8.

    AN

    BORD

    PLE N L

    Received:

    A b

    l

    } I

    Fee :

    -ES oDO

    Receipt No:

    J

    I

    3 1

    2

    I

    b

    Health Infrastructure Development compr ising National Paediatric Hospital,

    Innovation Centre and Family Accommodation Unit at StJames Hospital

    Campus, Satellite Centres

    at

    Tallaght and Connolly and Construction Compound

    at Davi tt 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

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    NCH PLANNING APPEAL

    Ref

    Pl29N.PA0043 Jean Early John lane

    .

    '

    Contents

    1.0 SUMMARY

    3

    2.0 ZONING DEVELOPMENT PLAN 6

    3.0 TRANSITION WITH RESIDENTIAL ZONE 10

    4.0 TRAFFIC SITE ACCESS 11

    5.0 CAR PARKING

    5

    6.0 HELICOPTER LANDING PAD 16

    7.0 SCALE, HEIGHT FORM

    7

    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 Page2

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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

    t

    James' Hospital Campus, Satellite Centres

    at

    Tallaght and Connolly and

    Construction Compound

    at

    Davi tt Road, Dublin.

    1.0 SUMMARY

    Rev A

    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 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 d irected 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 .

    r

    r

    27

    Sep tember 2015

    agel

    0 2OCT

    2 15

    LTR04TEO

    FltOM

    ~

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    .

    -

    _ _ -

    NCH PLANNING APPEAL Ref I PL29N.PA0043

    Jean

    Early & John Lane

    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.

    SKETCH

    SKETCH

    I

    0 2

    O T

    2 15

    Rev A

    27

    Sep

    tember 2015 Page

    T

    DATED FltOM

    .... .

    PL

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    NCH PLANNING

    APPEAL

    Ref PL29N .PA0043

    Jean Early & John lane

    1.1 Extract from the Pre Planning Consultation with An Board Pleanala:

    Inspectors Report Ref PL29N.PC0158

    by

    Kevin Moore dated uly 2015

    2.3 The proposed development now comprises:

    A 473 bed children's hospital at St. James's Hospital campus. Dub

    li

    n

    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

    ofl

    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

    j 27

    September 2015 PageS

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    NCH

    PL NNING PPE L Ref

    PL29N.PA0043

    Jean Early John Lane

    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

    .

    Rev A

    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

    o 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

    o

    the city's

    conservation areas through

    the

    application

    o

    the policies, standards and guiding

    principles on building heights,

    and to

    protect and conserve the special interest and

    character o 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 T J 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 ~ s o R O P L E N L

    E

    BV

    _

    T\IV\

    ...

    27 September 2015

    Page

    Q2 OCl

    2 \5

    L t R ~ l E ______

    FttOM .

    PL

    -

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    NCH PLANNING APPEAL Ref PL29N .PA0043

    Jean Early & John Lane

    Rev A

    2 1 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

    f

    the basement areas were included

    the

    floorspace figure would rise to 122,472

    sq.m. and give

    a

    plot ratio

    of

    2.5.

    t

    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 ofbuildings, 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

    T\ME

    v

    _

    27 September 2015

    Page7

    0 l

    OCT

    2 15

    LTR DAlED ROM '

    PL

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    NCH PLANNING APPEAL Ref

    Pl29N

    .PA0043

    Jean Early

    & John Lane

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

    Rev A

    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

    of42%

    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.

    TIME

    27

    September

    2 15

    PageS

    02 O T 2 15

    LTR OATD _

    ROM

    PL

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    NCH

    PLANNING APPEAL Ref PL29N .PA0043

    Jean Early & John Lane

    Rev A

    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

    t

    13,000sq.m.,

    or

    27%, with

    a

    total

    of

    22,000sq.m

    of

    open space

    t

    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 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

    stories above street level.

    PROPOSED

    EXPA

    N

    SIO

    N

    eroo

    FotHCH

    oc

    nME

    27 September 2015

    Page9

    02

    OCT

    2 \5

    LTROAiED

    _ _ _ _

    IWM

    P L ~ = = = = ~ = = ~

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    NCH

    PLANNING

    APPEAL

    Ref

    PL29N

    .

    PA 43

    Jean Early & John Lane

    3.0 TRANSITION WITH RESIDENTIAL ZONE

    Rev A

    The Development Plan, Section 15.9 TRANSITIONAL ZONE AREAS states

    ~ t h t 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 esidential properties.

    e

    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 Before

    O'Reilly Avenue fter

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    Early

    John Lane

    4.0 TRAFFIC SITE ACCESS

    Rev A

    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

    =

    AN BORD

    PL EANALA

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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 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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    NCH PLANNING

    APPEAL Ref

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    &

    John Lane

    Rev A

    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.

    U

    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 Bowe Lane 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 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 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 ~ f f i c

    along Mount Brown (close to the pr NJl

    f

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    PlANNING APPEAL Ref Pl29N.PA0043

    Jean Early

    &

    John Lane

    Rev

    A

    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

    standstill at

    Mount

    Brown

    7th

    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.

    AN BORD

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    Rev

    A

    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 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

    dr

    awings 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 soR

    PLEANALA

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    PROPOSED

    W TER M IN CONNcnON

    NEWG SSIUO

    on Cone.

    Plinth

    wll l Pallsadt

    ' '

    Jean Early & John Lane

    BELOW GROUND

    RAMP

    ;

    . .

    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

    Rev A

    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 t a f L a n d l t i s i t o r : s = a ~ i l i n g

    AN BORD PLEANALA I

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    PLANNING

    APPEAL

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    .PA0043

    Jean Early & John Lane

    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 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

    S

    t.

    Luke's hos

    pi

    tal 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 pa tients. 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.

    f

    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

    out of the proposed

    new entrance. See Section 5 above.

    The traffic plans are completely unrealistic: Page 24

    of

    the Draft Site Capacity

    Study: ... t 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

    Rev A

    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 fronl.

    ~ ~ v ~

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    APPEAL Ref

    PL29N.PA0043 Jean

    Early John

    Lane

    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

    Rev A

    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

    AN BORO PLEANALA

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    Jean Early John Lane

    Rev A

    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

    a ~ a d e

    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 gas

    . delivery collection.

    AN

    BORO

    PLEANALA

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    Rev A

    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

    27

    September

    2015 Page

    9

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    NBORO

    TIM

    LTR DAT0

    l

    Rev

    A

    Photo 3: Former Entrance to St James Hospital

    hoto

    . 4: Existing

    wall &

    part

    of school house

    which are proposed to be

    demolished to make

    way for

    a 3 storey building with modern cladding.

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    APPEAL

    Ref I Pl29N.PA0043

    Jean Early & John Lane

    Rev A

    \

    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 1 Floor Plan Dwg No NPH-A-BDP-PL,-01-FA-12 1

    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

    f

    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 Connol ly 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.

    f

    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.

    . .

    N soRD PLEAMALA

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    Early

    &

    John

    lane

    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.

    90

    IMPACT

    ON

    RESIDENTIAL AMENTITIES

    Rev

    A

    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 Sett lement & 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, d i m m l e - - - - - ~ ~ ~ ~ - : -

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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

    Rev A

    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

    a c c ~ s to the new proposed FM (Facility Managem r9

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    John Lane

    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 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

    th

    is 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 th is 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 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 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.

    2

    .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

    Rev A

    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 ra ted site selected for this

    hospital?

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    Lane

    r

    '

    1.

    to.'

    The site pl n on which the Dolphin report for t James was b sed on Site A

    was to cont in both the NCH the Maternity Hospital s shown above Site B

    was available

    for

    future expansion

    nd

    is

    now proposed

    to house the

    new

    Maternity Hospital

    14.0 COMMUNITY GAINS

    Appendix 5: 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

    f

    Rev A

    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

    C J B O R D P L . : A N L

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    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 3 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:

    Rev A

    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:

    s 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 ofAlternatives

    and th

    11

    , , . . . , ; , . . , , . , , ' '

    Report address this issue.

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    Early & John Lane

    -

    Rev

    A

    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 tri

    location (children s hospital,

    adult

    teaching hospital and maternity

    hospital).

    A Draft Site Capacity Study has been prepared with respect to

    James's

    Hospital campus that addresses the ability

    of

    he 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

    he 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

    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.

    \ I '

    I

    n outli

    ne

    Construction Management Plan has been preparedand

    is submitted with the application

    and

    the specific matter

    of

    he

    existing

    hospital

    operations is

    addressed

    therein.

    See above for the construction issues we have grave concerns

    about

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    Rev

    A

    Satellite Centres - their need and

    applicability in

    the context of a national

    and regional

    strategy

    relating

    to

    same.

    he

    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

    o

    one

    or both atellite Centres

    failing

    to acquire

    planning permission

    or

    ailing to be developed.

    he

    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

    he 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 he Connolly Hospital

    Master

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    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 4

    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

    issu s 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 hese matters are addressed in full in the EIS

    17.0 CONCLUSION

    Rev A

    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

    e

    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

    e

    addressed by the developer.

    This. c._ .

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    PlANNING

    APPEAL

    Ref

    t

    PL29N.PA0043

    Jean

    Early John Lane

    Rev

    A

    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 ~ o p o s e 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 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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    PLANNING APPEAL

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    John

    Lane

    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: Descr iption of the Development

    2.4.1 New Children's Hospital uilding

    .

    J

    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 ltleoverall he Qht

    or

    he building to ridge level or

    he

    roof 219

    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 a evised ground level or Ordnance Datum 21m at the proposed entrances

    The

    proposed

    storey heights

    are

    as foiJoY s

    18.2 Extract from the New Children's Hospital Web Site

    http

    ://www newchlldrenshospital.ie/

    Concept design for the new children's hospital is unveiled:

    Key acts about the

    building

    7

    storeys at ts highest pomt

    With the maJonty of the bu1ldmg

    sutmg at four storeys

    42

    beds

    n cr

    tJCal care un1t

    8

    neonatal

    cn t

    1cal care

    un.ts

    380 single 1n-pat1ent rooms

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    18.3 Extract from the Public Site notice:

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    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 August 2014

    Rev A

    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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    N.

    PA 43

    Jean Early

    &

    John Lane

    r

    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 esn'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

    Rev

    A

    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 - risin g to seven stor

    es at

    its highest point

    above

    ground

    s1ts comfortably within the existing St. James s Hospita l campus,

    the

    first views of

    the hospita l being an oval pavilion

    set

    n a therapeutic rooftop garden. The garden

    is

    an integral part of the design as

    it

    w ll give a tangible

    sense

    of this being a

    spec1al pl

    ace

    - one for children

    and

    young people elevated above

    the

    world of

    adults

    .

    F

    D2

    O T .J

    I _

    FROM

    .....

    27 Sep

    tember

    2015

    Page 33

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