A review of the assessment of Noise and Vibration relating to the proposed National

Children's Hospital on a campus shared with St James's Hospital, James's Street,

Dublin 8.

Rev:1.21 (Issue)

Prepared by:
Diarmuid Keaney, ICAN Acoustics.
Date: Thursday, 01 October 2015

Signature:

______________________________

Diarmuid Keaney MIOA

M.Sc. in Applied Acoustics, Diploma in Acoustics and Noise Control and B.E.
ICAN Acoustics,
Tel: 01-4403869, 091-588555.
Mobile: 087-8137058
Email: diarmuid@acoustics.ie
Web: www.acoustics.ie

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Table of Contents
EXECUTIVE SUMMARY

III

INTRODUCTION

1.1

Proposed location for the NCH

1.2

About the Author

THE PURPOSE OF AN EIS

2.1

Impact from noise and vibration

2.2

Existing Environment

CONSTRUCTION PHASE

3.1

Assessment Criteria

3.2

Predicted Demolition/Construction Noise

3.3

Vibration resulting from construction activities

THE PROJECT CONSTRUCTION MANAGEMENT PLAN

4.1

Extract from the Outline Construction Management Plan at St. Jamess Hospital

4.2

Noise Limits set out in the Construction Management Plan

10

4.3

Vibration Limits set out in the Construction Management Plan

11

OPERATIONAL PHASE

12

5.1

Increased noise from traffic

12

5.2

Assumptions made in the AWN Consulting study

13

5.3

Measurement of an actual Medevac Hospital Landing/Take Off

17

5.4

Specialist services Health Technical Memorandum 08-01: Acoustics(2008)

26

CONCLUSION

31

6.1

Construction Noise Impact

31

6.2

Vibration impact during the Construction Phase.

31

6.3

The Impacts of Helicopter Noise and activity on Hospital Bedrooms

32

6.4

The Impacts of Helicopter Noise on residential amenity

32

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6.5

Overall Conclusion

33

TERMINOLOGY

35

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Executive Summary
This study examines the assessment methods used in the projects EIS and closely examines the likely impact
of demolition/construction noise on the residential properties and existing hospital buildings within vicinity of the
proposed NCH construction site. It highlights a significant short fall in the EIS, where NRA construction noise
limiting levels (for new road schemes) are being proposed in what is a long term construction project (2 to 3
years), in a constricted space arrangement unlike a moving road scheme. Our study also indentifies guidance in
BS5228 which is referenced in the EIS, yet some elements have been ignored which suggests that for the
construction noise limiting levels proposed at the site, that temporary re-housing of residents should be
considered. This assessment of noise and vibration confines itself to the St Jamess Campus. Our study shows
that the authors have been selective in the use of guidance in discussing examples of noise limits in BS 5228,
where they have only cited the most simplistic case. One is left to conclude that the criteria chosen by the
authors, the NRA criteria, have been chosen, not because they are most appropriate but because they favour
the authors argument.

We have review the projects proposed vibration assessment methodology and it is clear that no examples of
calculated vibration have been provided. It is also evident that a basic generic third party calculation method is
being considered and one that does not take account of the actual ground strata at the location. Considering
the proximity of the proposed ground works, 10m from residential properties and 7.5m from clinical areas, we
would have expected to see a rather more robust prediction method and perhaps a vibration risk assessment.
Neither of these have been provided in the submitted EIS.

The Construction Management Plan adopts the same criteria proposed in the chapter on noise and vibration
where contractors will work to limiting levels suggested by AWN Consulting which in my view are clearly not
appropriate for this site.

There are many short falls highlighted with regard to operational noise and its likely impact. Design
documentation identifies a naturally ventilated building where possible, however it would appear that no
consideration has been given to the fact that naturally ventilated building are inherently acoustically weak
structures with regard to inbound noise. It would appear that noise intrusion from external sources has not been
adequately considered and no attempt has been made to establish if the naturally ventilated hospital rooms
would be actually fit for purpose if assessed using appropriate UK guidance documents, issued by the
Department of Health (HTM-08).

Our review shows that the impact of noise arising from the proposed helipad has been grossly underestimated.
As part of our study we have investigated an actual hospital helicopter Medevac operation and timed the
duration of each element. We would be very concerned also that the project EIS considers just one aircraft type
(Augusta Westland AW-139) and does not consider the likely impact of a Sikorsky S92 and the potential impact

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on both residents and hospital occupants. A fundamental shortfall in the assessment of noise impact is the fact
that noise sensitive naturally ventilated hospital bedrooms have not been assessed with regard to the likely
impact of inbound helicopter noise and the fact that it will give rise to sleep disturbance or in this case fright to
young children. The worst affected elements of the proposed NCH will be hospital bedrooms on Level 4, Level
5 and Level 6. Our predictions show that any use of the helipad will most likely give rise to sleep disturbance at
night in the hospital bedrooms and that no consideration has been given to the layout in this regard as
suggested in HTM-08. It appears also that the chapter on noise and vibration attempts to understate the likely
impact of noise on residential properties too arising from helicopter movements and goes to great lengths to cite
reports which in some cases dismiss the need for any noise assessment whatsoever. The Irish Aviation
Authority provide very clear guidance on the placement of helipads and on their likely noise impacts, however
this has been ignored. There is a serious conflict in the design strategy where it is proposed that a naturally
ventilated building would be constructed at an urban location with a proposed helipad in such close proximity,
which in our view would give rise to hospital bedrooms which are unlikely to be fit for purpose.

In conclusion, the degree of noise and vibration has not been adequately considered with regard to the
proposed NCH development and these omissions seriously compromise the proposed development in our view.
An EIS should adequately consider the likely impact of noise and vibration on both the occupants of the
proposed facility and occupants of noise/vibration sensitive properties in the locality; however this has not been
satisfied for the proposed NCH development.

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1 Introduction
ICAN Acoustics have been engaged by the Jack and Jill Foundation, to review a noise and vibration study
submitted as part of an Environmental Impact Statement (EIS) relating to the proposed National Children's
Hospital (NCH) at St James's Hospital, James's Street, Dublin.

The noise and vibration study under review in this report has been prepared by AWN Consulting and forms a
key element to the project's Environmental Impact Assessment (EIA). The report examines the AWN
Consulting study in detail and specifically refers to Chapter 11 (Noise and Vibration) and Appendix 11.1
(Glossary of Acoustic Parameters).

This review will consider principally noise and vibration impact at the St James's site and while the AWN
Consulting study discusses a construction compound at Davitt Road, Drimnagh, Dublin 12, this will not be
considered in detail by us. The focus of this study specifically relates to the likely noise and vibration impact on
the existing St James's Hospital during the construction phase as well as considering operational noise and its
impact on the proposed National Children's Hospital and residential properties within the vicinity of the site.

1.1

Proposed location for the NCH

St James's Hospital is located in a densely populated area of Dublin 8, between St James's Street and the
LUAS Tramway. It is surrounded on four sides by residential streets, the nearest residences being
approximately 50 m from the closest part of the proposed childrens hospital. The hospital will be situated
principally where an existing car park is currently located on the hospital grounds, however it is also likely that a
number of existing buildings will also need to be demolished as part of the proposed development.

Figure 1 below shows an architectural rendered drawing of the proposed National Children's Hospital (NCH) at
St James's Hospital. Some key features are noted in the design for noise and vibration purposes including an
elevated helipad, located on the southern end of the building adjacent to the southern boundary, close to the
LUAS tramway line and residential properties on St James's Walk. This figure also shows the proposed family
accommodation units proposed at the Western side of the NCH and it does give a good indication of the density
of the development and its proximity to residential dwellings within the area.

It is worth noting that the proposed NCH building will be closely bounded by residential properties on the
southern side of the site, the western side of the site and an estate of houses to the north east of the site, which
include Donnellan Avenue, O'Reilly Avenue, Owen's Avenue and Quinn Avenue. These streets are located on
the southern side of Ceannt Fort on Mount Brown and residential properties on O'Reilly Avenue will share a
rear garden boundary with the proposed NCH.

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Proposed family
accommodation
units.

Existing St
Jamess Hospital

Proposed NCH

Proposed
Helipad

Brookfield
Road
Luas stop &
James' Walk

South Circular
Road
Mountshannon
Road
Figure 1: Photomontage of the proposed hospital building at the St James' Hospital site.

1.2

About the Author

Diarmuid Keaney of ICAN Acoustics holds a Masters of Science in Applied Acoustics from the University of
Derby, where he was awarded a distinction on completion of his studies. Following on from the completion of
his independent study (as part of the Masters programme), titled "A critical review of the assessment of traffic
noise at rural locations in Ireland", his research work was published by an independent book publishing
company. This research has since become an acoustics technical reference book which sells on Amazon today
and has been endorsed by leading experts in the field of acoustics and mathematics. Diarmuid also holds a
Diploma in Acoustics and Noise Control and was awarded a merit by the Institute of Acoustics on completion of
his studies at the University of Ulster. Diarmuid also holds an Honours (2:1) Bachelor of Engineering Degree
from the National University of Ireland.

Diarmuid Keaney has over 15 years expertise in the area of acoustics and is highly skilled and experienced in
noise and vibration measurement and assessment, noise and vibration prediction, noise contour modelling,
environmental noise, building acoustics and environmental noise control. Diarmuid is a corporate member of
the Irish Branch of the Institute of Acoustics and currently serves (for 6 years at the time of writing) on the
Committee of the Irish Branch. Diarmuid regularly presents seminars on acoustics to architects, engineers, and
members of other related professions. Diarmuid is a guest lecturer at a third level institution where he provides
seminars on environmental noise and building acoustics to undergraduates of the Masters in Environmental
Engineering and Architectural courses. He has also had formal expert witness training and regularly provides
expert testimony in Court and at Oral Hearings in the area of acoustics.
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2 The purpose of an EIS

2.1

Impact from noise and vibration

An EIS should adequately consider the likely impact of noise and vibration on both the occupants of the
proposed facility and occupants of noise/vibration sensitive properties in the locality. It has already been noted
that the area is densely populated and there are a large number of residences which would be potentially
impacted by the construction and operation of the proposed NCH. With the proposed NCH development, we
need to also consider the likely noise and vibration impact on the existing nearby St Jamess Hospital during
construction and operational phases of the NCH project. Operational noise and vibration should also be
evaluated with regard the proposed NCH building and any adverse impacts that operational activities could
have on that building.

Chapter 11 has addressed potential impacts of noise and vibration at both the construction and operational
stages and we shall comment on the methodology of assessment and conclusions drawn. We note that the
construction phase, i.e. prior to opening of the hospital is estimated to last until 2019, i.e. approximately 4 years.
This will involve clearance of the existing site, ground works prior to construction and the construction proper,
prior to fitting out before the proposed hospital becomes operational. It is estimated that the
clearance/construction phase will last approximately 2 to 3 years. Considering the proximity of a large
number of dwellings and the length of the project in a constricted space, it is considered that the construction
phase of the project is likely to give rise to an appreciable impact from construction activities to both local
residents and to the existing hospital.

Figure 2 below sets out the details of the AWN Consulting Noise and Vibration study and their approach with
regard to noise and vibration relating to the site.

In assessing the noise and vibration impacts the following methodology will be adopted:
1. Characterise the receiving environment through a series of baseline surveys;
2. Determine appropriate criteria for evaluating the significance of noise and vibration impacts
through reference to local guidance documents where applicable and international best practice;
3. Calculate the potential noise & vibration impacts using industry standardised calculation
methods;
4. Assess the impact by comparing the calculated levels against the adopted criteria;
5. Where necessary specify ameliorative, remedial or reductive measures to control the impacts to be
within the adopted criteria, and;
6. Present the predicted impact of the proposed development including the ameliorative, remedial or
reductive measures.
Figure 2: An extract from the AWN Consulting Noise and Vibration study and methodology adopted
(11.1.2)
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We would not disagree with the methodology adopted but it will be necessary to consider the methods used for
measurement and evaluation and the criteria used in determining the likely impact of noise and vibration.
We will review the construction and operational phases separately in the light of the potential impact on the
existing environment as described in the EIS.

2.2

Existing Environment

Surveys of noise and vibration have been conducted at a relatively large number of locations in and around the
proposed site. The noise surveys indicate that the residential properties around the hospital are in what would
be described as typical urban noise environments. It is noted that the background noise levels vary between
approximately 42 - 45 dB LA90 and 38 40 dB LA90 during daytime periods in predominantly residential streets.
At some locations, such as N2, the background noise levels at houses close to the main road are higher, due to
the proximity of passing traffic. However as the distance from the road increases along the side streets, the
noise level will drop accordingly. In general, houses closest to the proposed site are not subjected to continuous
high levels of noise from traffic or other sources.

A number of noise and vibration measurements were made inside wards and treatment areas in close proximity
to the proposed site within the existing hospital. It was found that levels of noise within those areas was
dominated by general activity and conversation and would be typical of what might be expected in a medical
treatment room. Levels of vibration were found to be very low.

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3 Construction phase
3.1

Assessment Criteria

The potential impact of noise and vibration during the construction phase is discussed in Paragraph 11.1.5.1 of
the submitted EIS. It is correctly stated that there is no published statutory Irish guidance relating to maximum
permissible noise and vibration levels during the construction phase of a development although several
publications are used to set appropriate criteria. In this case the adopted criteria are presented. It must be
presumed that the criteria have been adopted by the authors of the report, since there are no nationally adopted
criteria.

The authors briefly discuss in Appendix 11.2 a method for deriving criteria for assessing the likely impact of
noise and vibration during the construction phase of the project. Mention has been made of the National Roads
Authority (NRA) publication Guidelines for the Treatment of Noise and Vibration in National Road Schemes.
Some paragraphs from BS 5228-1:2009+A1:2014 Code of practice for noise and vibration control on
construction and open sites Noise have been presented, principally in relation to a method of predicting noise
levels from site operations and an example of determining noise limits for construction and demolition noise.

We note however that the authors have been selective in discussing examples of noise limits in BS 5228,
where they have only cited the most simplistic case, Annex E: E2, which is described as the older and more
simplistic method. BS 5228 does in fact give a number of examples of noise limits for differing situations as
discussed in E3 Significance based on noise change. This part of the annex suggests that an alternative
and/or additional method to determine the significance of construction noise levels is to consider the
change in the ambient noise level with the construction noise. This reflects more conventional EIA
methodologies for noise.

Since an environmental impact assessment is used to determine the likely impact on the local environment, it
suggests that it would be appropriate to determine how the level of noise would change in relation to the preexisting or ambient environment.

Two methods are given in E.3.2 and E.3.3 (of the BS 5228 guidance) for determining appropriate limits by
considering pre-construction noise levels. When the baseline noise data shown in the EIS is considered, both
these methods would suggest a limiting noise level of 65 dB LAeq during daytime hours, 55 dB in the evenings
and 45 dB at night-time.

Paragraph E.4 goes on to discuss the assessment of the significance of noise effect and suggests that where
the construction noise exceeds the ambient noise level by more than 10 dB and for a period of 10 days or more
in any 15 consecutive days or for a total of more than 40 days in any 6 month period, temporary re-housing
should be considered. It also suggests that buildings which are likely to be particularly sensitive to noise,
(including hospitals) will be subject to individual consideration.
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It is noted that daytime and evening ambient noise levels (LAeq) at a number of the baseline monitoring sites are
below 55 dB. It is therefore surprising that no assessment against that part of the Annex E to BS 5228 relating
to relative change was included, since it is apparent that the change of impact is likely to be significant.

One is left to conclude that the criteria chosen by the authors, the NRA criteria, have been chosen, not because
they are most appropriate but because they favour the authors argument.

We must stress at this point that the demolition/construction phase will last for a period of 2 to 3 years. BS
5228 recognises that it is generally assumed that a greater difference might be tolerated, than for an industrial
source, when it is known that the operations are of short or limited duration, however it also recognises that the
longer the duration of activities on a site, the more likely it is that noise from the site will prove to be an issue.

The authors have adopted the NRA criteria, which are intended to be used for new road schemes. It should be
borne in mind that whilst a major road project may last for a period of years, the activity will not be static at any
particular location but will move along the route of the road. Hence persons affect by noise will not be
continually affected by noise however long road building occurs. However in the case of the proposed site for
the Childrens Hospital, residents will be subjected to construction noise over the entire period of construction.
We would seriously question then whether the construction noise assessment has been based on suitable
criteria for this project and this location.

3.2

Predicted Demolition/Construction Noise

The submitted EIS has predicted likely levels of demolition and construction noise on and around the site, using
typical noise levels listed in BS5228 for various operations. Models have been produced using computer
software. The model includes mitigation measures, including temporary screens around the site. Considering
that the predicted noise level models have been based on published empirical data it should be stated that the
noise levels published in Table 11.12 of the submitted EIS will not be a precise prediction. It is possible that
actual levels could be higher for a number of reasons including the degree of mitigation applied, exact location
of plant and height of emission of noise from plant.

Table11.12 indicates that the overall level of construction noise throughout the duration of such work, with
relatively few exceptions is likely to be between 60 and 68 dB LAeq at noise sensitive premises. For example at
Receiver position 24 (61 OReilly Avenue) the construction/demolition noise has been predicted to be between
64 68 dB throughout the construction period. When viewed against a measured ambient noise level of 52 dB
LAeq on an afternoon, such noise, over an extended period of several years, even during daytime hours, would
represent a considerable impact upon the residents in that locality. Similarly the predicted construction noise
level outside a number of spaces within the hospital would be high for prolonged periods. It is noted that outside
the Trinity Health Sciences Centre the noise level has been predicted to range between 67 76 dB. It is
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suggested in Table 11.13 of the EIS that the internal noise level in that space during the operations would range
from 42 51 dB, that is a reduction of 25 dB through the external faade of the building. The assumption has
been made that windows will be closed at all times but our understanding is that the rooms in the hospital are
naturally ventilated and it will therefore be necessary to open windows for ventilation. In such circumstance the
internal noise level is likely to be 10 15 dB higher, which will be between 57 66 dB. Such level would be
considered to be unacceptable in situations where good speech communication is required or where a quiet
environment is required for clinical work.

The authors have concluded that outside all noise sensitive locations around the site the construction noise
levels will be below 70 dB LAeq and hence within limits which would be considered to be acceptable. We would
argue that in many of the locations the level of construction noise would give rise to a considerable impact over
an extended period, even after mitigation measures had been employed. We do not accept that residents who
would be exposed to external noise levels of up to 70 dB LAeq day after day for a period of up to 3 years would
find the noise environment to be in any way acceptable.

It is also concluded that internal noise levels in clinical areas within the hospital will be lower than the typical
internal noise criterion of 45 dB LAeq. When windows are open for ventilation noise levels in a number of clinical
spaces would be likely to be considerably in excess of 45 dB and could materially affect clinical work. We note
that no consideration has been given to short term high levels of noise from particular operations. Such impact
type noises can give rise to shock and sleep disturbance.

3.3

Vibration resulting from construction activities

The likely impact of vibration during the construction stage of the project is discussed in chapter 11.1.5.1 of the
EIS. It is acknowledged that vibration can affect buildings and occupants, both in terms of physical effect on
buildings and human disturbance and comfort. It is acknowledged that there are concerns particularly in relation
to some residential properties which are particularly sensitive due to weak foundations and to activities within
clinical areas of the hospital.

The basis of the AWN Consulting predictions use a third party hypothesis, which we understand has been
prepared by Rupert Taylor (Document Ref. CHOI/MPH/6A dated 7 February 2011), and assumes that the work
done by an auger is proportional to pile toe area, which is proportional to the square of the radius.

We are presented with the follow hypothesis in the AWN Consulting submission

This is taken from the report prepared by Rupert Taylor (Document Ref. CHOI/MPH/6A dated 7 February 2011) on the
vibration impacts of the previously proposed Childrens Hospital Development at the Mater site where he state, Based on
the hypothesis that the work done by an auger is proportional to pile toe area, which is proportional to the square of the

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radius. The power in a vibration signal is proportional to the square of the velocity (from engineering basics) so that the
vibration velocity is proportional to the square root of the power and therefore proportional to the radius.

Examples of suggested vibration allowable levels are given for soundly constructed buildings, sensitive
buildings and clinical buildings in Tables 11.7 11.9 of the submitted EIS. It is reported that the impact of
vibration is likely to be greatest during the piling phase of the project and in light of the fact that there are many
sensitive properties in the vicinity, bored piles will be used rather than hammered piles. There is no mention of
any other possible source of vibration, such as the use of mechanical breakers and pneumatic drills which
would be used for the breaking and opening of concrete and metalled surfaces.

In predicting the impact of construction vibration, extracts from BS 5228-2 Table D have been used to show the
apparent vibration levels from rotary bored piling and then reference is made to the report of Rupert Taylor
relating to vibration impacts at the previously proposed Childrens Hospital Development at the Mater site. No
examples of calculation of vibration levels are given, but it is reported that considering the distance of the piling
works from the nearby residential buildings (as close as 10 m) and the hospital Emergency Department (7.5 m),
vibration levels will be well below the level at which even cosmetic damage would occur and that levels within
clinical areas in the hospital will have no perceptible impact. In the interests of transparency such examples of
vibration calculations should be given.

We are not able to make any detailed comment on the method of calculation due to the fact that the vibration
calculations have not been given, but it would appear that a very basic generic calculation has been used
rather than one which takes account of the actual ground strata in this location. Considering that piling will take
place as close as 7.5 m from clinical areas and 10 m from residential properties, we would have expected to
see a rather more robust prediction method.

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4 The Project Construction Management Plan

This chapter considers a review of the Construction Management Plan prepared by O'Connor Sutton Cronin
Consulting Engineers, dated August 2015. It would appear that this document adopts the criteria for noise and
vibration which have been set out in AWN Consulting's chapter on noise and vibration.

4.1

Extract from the Outline Construction Management Plan at St. Jamess Hospital

The following text is an extract from the Outline Construction Management plan for St Jamess Hospital. This
has been reproduced below to allow us to make comment in the latter part of this chapter.
The works for the secant pile wall to the perimeter of the basement are likely to commence prior to the
completion of, and thus overlap with, the demolition works. The piling works are estimated to continue at a rate
of approx. 3-4 piles/day per piling rig. Given the plan extent of the site and the required secant pile wall, it is
estimated that there would be in the order of 4-6 piling rigs on site during the peak piling works. This would give
rise to a requirement for approximately 40 concrete loads per day for secant pile wall installation.

The overall plan extent of the secant pile wall is c.900 linear metres leading to a requirement for c.1000no.
piles. The piles vary in length depending on their location on site and the lowest level of structure at that
location, with piles typically varying from c.10m to c.20m in overall length.

The proposed building is located around some sensitive receptors, namely the adjacent listed Haughton
Institute and the McDowell Avenue residential properties and boundary wall to the rear as well as 3no. mature
trees on Jamess Street. A secant pile wall is the proposed ground support system along the
boundary/interfaces and has been set-back away from these in recognition of their sensitivities while protective
hoarding shall be applied to the mature trees. Throughout the build and construction process these existing
buildings and structures will be adequately protected and monitored to ensure their current condition is not
structurally impaired in any way. During the installation of the secant pile wall and basement excavation
activities, state of the art real time monitoring will be set up and carried out. A traffic light system will be put in
place consisting of:
o Green-vibrations below threshold limits-OK to proceed
o Amber-vibrations exceed first threshold limit-Stop and check
o Red-vibrations exceed second threshold limit-Stop and action
Once the secant pile wall is installed, works will commence on the excavations down to basement level. This
will involve the removal of c. 5,000m3 of material for disposal off site.

We would be concerned that the Outline Construction Management Plan appears to focus its concerns on
vibration sensitive listed buildings, some residential properties and 3 mature trees on James's Street. While the
construction management plan does make reference to allowable limits for hospital operating theatres,
precision laboratories and audiometric testing booths, it makes no specific references to vibration sensitivity of
imaging equipment such as hospital CT scans or robotic surgery systems. While it could be suggested that
precision laboratories may cover imaging and perhaps robotics medical work, we are most surprised that an
identification of vibration sensitive hospital equipment (by way of a drawing) and its exact location is not
included in the outline of the Construction management plan. In our experience, robotics work is not particularly
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vibration sensitive, however it would seem prudent to carry out a risk assessment on all the potentially vibration
sensitive equipment and services that take place considering the proximity of the working St James's Hospital
to the proposed NCH construction site. This deficiency in assessment will be addressed in greater detail later
in this report.

4.2

Noise Limits set out in the Construction Management Plan

Figure 3 below is an extract from the Construction Management Plan. It is clear that the contractor is expected
to adopt the limiting levels suggested by AWN Consulting, which are in fact clearly not appropriate for this site
as shown in our Chapter 3.1 and Chapter 3.2 above.

Figure 3: Extract from the Construction Management Plan prepared by OCSC, showing prescribed
noise limiting levels which have been adopted from the Chapter prepared by AWN Consulting.

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4.3

Vibration Limits set out in the Construction Management Plan

It would appear also that OCSC have adopted the vibration limiting levels set out in the AWN report, which have
been discussed in our Chapter 3.3 above. In that chapter we set out our concerns relating to the methodology
which has been adopted with regard to vibration prediction and assessment.

Figure 4: Extract from the Construction Management Plan prepared by OCSC, showing prescribed
vibration limiting levels which have been adopted from the Chapter prepared by AWN Consulting.

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5 Operational Phase
5.1

Increased noise from traffic

It should be noted that there is a significant amount of site traffic already present at the existing St Jamess
Hospital. In terms of noise assessment and the impact of changes in the noise climate as a result of noise
arising from the proposed development, it should be noted that a doubling of traffic volume at the site would
typically result in an increase of approximately 3dB(A), therefore the resulting change would not be deemed to
be significant in terms of the overall scheme. We note that the AWN Consulting report (Table 11.16) reports a
change in traffic level which is insignificant at the year of opening, in the order of 0.1~0.6dB. Following on from
Table 11.16, Table 11.17 of the submitted EIS reports this change as being barely perceptible and minor. What
is most surprising however is that the AWN report does not give any consideration to the fact that the proposed
NCH building will be a naturally ventilated building where possible in an environment which the baseline study
describes a traffic dominated urban noise climate. Inbound noise from external sources can be a concern when
it comes to naturally ventilated buildings and the location of a naturally ventilated in high activity urban
environment would be somewhat questionable.

Architecturally rendered drawings show that it is proposed that the NCH bedrooms will be naturally ventilated
with top hinged window systems. Our Figure 15 on page 24 of this report shows an example of what we
understand to be a typical NCH bedroom. Naturally ventilated buildings are typically acoustically weak and
often are unsuitable at site locations where traffic noise and ambient noise is already likely to be high, such as
in this case.

In our view, the following guidance documents should be referenced to establish if a naturally ventilated building
is to be considered in what is already a built up urban environment, which could find the NCH proposed room
ventilation strategy to be inappropriate and unsuitable for the site.

Reference documents to be considered:

1999 WHO guidelines for community noise (sleep disturbance)

WHO Night Noise guidelines (L.O.E.L. with regard to sleep disturbance)

Health Technical Memorandum 08-01: Acoustics

The UK Department of Health issued specific guidance (HTM-08) which prescribes appropriate noise levels
relating to hospitals. The guidance provides different criteria for sleeping during the daytime and night, which
has been reproduced in Table 1 below. While it does acknowledge that Table 1 is not in full compliance with
WHO recommendations to avoid sleep disturbance, it also recognises that hospital environments can be
subject to high sporadic noise levels, including emergency vehicles and helicopters. We were unable to locate
any such assessment in relation to likely inbound noise relating to the proposed naturally ventilated NCH
hospital building being proposed at St Jamess. The applications baseline study does show that daytime noise
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levels are significant at street levels, such as baseline study locations (N2, South Circular Road) with traffic
noise levels as high as 66dB(A) at the lower floor facades and (N5, St James's Walk) with distant traffic and
Luas noise as high as 62dB(A) at midnight. We note that there are parent accommodation rooms planned on
these naturally ventilated facades at Level 2 and bedroom accommodation at Level 1, which would cause
concern in relation to the proposed naturally ventilated building strategy.

Table 1: Extract from HTM-08 in relation to criteria for noise intrusion to be met inside the spaces from
external sources.
There is no evidence in the AWN Consulting report submitted with the application, to establish if it is appropriate
to install a naturally ventilated building at this urban location. It is worth noting also that for the construction
phase of the proposed NCH project over a 2 ~ 3 year time frame, how the noise climate in the existing St
Jamess hospital will differ from the levels described in Table 1 (HTM-08) extract above is not addressed. This
needs to be determined if the intrusive noise from construction will allow St Jamess to function and continue
as a working hospital throughout the protracted construction phase. In fact it would appear that AWN in their
review of the proposed construction noise impact, propose that Clinical areas have factored in a degree of
noise reduction afforded by a closed windows to minimise noise intrusion. This in our view should not be
proposed without the consideration of how these clinical areas will be ventilated in the absence of what appear
to be naturally ventilated rooms with openable windows.

5.2

Assumptions made in the AWN Consulting study

The AWN Consulting chapter on noise and vibration, submitted as part of the NCH EIS, suggests that the
impact of noise has been quantified using just four helicopter movements per week. The AWN Consulting
submission is clear on its assumptions that the basis of the assessment had been carried out based on the
following assumptions:

the aircraft that will be in service at the site will be an Augusta Westland AW-139 as operated by
the Irish Air Corps;

helicopter trips to the new childrens hospital will be for emergency cases only and as a result may
occur at any time of the day and night;

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the proposed helipad will service both the new childrens hospital and the wider St. Jamess Hospital
campus, and the expected number of cumulative flights (i.e. serving the new childrens hospital and St.
Jamess Hospital campus) over a week long period is 4 landings and 4 take-offs.

Following on from these assumptions, the Chapter on Noise within the EIS assumes a very basic interpretation
and limited understanding of how helicopter operations actually work in practice. In the predictions carried out,
the EIS considers:

Just one helicopter type and no consideration has been given to other helicopter types.

The prediction process has been based on measurements carried out by a third party, Commandant
Colin Roche using a Brel & Kjr Type 2260 Precision Sound Level Analyser, with no detail provided
on the test arrangement, with the exception that measurements were conducted at 3m distance (from
where?). It is expected that if this relates to 3m from the aircraft fuselage, then Commandant Roche
would be directly under the main rotor.

The predictions are over simplistic in that they simply consider a landing time of 63 seconds and a takeoff time of 17 seconds.

It is clear that there is a fundamental misunderstanding of actual Medevac helicopter operational requirements
which have not been factored into the predictions carried out by the projects noise consultants. While we are
not disputing Commandant Roches measurements, there has been a fundamental misunderstanding as to how
helicopter operations function at a Hospital Helipad. When we examine the predictions, it is clear that a very
limited set of data, which are of very short duration event times (63 seconds & 17 seconds) have been
considered. Figure 5 below, extracted from the AWN Consulting report, considers a single Augusta Westland
AW-139 as the only helicopter that will use the proposed helipad.

Figure 5: Extract from the Chapter 11 (Noise and Vibration) relating to the measurement of a single
aircraft (AW-139) prepared by Commandant Colin Roche of the Irish Army.
In the submitted EIS the noise consultants have attempted to predict the impact of helicopter noise using the
benefits of averaging the noise levels over a day time 16 hour period and an 8 hour night period. In Figure 6
below we can see that the night dB(A) level is based on a single landing which has been averaged out over an
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8 hour period in an attempt to minimise the apparent impact created by a landing at night. However what is
likely to be much more important in relation to assessment of helicopter noise in this particular situation is the
likely level of noise from individual events, which may give rise to sleep disturbance or in this case cause fright
to young children.

Our noise contour model shows that the actual noise level experienced at worst affected residential properties,
when the aircraft is landing or taking off at the helipad will be in the order of 72dB(A) for the Augusta Westland
AW-139 when hovering at the helipad, which in our view is a very significant impact. This has been based on
the consideration of a single helicopter type and does not represent larger aircraft such as the Sikorsky S92. It
is also worth noting that NO consideration has been given in the EIS to the likely impact of noise in relation to
the rooms in the hospital affected by noise from helicopter activity at the helipad.

Figure 6: Extract from the Chapter 11 (Noise and Vibration) of the EIS relating to the predicted noise
levels at James' Walk and South Circular Road/Mountshannon, all of which have been based on
reported noise levels prepared by Commandant Colin Roche of the Irish Army

It would appear that the LAeq,T has been averaged over a 16 hour period for the daytime and an 8 hour period
for the night time, which has then been applied to noise sensitive locations at St James Walk and South
Circular/Mount Shannon.

When we examine the impact of a helicopter over shorter, more appropriate observation periods, we can see
that the impact of noise is numerically greater than what is being reported. If the noise consultants assumptions
only consider 1 landing and 1 takeoff over a 16 hour daytime period, it is likely that these two short events will
indicate a numerically lesser impact. For the night period we note also that AWN Consulting considered only a
single landing for a given night which was then averaged over an 8 hour night period. This again would indicate
a numerically lesser impact than what would have been expected if assessed using a 15 minute or 5 minute
night period, which in our view would have been wholly more appropriate.

It should be noted however that humans do not average single noise events over an eight hour period at night
and when a noise disturbance at night occurs, it is evaluated as a single event which is contrasted with the
normal noise climate expected or the noise climate before or after the event. The averaging used by AWN
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Consulting, using mathematical averaging over extended periods, has clearly under-estimated the true impact
of a helicopter event during the daytime and night periods.

The Irish EPA Guidelines (NG4), used for the assessment of industrial noise in Ireland, suggest noise sample
periods should be either 15 minutes or 30 minutes in duration, which applies to day, evening and night time
periods. Other standards such as BS4142:2014 suggest a shorter period of 15 min at night from 23:00 h to
07:00 h, so the concept of averaging noise impact over extended periods (16 hour daytime, 8 hour night time)
would not be appropriate for loud infrequent noise events, such as those created by helicopter landing close to
residential properties. Table 2 below has been prepared to show how time averaging can influence the
predicted level. In this table, we have used the 16 hour and 8 hour data presented in the AWN Consulting report
and examined this as an identical helicopter noise source over 15 minute and 5 minute intervals. It should be
noted that numerically the impact is significantly greater when appropriate shorter periods of assessment are
used.
AWN's

AWN's

Predicted noise

Predicted

Predicted

Predicted

Predicted

level, for the

noise level, for

noise level,

Daytime

Night time

same source

the same

for the same

Level

Level

predicted using

source

source

(Averaged

(Averaged

LAeq,15mins for

predicted

predicted

over 16

over 8

a daytime period.

using

using

hours)

hours)

LAeq,15min at

LAeq,5min at

night.

night.

James Walk

62dB

68dB

77dB

83dB

87dB

South Circular

62dB

72dB

77dB

87dB

91dB

16 hours

8 hours

15mins (900

15mins (900

5mins (600

(57500

(28,800

seconds)

seconds)

seconds)

seconds)

seconds)

Road/Mountshannon

Observation Period

Table 2: Contrasting AWN Consulting's time averaged predicted levels against typical observation
periods.
It is clearly apparent that the impact of helicopter noise on both patients and residents, assuming landing/takeoff times as reported, when assessed in relation to individual events rather than averaging over an extended
period is very much greater than would be suggested in the AWN Consulting report.

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With regard to the NCH proposed helicopter landings and take-offs per week, the EIS suggests just 4 per week
which will likely underestimate the likely use for a helipad that will service the existing St Jamess adult hospital
as well as the proposed NCH. In Galway City, for a much smaller hospital facility local news reports show that
the Helipad at UCHG is currently subject to one Irish Air Corp landing and take-off per day (Augusta Westland
AW-139) and on some days the hospital can have up to seven Medevacs per day. A link to the news source
has been reproduced below for reference purposes.

http://galwaybayfm.ie/hse-justifies-upgrade-uhg-helipad/

We would be very concerned that the usage of the helipad as set out in the submitted EIS, with an expected
use of 4 times per week with a single type of helicopter, would grossly underestimate the likely noise impact on
residential properties as well as the noise impact on hospital bedrooms at the proposed NCH and the existing
St Jamess buildings. We would also suggest that Medevac operations could not be limited to just four times a
week either, simply by the fact that they are medical emergencies. Therefore in the submitted EIS, we are
unsure of the purpose of selecting just four landing/takeoffs per week was used and why some research was
not carried out at existing hospitals to determine worst case helicopter traffic, which would be then factored up
for the proposed single helipad serving the proposed NCH and the existing St Jamess hospital. This prediction
would include the likely noise impact created at the year of opening and say 15 years ahead, which would be
typical in an EIS study.

5.3

Measurement of an actual Medevac Hospital Landing/Take Off

As part of our study, we actually carried out a duration analysis for a Medevac 112 Hospital helipad landing at
UCHG Galway City. As part of this study, the aircraft evaluated was an Irish Air Corps Augusta Westland AW139. This study allowed us to accurately quantify the times involved, which are significantly longer than those
used in the AWN Consulting's noise predictions in relation to the proposed Helipad at the proposed NCH at St
James's.

Figure 7: Medevac 112 landing and takeoff at UCHG, Heliport Galway City (April 2015)
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Action

Description

Duration

Approach to the helipad

Helicopter noise was the dominant source of noise.

84 seconds

Includes the helicopter approach right up to wheel

touchdown. Engine and main rotor operating at this time.
Aircraft on the helipad

Ramp down of main engines and main rotor, however

50 seconds

the APU remained running after the main rotor had been
shut down.
Patient/Stretcher Transfer

In this study, the engine and rotor were static, therefore

we have not included this in our Medevac time analysis.

Aircraft on the helipad

Engine stabilisation and pre-flight checks before takeoff.

120 seconds

Engine and main rotor operating at this time.

Aircraft takeoff, hover and

Helicopter lift from helipad and departure.

57 seconds

departure.
Total time of event

311 seconds

Table 3: Evaluation of a typical Medevac landing and departure with an Irish Air Corps Augusta
Westland AW-139 at UCHG Hospital, Galway City.

It should be noted that the AWN Consulting's predictions only consider a landing event of 63 seconds and a
departure event of 17 seconds which may have been a 'touch and go' event at Baldonnel Airfield, but it is our
view that the Medevac operation has been grossly underestimated in terms of its actual duration and
consequential noise impact. In our view the impact of a Medevac landing and departure has not been
adequately considered in the AWN Consulting chapter on operational noise impacts. The duration of the noise
impact has in fact been under-estimated by a factor of almost 350~400%, possibly from the use of 'touch and
go' measurements at Baldonnel Airfield, instead of examining an actual Medevac at a hospital helipad such as
we have researched and assessed. Figures 8 & 9 below shows the proximity of the proposed Helipad to both
residential properties as well as hospital bedrooms (Level 4, Level 5 and Level 6) at the proposed NCH
building.

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Nearest Noise Sensitive

Hospital Bedroom Receptors
at the proposed NCH

Nearest Noise Sensitive

Residential Receptors at
James's Walk.

Proposed Helipad
Location

Figure 8:: Showing the proposed NCH at St Jamess with the nearest noise sensitive bedroom receptors
at the proposed NCH. Also in this image, we can see the nearest noise sensitive residential dwellings
located at St Jamess Walk.

Nearest Noise Sensitive Receptors at the

proposed NCH extended over Level 4,
Level
vel 5 and Level 6.

Proposed Helipad
Location

Nearest Noise Sensitive

Residential Receptors at
James's Walk.

Figure 9: This drawing shows a section through the proposed NCH and its proposed helipad and the
proposed proximity to residential dwellings on James' Walk.

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5.3.1

Location of hospital bedrooms relative to the helipad.

Figure 10 below shows a plan view of level 4 showing noise sensitive hospital bedrooms and their proximity to
the proposed helipad. It should be noted that Level 4, Level 5 and Level 6 all house noise sensitive childrens
naturally ventilated hospital bedrooms.
Nearest Noise Sensitive Receptors at
the proposed NCH extended over
Level 4, Level 5 and Level 6

Proposed Helipad
Location

Figure 10: Shows a plan view of the Helipad relative to the upper levels of the NCH.

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5.3.2

Preparation of a 3D Noise Contour Model of the Helipad

Using CADNA-A by Datakustik, a 3D noise contour model has been prepared for the site to allow us to model
the likely noise levels at the nearest facades to the proposed helipad, during helicopter operations at the
proposed NCH. The model allows us to accurately determine the likely noise levels during a helicopter event at
the facades of Level 4, Level 5 and Level 6 of the NCH as well as the noise sensitive residential properties
st

within the area, most of which are at street level and on some occasion are at 1 floor and 2

Nearest Noise Sensitive

Receptors at the proposed NCH
at Level 4, Level 5 and Level 6

nd

floor levels.

Proposed Helipad
and modeled
Augusta Westland
AW-139
Nearest residential
properties on St
James's Walk 46m
from the Helipad

Nearest residential
properties on South
Circular Road.

Nearest residential
properties on
Mountshannon
Road.
Figure 11: Shows a 3D view of the noise contour model with a number of noise sensitive receptors
identified which will be shown in the 2D noise contours below.

Noise receptors were modelled at window height at Level 4 of the NCH building, to determine the likely noise
level at the naturally ventilated hospital bedroom facades of the proposed building. Receptors at street level at
locations such as St James's Walk, Mountshannon Road and South Circular Road were modelled at 4m above
the ground level to represent the likely noise levels outside a typical residential bedroom at night. However, it
should be noted that there is a three story apartment block (Glenmalure Court Apartments) on St Jamess Walk
with bedrooms windows at circa 8m high which will be exposed to still higher levels of helicopter noise than a
typical residential property within the vicinity. So our predicted NCH helicopter noise levels within the vicinity of
properties on St Jamess Walk, Mountshannon Road and South Circular Road, is conservative in its prediction
and does not include higher level residential bedrooms that would exist in apartment type buildings, such as
Glenmalure Court Apartments.

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5.3.3

Noise contour model showing the impact on the nearest hospital bedrooms

Modelled noise source: Augusta Westland AW-139 (using Commandant Colin Roches measurement data from
Baldonnel Airfield).

A typical scenario showing the likely noise levels at the facades of Level 4, Level 5 and Level 6 during a take-off
or landing of an Augusta Westland AW-139 has been generated by us. It can been seen that noise levels
outside hospital bedrooms, during a helicopter event will be in the order of 74~76dB(A) when aircraft is located
at the proposed NCH helipad.

Figure 12: A 2D noise contour model showing the likely noise contours created by an Augusta
Westland AW-139 and the predicted noise levels at the facade of bedrooms at Level 4.

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5.3.4

Noise contour model showing the impact of Air-Sea rescue helicopters

The AWN Consulting assessment in the submitted EIS is based only on a short measurement of one Augusta
Westland AW29 helicopter, which we understand was measured at Baldonnel Airfield by a third party army
officer. This consultancy has measured noise from a Sikorsky S92 helicopter at another site, and this shows
that the noise levels will be 13.5dB(A) higher for the Sikorsky S92 when compared with the proposed Augusta
Westland AW29. This 13.5dB(A) differential has been determined from the reported landing level of 101dB(A)
at 3m from the aircraft, which we understand were compiled by Commandant Colin Roche of the Irish Air
Corps. When this scenario is modelled with regard to the proposed Helipad at St Jamess Hospital, it is clear
that the noise impact will be very significant with this larger aircraft.

Figure 13: It is clear that noise levels will be greatly in excess of 85dB(A) for the most part and that
Hospital Bedroom facades will be subject to noise levels in the order of 85~92dB(A) when the aircraft
has the main rotor running on the helipad as shown above.
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5.3.5

The NCH Natural Ventilation Strategy on facades

An extract from NCH Energy Strategy Report 14_D110 Satellite Centres, July 2015 suggest that the majority of
the NCH building will be naturally ventilated where possible. It suggests in our Figure 14 below that the NCH
bedrooms will be designed to have openable window sections which will allow these rooms to be naturally
ventilated, with the exception of an extract fan in the en suite bathroom.

Figure 14: Extract from Energy Strategy Report 14_D110 Satellite Centres, July 2015

It is well recognised that naturally ventilated buildings are acoustically weaker than their mechanically ventilated
counterparts, which would be a serious concern with regard to the likely impact of inbound noise. While
naturally ventilated buildings are typically a preferred choice from a sustainability perspective, it is questionable
if a naturally ventilated building will provide adequate resistance to the inbound noise at the proposed NCH
building for both typical environmental noise as well as helicopter movements. Typical helicopter movements at
the proposed NCH helipad will include landings and takeoffs in close proximity to the NCH bedrooms.
Naturally ventilated hospital bedrooms

Figure 15: Artists impressions show large glazed windows with natural ventilation provided by large top
th
hinges window sashes (Source: Irish Independent, Wednesday 30 September 2015).

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Our predictions show that based on the AWN reported measurement the noise from the proposed Augusta
Westland AW-139 on the helipad would be in the order of 74~76dB(A) at the worst affected bedrooms.

Based on the 1997 World Health Organisation (WHO) Guidelines on Community Noise, a partially open window
will result in approximately a 15dB(A) level difference between the external facade and noise level inside the
bedroom. This methodology allows us to estimate the likely level inside a bedroom with a window which has
been left partially open for ventilation purposes. This would indicate that during a landing (Augusta Westland
AW-139) at the helipad, internal noise levels in affected NCH bedrooms will be in the order of 59~61dB(A).

Noise contour modelling shows also that helicopter noise levels outside noise sensitive hospital bedrooms
could be as high as 88~92dB(A) with larger aircraft such as the Sikorsky S92. At a level of 88~92dB(A) outside
a naturally ventilated bedroom facade, internal noise levels at the NCH bedrooms would be in the order of
73~77dB(A).

It is worth noting also that hospital bedrooms are likely to have a vinyl type of floor finish combined with minimal
furnishings, which will make the rooms slightly more reverberant than one would expect in a domestic
environment. More reverberant rooms will give rise to marginally higher noise levels inside the hospital
bedroom which may result in a still lower performance than the 15dB(A) suggested in the 1997 WHO Guidance
on Community Noise. We understand also that the NCH bedrooms will include large windows and it is accepted
that facades with larger windows perform lower acoustically than typical arrangements where the window area
is small relative to say a masonry facade. It is worth noting also that large glazed panels, as is proposed on the
facade of the NCH, could well be subject to panel resonance effects due to the proximity of their natural
frequencies to that of the helicopters main rotor blade passing frequency, which should also be considered in
the assessment process. This has also not been undertaken by the applicants.

The 1997 WHO Guidance on Community Noise also discusses noise values to limit noise which would disturb
or interfere with restful sleep as well as recommended levels in other areas within a property. These guidelines
indicate that the noise level inside a living room, due to external sources, should not exceed 35 dB(A) during
the daytime/evening to prevent moderate annoyance, and 30 dB(A) at night-time to prevent sleep disturbance.
It should be noted that these standards are based principally on relatively steady, broadband noise such as that
from traffic, machinery, plant etc. The guidance indicates that When the noise is composed of a large
proportion of low-frequency sounds a still lower guideline value is recommended. The guidance also
indicates that short term impulsive noise will disturb sleep and that it is important to limit the number of noise
events with a LAmax exceeding 45 dB

It should be noted that noise from the proposed helicopter activities at the NCH will give rise to noise levels,
inside noise sensitive bedrooms, that will be some 25dB(A) higher than would be described as the level that
would prevent moderate annoyance in a living room. As a general rule of thumb, a level difference of 20dB(A)
equates to a quadrupling of perceived loudness.
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With regard to the night period, the noise level from any helicopter using the helipad would greatly exceed an
LAFmax of 45 without exception inside naturally ventilated hospital bedrooms, which is a level that the World
Health Organisation in their 1997 Guidelines for Community Noise say should be avoided at night to avoid
sleep disturbance. It is also worth noting that the 30dB(A) guidance value suggested by WHO at night, would be
exceeded by 40dB(A) during larger helicopter (Sikorsky S92) activity within the vicinity of the hospital bedrooms
on the south eastern and south western end of the residential block on Level 4, Level 5 and Level 6.

5.4

Specialist services Health Technical Memorandum 08-01: Acoustics(2008)

The UK Department of Health issued specific guidance which prescribes appropriate noise levels relating to
hospitals. The guidance provides different criteria for sleeping during the daytime and night time periods and
does acknowledge that the criterion is not in full compliance with WHO recommendations. The document does
provide very clear guidance on sporadic events, such as helicopter movements. The guidance in relation to
'Sporadic Events' is as follows:

2.15 Hospitals are often affected by noisy but sporadic events such as vehicle sirens,
helicopters and aircraft. Each source has to be considered separately and an appropriate
strategy devised.

2.16 A policy of no sirens on site (unless essential) is recommended.

2.17 It is unlikely that the criteria in Table 1(Table 1 in HTM-8) will be achievable with helicopter
movements included, so helicopters may cause some disturbance. Careful planning of the
hospital layout and flight path can, however, reduce the effects of helicopter noise.

Having reviewed the AWN Consulting chapter on the potential impact of helicopter noise on the proposed NCH
building or indeed the existing St Jamess hospital facility, it is clear that no careful planning has been devised
in relation to the proposed helipad.

To locate a helipad in such close proximity to a naturally ventilated hospital bedrooms is in fact a clear
demonstration that the helipad and the buildings natural ventilation strategy of the NCH are at cross purposes.

It would appear the AWN Consulting report references many international reports, some of which suggest that
the medical helicopter services are time-critical and provide a noise-excusable public service. We would
strongly disagree with this and that it is clear that patients of the proposed NCH hospital, the existing St
Jamess hospital and residents have not been adequately considered, which in our view is a very serious
omission in the noise assessment submitted with the planning application.

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5.4.1

Irish Aviation Authorities Guidelines the location of Helipads

Having examined the projects noise consultants chapter on the impacts of noise from the proposed Helipad, we
note that the authors suggest that "there are no Irish guidelines for the assessment of helicopter noise impacts".

While we are of the view that there may not be Irish guidelines for the assessment of noise impact, the Irish
Aviation Authority do provide very clear guidance on the design and placement of helipads in the interests of
protecting residential amenity of which noise and vibration can be considered a very important component. We
could not find any reference to this guidance in the EIS, which specifically refers to the siting and location of
helipads. In our view AWN Consulting have gone to great lengths to identify studies which suggest that
'helicopter noise should not be considered and that it should be noise excusable' or that 'the activity is so
infrequent that the impact of noise need not be considered'. The studies presented by AWN Consulting in
support of this have been referenced below and we have provided further comments on our interpretation of the
studies.

Study 1: A New Zealand Standard (NZS 6807:1994) where is it simply stated that their standard 'is not
intended to apply to infrequently used helicopter landing areas or emergency operations'.

This in our view is no justification or a reason to ignore the likely operational impact of such aircraft. It is also
our view that AWN Consultants are not in a position to make comment on the likely future traffic associated with
the proposed St James's Helipad. In our view 4 landings/departures per week does seem very conservative and
something which could seriously underestimate likely usage. The volume of helicopter activity does appear to
be very moderate for a helipad which is intended to service the existing St Jamess Hospital as well as the
proposed national facility, when compared with current helicopter traffic at a smaller hospital such as UCHG in
Galway City.

Study 2: A reference to US Federal Aviation Authority (FAA) document 'Non-military Helicopter Urban Noise
Study, 2004, where it states 'Emergency helicopter service should be exempt from restrictions'.

This in our view relates to wider geographical areas and does not related to a single concentrated landing site
in a densely populated residential area, which is being proposed at the NCH at St James's.

Study 3: The UK Department of Health Estates and Facilities Division publication Health Building Note 15-03:
Hospital Helipads, 2008 states The occasions when ambulance helicopters cause disturbance are likely to be
irregular, few in number and short in duration. As a result, a formal noise analysis for hospital helipads is
unlikely to draw useful or objective conclusions and will be of limited assistance to planning committees.

We welcome AWN Consultings references to UK Department of Health Documents, however we do not

understand why a well known acoustics Health Technical Memorandum 08-01: Acoustics(2008) has not been

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considered in their assessment. This document specifically addresses matters pertaining helicopter noise (and
other sporadic noise events) which has been discussed above.

For clarity we have reproduced the Irish Aviation Authoritys clear guidance on the selection of suitable Helipad
locations. See Figure 16 below where we have underlined the most relevant points.

Figure 16: IAA Heliports Guidelines for Heliport Site Owners/Occupiers and for Heliport Site-keepers
In our view this Irish Aviation Authority (IAA) guidance may have been overlooked as it is not referenced in the
EIS and its guidance is detrimental to the placement of the proposed helipad in the proposed NCH site at St
James's. It clearly acknowledges that a helicopter especially when operating over a populated or congested
area, can be noisy and an irritant to persons on the ground. The IAA extend this to suggest that such
arrangements often give rise to noise disturbance/nuisance complaints from members of the public and that this
should be taken into account when planning operations.

It would appear also that the IAA are clear in their guidance that they have no responsibility for helicopter noise
and that complainants have access to the EPA Act 1992 to address noise matters. This in our view would allow
a resident to readily challenge the use of the helipad and under noise nuisance law could allow the courts to
make a ruling that helicopter operations should be restricted to open space areas within Phoenix Park with
ambulance transfers to the proposed NCH facility.

We note that in the AWN Consulting's chapter on helicopter noise, there is a final statement that does cause us
some concern. In their final comments they suggest "it is concluded that helipad activity will not be a significant
noise nuisance". In our view AWN Consulting have not demonstrated that a noise nuisance will not be caused
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by the proposed NCH helipad. In fact, if we were to analysis this statement further, it could be interpreted that
AWN Consulting are actually acknowledging that there will be a 'noise nuisance' caused by the proposed NCH
helipad, but that it will not be 'a significant noise nuisance' based on their assessment.

5.4.2

Helicopter noise impact in the AWN Consulting report.

In the section on helicopter movements, the AWN Consulting report suggests that "During the night-time the
overall noise impact will be greater due to the shorter assessment period". While this is correct in terms of the
fact that that the night period (of 8 hours) is shorter than that of a daytime period (of 16 hours), the authors have
simply neglected to mention noise sensitivity at night which is a crucial part of the assessment process. It is for
this very reason that typical limiting levels used by the EPA, as an example, are some 10dB(A) lower at night
than they are during a daytime period. We would be concerned that the authors are also attempting to average
a helicopter landing period over an 8 hour night period in an effort to suggest a lesser numerical impact. We are
at a loss to know why the authors did not prepare a noise contour map for helicopter landings at the NCH to
determine the likely impact on both hospital bedrooms and residential properties within the vicinity. In our view
this has been a very serious omission in the EIS.

We do appreciate that the AWN Consulting report does recognize and acknowledge the fact that the likely
helicopter noise in the area of the proposed NCH helipad will be easily recognisable and that it will dominate the
noise environment, however it is our view that helicopter operations have been grossly under-estimated in that
it has been based on a limited number of trips, i.e. 4 per week with the use of a single aircraft type.

Figure 17: Extract from the Chapter on Noise and Vibration in the EIS prepared by AWN Consulting.
In Figure 17 above, AWN Consulting suggest that the helipad will not be a significant nuisance, however we
note that they advise that several mitigation measures are presented in section 11.2.6 in order to minimise the
impact. When we examine Section 11.2.6 refers to three specific sub headings, which have been reduced
below:

11.2.6.1 Construction Phase (Construction related noise mitigation)

11.2.6.2 Operational Phase (Building Services & Additional Traffic on Public Roads)
11.2.6.3 Do Nothing Scenario (a scenario which requires no noise mitigation)

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When we review Section 11.2.6, we note that AWN Consulting have neglected to suggest any measures to
reduce the impact of helicopter noise and they have simply omitted this in their study, despite suggesting that
their chapter provides several mitigation measures.

5.4.3

Alternative Helicopters

It should be noted that the noise consultants predictions assume the exclusive use of the Augusta Westland
AW-139 which in our view is simply insufficient. The 3D noise contour modelling and measurement data from a
Sikorsky S92, indicate that the predicted noise levels will be some 13.5dB(A) higher than the data provided by
the Commandant Colin Roche, which has been the basis of the AWN Consultings predictions for the proposed
NCH helipad.

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6 Conclusion
Having reviewed the noise and vibration study (Chapter 11 and Appendix 11.1), submitted in support of the
National Children's Hospital application at St James's Hospital Dublin, we are forced to conclude that the
submission fails to adequately consider the likely impact on noise and vibration for the proposed development
both at the construction phase and at the operational phase. We have a number of sub conclusions below in
relation to the proposed development to explain how we have arrived at this conclusion.

6.1

Construction Noise Impact

Having reviewed details of the baseline study, the outline construction management plan, site predictions and
noise criteria used, it is our view that the authors have selectively used guidance prepared by the National
Roads Authority with limiting levels which contradict clear guidance suggested in BS5228. It would appear that
the authors, using the NRA's guidance on construction noise (for road projects), appear to be suggesting that
residents subjected to 70 dB LAeq day after day for a period of up to 3 years would find the noise environment to
be acceptable. BS5228, Paragraph E.4 is very clear on the significance of noise effect and suggests that where
the construction noise exceeds the ambient noise level by more than 10 dB and for a period of 10 days or more
in any 15 consecutive days or for a total of more than 40 days in any 6 month period, temporary re-housing
should be considered. It also suggests that buildings which are likely to be particularly sensitive to noise,
(including hospitals) will be subject to individual consideration. Having reviewed the authors baseline study,
noise levels during the construction phase will be 10dB in excess of the ambient, therefore temporary rehousing would apply if the noise consultants were to adhere to the guidance they themselves refer to in their
assessment. It is worth noting also that NRA in the guidance (Guidelines for the Treatment of Noise and
Vibration during the construction of National Road Schemes, 2004) used in the EIS suggests on page 2 that
the NRA does not accept any responsibility for loss or damage occasioned or claimed to have been
occasioned, in part or in full, as a consequence of any person acting from, or refraining from acting, as a result
of matter contained in this publication. This in our view would be a further reason to rely on more appropriate
guidance defined in British Standard BS5228, Paragraph E4.

6.2

Vibration impact during the Construction Phase.

We do not dispute the vibration threshold levels which AWN Consulting had set out in their report in relation to
vibration sensitivity within a hospital environment. This is of particular importance since it is proposed that St
Jamess will continue as a working hospital throughout the construction phase of the project. While the AWN
Consulting assessment sets out vibration thresholds that should not be exceeded, they have made no attempt
to establish if these vibration thresholds can be met at vibration sensitive locations such as theatre locations or
imaging locations where Computed Tomography (CT) scans take place. We would be very concerned however
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that the AWN Consulting assessment fails to geographically identify exact vibration sensitive locations and
establish if a construction project using the proposed methods is feasible in such close proximity to these
noise/vibration sensitive places. We would be very concerned about the reliance on a single third party
hypothesis, which we understand has been prepared by Rupert Taylor (Document Ref. CHOI/MPH/6A dated 7
February 2011). In our view their approach is very simplistic and it would not be correct to rely on a hypothesis
which was in fact developed for another site which assumes the ground to be homogeneous in nature. We
would be concerned also that there is no mention of any other possible source of vibration, such as the use of
mechanical breakers and pneumatic drills which would be used for the breaking and opening of concrete and
metalled surfaces.

We are not able to make any detailed comment on the method of vibration calculation but it would appear that a
very basic generic calculation has been used rather than one which takes account of the actual ground strata
in this location. Considering that piling will take place as close as 7.5 m from clinical areas and 10 m from
residential properties, we would have expected to see a rather more robust prediction method.

6.3

The Impacts of Helicopter Noise and activity on Hospital Bedrooms

It is evident that no attempt has been made by AWN Consulting to assess the likely impact of inbound
helicopter noise on the NCH building which has been designed to be naturally ventilated. In our view this is a
very significant omission on their part. Noise contour modelling shows that areas which house the NCH
bedrooms on Level 4, Level 5 and Level 6 are worst affected by the impacts of airborne helicopter noise during
the daytime and night period. Predicted levels show that with a naturally ventilated room, noise levels inside the
bedrooms during helicopter landing and takeoff events during the daytime and night period will be very high and
would be likely to cause distress to sick children. In our view, it would be wholly inappropriate to locate noise
sensitive hospital bedrooms in such close proximity to a helipad. We are concerned also about the use of third
party basic data measured at 3m from one Augusta Westland AW139 at Baldonnel Airfield which actually under
represents the time associated with a typical hospital Medevac operation.

While the AWN report neglects to consider the likely effect of inbound noise on hospital bedrooms, we have
modelled the likely noise contribution from a Sikorsky S92 which is a larger and louder aircraft than the Augusta
Westland A139. It is likely that this aircraft will have a serious adverse impact on hospital bedrooms during the
daytime periods and will most likely give rise to sleep disturbance at night in hospital bedrooms.

6.4

The Impacts of Helicopter Noise on residential amenity

While it appears that AWN Consulting have considered the residential amenity in their noise predictions, using
16 hour and 8 hour mathematical logarithmic averaging, it is our view that the actual helicopter noise impacts
have been numerically understated. The predicted levels, averaged over these longer periods are wholly
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inadequate representations of the actual noise impact expected at the nearest residential properties. We would
also be very concerned that the AWN predictions assume that a Medevac landing and take-off consists of a
single 63 second landing and single 17 second takeoff period. Having quantified the duration of an actual Irish
Air Corps Medevac at UCHG at Galway City, we estimate that the AWN Consulting calculations have predicted
the noise impact which is underestimated in its duration by a factor 350~400%.

When we apply our time studies to a typical Irish Air Corps Medevac operation, combined with the shortening of
the evaluation period to 15 minutes for 1 landing during the daytime and 5 minutes at night, it is evident that
actual helicopter noise impact will be very significant at the residential properties.

It is worth noting also that the AWN Consulting predictions assume only one landing at night, however
operationally this is not correct. It would appear that AWN Consulting predictions envisage a scenario where a
helicopter crew would land the aircraft at the NCH hospital at night and would not depart again until the
following day. In our view operational matters have not been adequately represented and differ greatly from
what a Medevac actually entails.

We would be concerned also that the AWN report only considers one aircraft type and does not consider the
likely noise impact created by a Sikorsky S92. Measurements show the Sikorsky S92 to be a louder aircraft
which may not be restricted to daytime operations either. When we contrast the propose 4 landings/take offs
per week against those noted at a smaller hospital at UCHG in Galway City, with 7 per week and in some cases
up to 7 Medevac cases on occasion, it would appear the proposed NCH helipad usage may be significantly
under estimated.

6.5

Overall Conclusion

In the AWN Consultings Chapter on Noise and Vibration, we note that the authors suggest that their
methodology has been based on comparing their calculated levels against the adopted criteria. It is our overall
conclusion however that criteria has been adopted to suit the particular application, rather than what is best
practice criteria and assessment methods. It would appear that the authors have been very selective in the use
of assessment criteria and have not in our view adequately assessed construction or operational noise and
vibration.

The Chapter on Noise and vibration neglects to adequately assess the impact of construction noise on existing
adjacent residential properties and at the existing St James's Hospital buildings. It would appear that less
onerous limiting levels used by the NRA in Ireland for road projects are being proposed for construction noise
limiting levels. While the AWN Consulting report does reference BS5228, it neglects to cite the guidance in
relation to a long term construction project which may include the temporary re-housing of residents. It would
appear that the guidance provided in this chapter has been adopted without question into the outline

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construction management plan, which would be a concern also and could have legal implications if the
development was to proceed.

While limiting levels have been quoted with regard to vibration sensitive equipment, the authors have not
indicated exact locations for vibration sensitive hospital equipment nor have they carried out a risk assessment
in the EIS. We would be concerned also that a third party hypothesis is being quoted to determine if vibration
levels are likely to be excessive within the vicinity of vibration generating equipment. In our view this is an over
simplistic approach and it assumes that the ground is a homogeneous structure, which in fact is unlikely on any
site. Vibration transfer on any site is a function of the vibration characteristics of the source, ground conditions
(which are not stated), building foundations and building construction material at the existing St James's
buildings and residential properties. For this reason it is our view that the impact of construction vibration has
not been adequately considered.

Noise predictions relating to the helipad are flawed in our opinion with regard to best practice and guidelines.
There is a gross underestimation of the duration of an actual Medevac event, consideration of a single
helicopter aircraft (AW-139) with limited measurement data, understating of the numerical noise impact through
minimal usage averaged out over 16hour daytime and 8 hour night periods and the fact that no consideration
has been given to the likely impact of helicopter noise on naturally ventilated hospital bedrooms.

Having considered the chapter presented on noise and vibration in the EIS presented relating to the proposed
National Children's Hospital, it is our view that the impact of noise and vibration has not been adequately
considered. On the basis of our study and review contained in this report, it is our view this seriously
compromises the projects EIS. The primary purpose of an EIS is to provide an objective and impartial
discussion of significant environmental impacts, and reasonable alternatives and mitigation measures that avoid
or minimise adverse environmental impacts. Our evidence shows that this minimum requirement has not been
met in the submission presented in relation to the proposed NCH project.

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7 Terminology
Decibel (dB): The decibel is a unit of level, which denotes the ratio between two quantities that are proportional
to the power; the number of decibels corresponding to the ratio of two powers is ten times the logarithm to the
base 10 of this ratio.
dB(A): A weighted sound pressure level (S.P.L.) approximately equivalent to the human ear frequency
response to noise.
The A suffix denotes the fact that the sound levels have been A-weighted in order to account for the nonlinear frequency response of human hearing. All sound levels in this report are expressed in terms of decibels
-5

(dB) relative to 2x10 Pa.

Equivalent Continuous (A) Weighted Sound Level [ LAeq T]:

This can be regarded as a notional level, which would, in the course of the measuring period (T), cause the
same (A) weighted sound energy to be received as that due to the actual sound over the actual measuring
period.

LAFmax: It is a measure of the A-weighted maximum sound pressure level with the instrument capturing using
the Fast (F) capture rate.

Reverberation: Reverberation is created when a sound or signal is reflected causing a large number of
reflections to build up and then decay as the sound is absorbed by the surfaces of objects in the space which
could include furniture and people, and air. Rooms with less furnishing and hard acoustically reflective surfaces
can have higher reverberation levels and consequently inbound noise can be marginally higher.

APU: The primary purpose of an aircraft APU is to provide power to start the main engines. Turbine engines
must be accelerated to a high rotational speed to provide sufficient air compression for self-sustaining
operation.

Main Rotor: A helicopter main rotor is the combination of several rotary wings and a control system that
generates the aerodynamic lift force that supports the weight of the helicopter

Helipad: a landing and take-off area for helicopters.

Helicopter movement: In this context describes a helicopter landing, taking off or hovering at the proposed
NCH helipad.

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