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Our Ref: 29N.

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

Ceannt Fort Residents' Association


C/ 0 Heather Hand
77 O'Reilly Avenue, Ceannt Fort
Mount Brown
Dublin 8
31st August 2015

Re: Health Infrastructure Development comprising National Paediatric


Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Madam,

An Bard Pleanala has received your recent submission in relation to the above mentioned proposed development and will
take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed.
The Board will revert to you in due course with regard to the matter.
Please be advised that copies of all submissions I observations received in relation to the application will be made
available for public inspection at the offices of Dun Laoghaire-RathdownCounty Council and at the offices of An Bard
Pleamila when they have been processed by the Board.
If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above
mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

Encis.
PA04.LTR

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Our Ref: 29N.PA0043


P.A.Reg.Ref:
Your Ref:

Paul O'Neill
National Paediatric Hospital Development Board
CfO G.V.A. Planning & Regeneration
Floor 2, Seagrave House
19-20 Earlsfort Terrace
Dublin 2
31st August 2015

Re: Health Infrastructure Development comprising National Paediatric


Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir,
Enclosed for your information is a copy of submission(s) received by the Board in relation to the above mentioned
proposed development.
If you have any queries in relation to the matter please contact the undersigned officer of the Board.
Please quote the above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with
the Board.
Yours faithfully,

Encls.
PA08.LTR

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An Bord Pleamila

Our Ref: 29N.PA0043


P.A.Reg.Ref:
Your Ref:

Chief Executive Officer


Dublin City Council
Civic Offices
Wood Quay
Dublin 8
31st August 2015

Re: Health Infrastructure Development comprising National Paediatric


Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir/Madam,
Enclosed for your information are two copies of submission(s)received by the Board in relation to the above-mentioned
proposed development.
Please ensure that a copy of this/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 Pleanala reference number in any correspondence or telephone contact with
the Board.
Yours faithfully,

ran Somers
cutive Officer
Direct Line:Ol-8737107
Encis.
PA07.LTR

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Ceannt Fort Residents Association

C/0
Heather Iland, Secretary
77 O'Reilly Avenue,
Ceannt Fort,
Mount Brown,
Dublin 8.

27111 August 2015

The Secretary
An Bord Pleanala
64 Marlborough Street
Dublin 1

Case reference: PL29N.PA0043


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

Dear Sir or Madame


Please find attached a copy of the Ceannt Fort Resident Association observation in relation
to the proposed application.

Yours Sincerely

'~~

AN BORD PLEANALA
TIME 14: , ~ g.. BY J..t= ....1

2 7 AUG 20i5

Heather lland

AN BORD PLEANALA
Received : 2.1 l;>CZ!. I tS Fee: 6-:> (.}Nz.s,~
Recetpt No: B \ 3~ Sq b

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NCH PLANNING APPEAL Ref# PL29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August 2015

Contents
1.0

EXECUTIVE SUMMARY

2.0

INTRODUCTION

3.0

RESIDENTS PARTICIPATION

4.0

ZONING & DEVELOPMENT PLAN

5.0

SCALE HEIGHT & FORM

6 .0

TRAFFIC & ACCESS TO SITE

11

7.0

CARPARKING

11

8.0

HELICOPTER LANDING PAD

12

9.0

CONSTRUCTION IMPACT

12

10.0

IMPACT ON RESIDENTIAL AMENTITIES

12

11 .0

SITE EXPANSION

13

12.0

FUTURE SITE MASTER PLAN

14

13.0

PROPOSED OPEN SPACES

14

14.0

DOLPHINS REPORT & ALTERNATE SITES

14

15.0

COMMUNITY GAINS

15

16.0

CONCLUSION

15

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NCH PLANNING APPEAL Ref# Pl29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August2015

Case reference: PL29N.PA0043

Health Infrastructure Development comprising National Paediatric


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

EXECUTIVE SUMMARY
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 scheme and telling the general
public and An Board Pleanala that the scheme is only 7 stories high (with a 3 storey
basement) and publishing same on their Web site. The submitted Planning
documentation refers to a 7 storey building at its highest in the Environmental Impact
Statement {EIS). Even Minister Leo Varadkar's own web page and his public launch
along with many interviews all refer to the New Children's Hospital as a 7 Storey
Building.
Because the general public and neighbours read this they have been directed to
deliberate untruth. Thus all notification for this hospital including press statements and
Ministers statements are fatally flawed and contrary to the provisions of the planning
statue and regulations.

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


truthful information regarding the height of the facility and that all publications
material be withdrawn, corrected including Ministers 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?"

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NCH PLANNING APPEAL Ref# PL29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August 2015

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.

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SKETCH2

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Ceannt Fort Residents Association
Rev A 26 August 2015

1.1

2.3

Extract from the Pre Planning Consultation with An Board Pleanala:


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

The proposed development now comprises:

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


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,

An Bord Pleamila

PL 29N.PC0158

See Attachment No. 1: Copy Attached


1.2

Extract from EIS Chapter 2: Description of the Development

2.4.1 New Children's Hospital Building

The building \'~R vary in height from Ulree storeys along its western side bordering the South Circular Road,
to seven storeys in the centre or tile site v.illl the overall he ght or the building to ridge level of the roof
structure s up to 34 95m (Ordnance Datum 55 95) and up to 37 95m to the top of the fiues on the roof
(Ordnance Datum 58 95m) above areVIsed ground !eve or Ordnance Datum 21m at the proposed entrances
The proposed storey heights are as ronm.'S
1.3

219

Extract from the New Children's Hospital Web Site


http://www.newchildrenshospital.ie/
Concept design for the new children's hospital is unveiled:
Key Facts about the building

7 storeys at Its h1grest po r~t w th tne ma,or t: of tl1e bu1 dwg Slitinq at our store;s
42 beds 1n ,. ucal cae .mt
13 neonatal nt~c.al Ce~re urYt~
80 51ngte ., patlent rooms

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Ceannt Fort Residents Association


Rev A 26 August 2015

1.4

Extract from the Public Site notice:

"The proposed building wUI 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.

1.5

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


Herald dated 11 August 2014
"The most devastating blow to the bid to amalgamate Ireland's three children's
hospitals on one campus was when a planning application for the Mater hospital site
was rejected in 2012.
Mr Varadkar said that lessons had been learned from that process.
"It's a much bigger site- it's nearly three times the size of the Mater site. It doesn't go
any higher than seven stories," he said.

1.6

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

1.7

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

Ireland is one step closer to having a new


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

I .

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lOAug 2015

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Ceannt Fort Residents Association


Rev A 26 August 2015

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

2.0

INTRODUCTION
The Residents of Ceannt Fort (Zone Z2 Conservation area) would like to state that
they are in favour of a project which will bring 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. There are huge schedule and cost impacts associated
with the proposed enabling works as 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.
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 Or. 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 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.
Ceannt Fort is a100 year old housing estate (first sod turned in 1914) 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 where fighting occurred
at both the current Rialto Gates and the proposed CRIC 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 Estate will be heavily involved.
Funding has been secured by the Ceannt Fort Communit for the celebration of the
AN BORD PLE;NALA
1916/2016 centenary anniversary.
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NCH PLANNING APPEAL Ref# PL29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August 2015

Ceannt Fort is zoned Z2 under the current Dublin City Development Plan 2011-2017
which states "To protect and/or improve the amenities of residential conservation
areas" We are of the opinion that the proposed development does NOTHING to
achieve this.

3.0

RESIDENTS PARTICIPATION
Our first contact from the NPHDB about the New Children's Hospital was a
pamphlet put thru 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 Hardiman and other members of
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).
At the F2, the residents asked for a dedicated meeting with the NPHDB for O'Reilly
avenue residents to specifically focus on their rear garden subsidence and drainage
concerns as there was a history from previous developments on the St James
Hospital Site. A survey of their properties was arranged by the NPHDB and a subcontractor ABL Chartered Surveyors did start an engineering and photo survey of
their properties. To facilitate attendance of all concerned, not just O'Reilly Avenue,
as subsidence and collapsed drains, concerned all residents immediatly beside the
development, the meeting was agreed for Wednesday 29th July @ 7pm at the
NPHDB office with residents from around Ceannt Fort and Brookfield Road.
ABL Chartered Surveyors, Seamus Mulligan 087 3506409) was contacted directly
for a copy of the survey and he said he couldn't provide a copy of the condition
survey, although he had passed on the survey to the consulting engineers for the
project (0 Connor Sutton Cronin). We believe this is a serious breach of data
protection, as we had not given permission to pass on the survey to a third party. To
date they still have not been released.
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
here 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 all the consultations
with the public as they were in fact just a PR exerJi!"e. ~:::-""-----

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Ceannt Fort Residents Association


Rev A 26 August 2015

4.0

ZONING & DEVELOPMENT PLAN

Ceannt Fort site is zoned Z2 under the current Dublin City Development Plan 2011 2017 which states "To protect and/or improve the amenities of residential
conservation areas"

St. James Hospital site is Zoned Z15 under the current Dublin City Development Plan
2011-2017 which states "To protect for institutional, educational, recreational,
community, green infrastructure & health uses. n
Chapter 3 of the EIS Section 3.5.1 .2 states: In relation to Z2 zoned lands it is the
policy of Dublin City Council to , ...protect the special character of the city's
conservation areas through the application of the policies, standards and guiding
principles on building heights", and to protect and conserve the special interest and
character of Architectural Conservation Areas and Conservation Areas in the
development management process. The Dublin City Development Plan notes that it is

important to avoid abrupt transitions in scale and use zones. In order to protect the
amenities of residential properties the Dublin City Development Plan advises that ,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.

If this is the case how does an existing view of O'Reilly Avenue change to this?

O'Reilly Avenue Before

O'Reilly Avenue After

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 maximum allowable site coverage for St. James Hospital site under the current
Dublin City Development Plan 2011-2017 is 50%
The Open Space requirements for St. James Hospital site under the current Dublin
City Development Plan 2011-2017 is 25% open space r-~-----

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Ceannt Fort Residents Association


Rev A 26 August 2015

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 St James Hospital.
When Phase 2 gets constructed the open space of the Meadow Garden will
disappear.
The current maximum allowable height for St. James Hospital site under the current
Dublin City Development Plan 2011-2017 is 7 stories /28M 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 3meters to the height.

5.0

SCALE HEIGHT & FORM


5.1 New Children's Hospital (NCH)
This Development will have a significant impact on the quality of life to the
residents of Ceannt Fort, especially those living on O'Reilly Avenue. It also has a
negative impact on the residents of SCR, Brookfield Road, Cameron Square,
Faulkner Terrace, StJohn Terrace, Old mount Brown and StJames 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 looks 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 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 location of the proposed expansion sites over
the meadow garden and the A&E drop off area was never discussed. 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 as point of a joint residents group.
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Ceannt Fort Residents Association
Rev A 26 August 2015

5.2 New Research Centre (CRIC)


This development is to be located to the rear of the houses on McDowell Avenue
in Ceannt Fort. No consideration appears to have been given to the design which
shoehorns these oversized buildings into this ancient and historical site. We are
incensed to see that in the Archology report there is no reference to the part
these buildings played in the 1916 rising (as occupied by Eammon Ceannt) and
that no consideration was made to incorporate part of the existing fa<;ade fronting
James Street in to the proposed design.
No consultation with the Residents prior to lodging the application took place as
the first time the drawings were ever revealed publicly was on Thursday 6th
August 2015 prior to lodging the application the following Monday 1oth August
2015.
Section 3. 1 of the Design Report states
"The design of the building has been developed in response to the site
context, the proposed integration with the surrounding buildings and the
requirements of the brief'
This is absolutely NOT the case when you look at the scale and adjacency of the
domestic houses that this development over shadows. The proposed
development is only located 1.89m from the existing boundary wall and less than
5m from the gable wall to house no. 1 McDowell Avenue. Apart from complete
loss of privacy, as windows on 31evels overlook the properties, there is also the
issue of loss of light due the massing and scale of the proposed building. The
proposal shows that the gas cylinders, waste tanks, labs waste etc is all to be
located between the new buildings and the existing houses. This is not
acceptable due to the risk of explosions and the additional noise that will be
generated due to waste I gas delivery & collection.
The proposed new pedestrian access off James Street is also 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 a 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 shall be further addressed as part of a future joint
Residents observation submission.
5.3 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.
These issues shall be addressed as part of a future joint Residents observation
submission.
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5.4 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 in the process?
5.5 Connolly Hospital Satellite Unit
We would propose that the function, scale and size of the Satellite unit is more
appropriate to the current NCH site at StJames Hospital as per our comments
above.

5.6 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.
These concerns shall be addressed as part of a future joint residents observation
submission.

6.0

TRAFFIC & ACCESS TO SITE


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 in Kilmainham .
The cumulative impact of other large developments in the area has not been
considered in relation to traffic such as Diagio and other major developments in the
area.
These and other issues shall be further addressed as part of a future joint
Residents observation submission.

7.0

CARPARKING
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 St James 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 hospital staff and visitors 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.
Of great concern to us also is the proposed new entrance from Mount Brown to the
proposed Basement Carpark as the roads are busy at the best of times along here
1Ntl I oat of tt reP.ropgsed-~
and won't be able to take the additional cars waiting to
1 1:30RD PtEANALA
new entrance.
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NCH PLANNING APPEAL Ref# PL29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August 2015

8.0

HELICOPTER LANDING PAD


We have a genuine concern in relation to the proposed location of the new
Helicopter Pad and its proximity to the adjacent residential units because of the
noise. 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
front of the Children's wards and adjacent to the overhead wires for the Luas below.
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.

9.0

CONSTRUCTION IMPACT
These and other issues shall be further addressed as part of a future joint
Residents observation submission.

10.0

IMPACT ON RESIDENTIAL AMENTITIES


10.1 Day light
The proposed new buildings on the St James 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 study was done for the houses at McDowell Avenue which will be in shade
due to the proposed CRIC building.

10.2

Settlement & Damage to housing


Commitments to some local residents in relation to structural surveys have not
been kept. See Section 3 above. These and other issues shall be further
addressed as part of a future joint Residents observation submission.

10.3

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?

10.4

Light pollution
The proposed scheme involves lighting up the site like a Christmas tree.
The new hospitable 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 lnf'9~-gt5~~~~~~~ALA

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NCH PLANNING APPEAL Ref# PL29N.PA0043


Ceannt Fort Residents Association
Rev A 26 August 2015

LED, dimmable with colour change capability. Reference drawing no. NPH-EARUP-DR-XX-ST-1002 for details.
Lighting is proposed along the new road which runs behind the rear of houses
at O'Reilly Avenue. These consist of Type A along road- both sides 6m pole
top luminaire LED, 100% DLOR, dimmable
Reference Drawing no. NPH-E-ARUP-DR-XX-ST-1001 . these will shine 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 lumina ire LED, 100% DLOR, dimmable. These will shine into the
rear of the adjoin dwellings on McDowell Avenue.
Ref Drawing no. CRIV NPH-E-ARUP-DR-XX-RB-1 001.

11.0

10.5

Traffic
See Section 6.0 above
There is currently no Taxi Rank in St James Hospital as this was removed
about 5 years ago.

10.6

Vermin invasion
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 rats 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.

SITE EXPANSION
The proposed site expansion of min 20% will severely impact the current building
design both functionally and visually as the current design does not lend its self to
expansion. But worse than that will be the detrimental impact it will have on the
adjoining houses and the residents quality of life. as basically the site capacity is too
small. There would be serious constructability issues too for both the patients in the
NCH 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 ONLY access to the new proposed FM (Facility
Management) centre located 3 stories underground at the lowest basement level.
This FM facility serves the entire StJames 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.
These and other issues shall be further addressed as part of a future joint Residents
observation submission.

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NCH PLANNING APPEAL Ref# PL29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August 2015

12.0

FUTURE SITE MASTER PLAN


These and other issues shall be further addressed as part of a future joint Residents
observation submission.

13.0

PROPOSED OPEN SPACES


These and other issues shall be further addressed as part of a future joint Residents
observation submission.

14.0

DOLPHINS REPORT & ALTERNATE SITES


A review and comments on the Dolphins report will be subject of an additional joint
Residents Association application. However 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 StJames 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 to moderate risk by incorporating the site
proposed for the new Maternity Hospital at the time which completely blows away
the concept of co~location

The site plan on which the Dolphin report for St James was based on. Site A was to contain
both the NCH & the Maternity Hospital. Site B as available for future expansion.

Mlllmlty
Ho'!lltal

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NCH PLANNING APPEAL Ref# PL29N.PA0043

Ceannt Fort Residents Association


Rev A 26 August 2015

15.0

COMMUNITY GAINS
Appendix 5:1 "Harnessing 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?

16.0

CONCLUSION
As per our Executive 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 that all publications material be withdrawn, corrected. We believe that the scale
of the proposed St James site (NCH, CERIC & FAU) constitute over development of
the site.

The Relevant fee of 50 is enclosed.

Yours Sincerely

Heather lland

Secretary
Ceannt Fort Residents Association
77 Ceannt Fort, Mount Brown, Dublin 8
Encl:

Attachments
Fee

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PL ZI'J- FA CO 4.5

An Bord Pleanala

Inspector's Report
Proposed Development
Construction of a Proposed Integrated National Paediatric Hospital Project,
Dublin.

Prospective Applicant:

National Paediatric Hospital


Development Board

Planning Authorities:

Dublin City Council


South Dublin County Council
Fingal County Council

Nature of Development:

Health Infrastructure

Inspector:

Kevin Moore

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1.0

PRE-APPLICATION CONSULTATION

1.1

A request to enter into pre-application consultations in relation to the


proposed National Paediatric Hospital development was received by the
Board on 22"d May, 2013 in accordance with section 378 of the Planning
and Development Act, 2000, as amended by the Planning and
Development (Strategic Infrastructure) Act 2006. The Board's
representatives met with the prospective applicant on the following dates:
20th June, 2013
ath May, 2014
30th October, 2014
171h November, 2014
ah April, 2015
23ro June, 2015
sth July, 2015

1.2

The Board's representatives had a further meeting on ath December, 2014


with representatives of Dublin City Council.

1.3

The essential question put to the Board is whether the proposed


development would or would not be considered strategic infrastructure
within the meaning of section 37A of the Act.

2.0

THE PROPOSED DEVELOPMENT

2.1

The original proposed development submitted to the Board for preapplication consultations on 22"d May 2013 comprised the construction of
a 384-bed inpatient and 54-bed daycare National Paediatric Hospital at St.
James's Hospital, James Street, Dublin 8. This development was the
subject of discussion at the first pre-application consultation meeting on
20tn June, 2013. At a second meeting on 8th May 2014 the prospective
applicant made a submission which referred to the development as
comprising the construction of a 384-bed inpatient and 85-bed daycare
hospital with two satellite centres- an increase in the number of daycare
beds and the provision of two remote centres at T allaght and
Blanchardstown Hospitals providing emergency care units, each dealing
with approximately 20% of emergency cases within the Greater Dublin

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Area. Further to this meeting, the prospective applicant sent a letter to the
Board which was received on 301h May 2014. Therein reference was made
to an Outline Construction Management Plan and to consideration of the
use of a largely vacant HSE site on Davitt Road, lnchicore as a main
contractor's temporary compound associated with the proposed
development. At a further meeting on 81h April, 2015, the prospective
applicant referred to the inclusion of a family accommodation unit as part
of the proposed development. At the meeting of 23ro June, 2015, the
prospective applicant introduced a research and innovation centre as part
of the overall project.
2.2

It is noted that the prospective applicant, in the letter received on 30th May
2014, sought the Board's agreement that the composite project at that
time of the new children's hospital and the two satellite centres constitute
strategic infrastructure development and can be handled as a single
planning application and with a single Environmental Impact Statement. It
was further requested if guidance could be given on whether it is
appropriate to include the planning for the contractor's compound with the
application for the children's hospital and satellite centres or whether it
should be submitted in isolation to Dublin City Council's Planning
Department. The Board, by letter issued on 241h June, 2014, stated that it
considered it would be appropriate for the proposed satellite centres to be
treated as integral elements of the project for the purposes of any formal
planning application and that, in respect of the proposed temporary
construction compound, there would be no objection to its inclusion in the
planning application.

2.3

The proposed development now comprises:

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


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,

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


Dublin 24, comprising approximately 4,500 square metres gross floor
area and forming a 3~storey extension to the existing 4~storey building,

A Children's Research and Innovation Centre, comprising


approximately 3,000 square metres gross floor area and 4~storeys in
height, at St. James's Hospital campus, Dublin 8, adjoining the existing
Trinity Centre for Health Sciences and with frontage onto James's
Street,

A 52 bed Family Accommodation Unit at St. James's Hospital campus,


Dublin 8, comprising approximately 4,400 square metres gross floor
area adjoining the proposed new hospital and forming a 3~storey I part
4-storey structure, and

A temporary Construction Compound, Davitt Road, lnchicore, Dublin 8,


constituting approximately 0.8 hectares of an 8.0 hectare plot.

2.4

The new Children's Hospital is proposed to provide tertiary and quaternary


care on a national basis, and in some specialities on an all-island basis. It
is proposed that it would provide in~patient care and all surgery. The
satellite centres are proposed to provide secondary care, namely urgent
care (41%) and outpatient care (14%), for the Greater Dublin Area. The
new Children's Hospital is proposed to link with local and regional
paediatric centres via an integrated national clinical network.

2.5

The proposed Children's Research and Innovation Centre would be co~


located with existing academic facilities on the St. James's Hospital
campus.

2.6

The Family Accommodation Unit would be located adjacent the new


Children's Hospital and would provide essential facilities for parents and
siblings of sick children with extended hospital stays.

2.7

The temporary Construction Compound would be located on HSE lands


approximately 1.6km south~west of St. James's Hospital campus and
would be used as a staging and storage area for building construction
materials.

2.8

There would be approximately 1,000 car parking spaces to serve the new
Children's Hospital. It is intended that 675 of these would be for visitors,

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with the remaining 325 for staff members. Up to 400 cycle parking spaces
are proposed. In addition to the established vehicular entrances at
James's Street and South Circular Road at the St. James's Hospital
campus, a new entrance would be added at Mount Brown.

2.9

Regarding consideration of the composite project of the above referenced


components, I acknowledge firstly the Board's previous acceptance of the
National Children's Hospital, the satellite centres being integral elements
of the project, and the inclusion of the construction compound in any
forthcoming application. I also acknowledge the new elements of the
project since that determination, namely the research and innovation
centre and family accommodation unit. I submit that the functions of these
elements demonstrate they are integral to the overall project. Furthermore,
I note the proposed siting of the relevant structures within the St. James's
Hospital complex in the vicinity of the location for the proposed National
Children's Hospital structure. I advise that it would be appropriate for these
proposed developments to be treated as integral elements of the project
for the purposes of any formal planning application for the National
Paediatric Hospital Project.

3.0

LEGISLATIVE PROVISIONS

3.1

Strategic Infrastructure Development


Section 37A(1) of the Act states:
An application for permission for any development specified in the
Seventh Schedule shall, if the following condition is satisfied, be made to
the Board under section 37E and not to a planning authority. Section
37A(2) of the Act:
That condition is that, following consultations under section 37B, the
Board serves on the prospective applicant a notice in writing under that
section stating that, in the opinion of the Board, the proposed development

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would, if carried out, fall within one or more of the following paragraphs,
namely(a) the development would be of strategic economic or social importance
to the State or the region in which it would be situate,
(b) the development would contribute substantially to the fulfilment of any
of the objectives in the National Spatial Strategy or in any regional
planning guidelines in force in respect of the area or areas in which it
would be situate,
(c) the development would have
than one planning authority.

a significant effect on the area of more

The Seventh Schedule of the Act is amended by section 78 Planning and


Development (Amendment) Act, 201 0 to include:

Health Infrastructure
4. Development comprising or for the purposes of the following:
- A health care facility providing in-patient services, but excluding a
development which is predominantly for the purpose of providing care
services within the meaning given to that term by section 3 of the Nursing
Homes Support Scheme Act 2009.

3.2

Environmental Impact Statement


Section 37E(1) of the Act states:

An application for permission for development in respect of which a notice


has been served under section 37B(4)(a) shall be made to the Board and
shall be accompanied by an environmental impact statement in respect of
the proposed development.

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4.0

NATIONAL AND REGIONAL POLICY

4.1

There are no objectives in either the National Spatial Strategy (2002-2020)


or the Regional Planning Guidelines for the Greater Dublin Area (20102022), which relate specifically to a national children's hospital and/or its
siting at the St. James's Hospital complex.

5.0

THE QUESTION OF STRATEGIC INFRASTRUCTURE DEVELOPMENT

5.1

Section 37A(2) of the Act sets out the conditions under which Seventh
Schedule development is considered to constitute strategic infrastructure
for the purposes of the Act.

5.2

Having regard to the nature and extent of the National Children's Hospital,
the prospective applicant considers that the proposed development falls
within paragraph (a) of that section of the Act, being of strategic economic
or social importance to the State. I concur that the proposed development
would, if carried out, fall within paragraph (a) of section 37A(2) of the Act
having regard to the following:

(a)

The proposed development would be of strategic social importance


to the state and the region, providing national tertiary paediatric
care and secondary paediatric care for the Greater Dublin Area;

(b)

The proposed development would not contribute substantially to the


fulfilment of any of the objectives in the National Spatial Strategy
(2002-2020) or the Regional Planning Guidelines for the Greater
Dublin Area (2010-2022);

(c)

In acknowledging that the development would have an effect on the


area of more than one planning authority, it may not be reasonable
to determine such impact to be significant having regard to the
nature, extent and context of such applicable related developments
to the National Children's Hospital itself.

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6.0

RECOMMENDATION

6.1

Having regard to the record of the pre-application consultations between


An Bord Pleanala and the prospective applicant, I recommend that the
Board decides that:

1.

The proposed development constitutes Strategic Infrastructure


Development under the meaning of Section 37A of the Planning
and Development (Strategic Infrastructure) Act, 2006 (as
amended), as it would fall within paragraph 37A (2) (a) of the Act;
and

2.

An EIS is required to be prepared under Section 37E (1) of the


Planning and Development (Strategic Infrastructure) Act, 2006 (as
amended).

7.0

CONSIDERATIONS RELATING TO PROPER PLANNING AND


SUSTAINABLE DEVELOPMENT

7.1

I note that the Board, under section 378(3)(c) of the Principal Act, may
provide advice to prospective applicants as to what considerations, related
to proper planning and sustainable development or the environment, may,
in the opinion of the Board, have a bearing on its decision in relation to an
application. The following are regarded as relevant considerations relating
to proper planning and sustainable development in this instance which the
prospective applicant was informed of during the pre-application
consultation process:

Pl29N.PC0158

Alternative sites
Justification for the siting, scale, functioning and form of the overall
scheme in planning and environmental terms.
The constrained nature of the St. James' Hospital site and capacity
for tri-location (children's hospital, adult teaching hospital and
maternity hospital).

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The ability to accommodate the future growth I expansion of these


developments individually and cumulatively.

The developments now and into the future in the context of a new
Master Plan for St. James' Hospital complex.

Construction and demolition impacts - developing the project,


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

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


national and regional strategy relating to same.

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.

The outcome in the event of one or both Satellite Centres failing to


acquire planning permission or failing to be developed.

Traffic and transportation - routing, access, modes, car parking.

The Coombe Hospital and its developability to accommodate the


proposed future maternity hospital.

The relocation of the Rotunda Hospital to Connolly Hospital,


Blanchardstown and the ability to accommodate same in the
context of the Connolly Hospital Master Plan.

Visual and streetscape impacts on the local and wider environment.

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


impacts on adjoining residential properties.

Public consultation .

Miscellaneous- archaeology, architectural heritage, impact on


infrastructure (underground services).

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8.0

PRESCRIBED BODIES

8.1

The following is a schedule of prescribed bodies considered relevant for


the purposes of Section 37E(3)(c) of the Principal Act
(a) Minister for Arts, Heritage and the Gaeltacht
(b) Minister for Communications, Energy and Natural Resources
(c) Dublin City Council
(d) Fingal County Council
(e) South Dublin County Council
(f) National Roads Authority
(g) Irish Water
(h) An Chomhairle Ealalon
(i) Failte Ireland
0) An Taisce
(k) Heritage Council
(I) Inland Fisheries Ireland
(m) CIE
(n) Railway Procurement Agency
(o) National Transport Authority
(p) Minister for Transport
(q) Health Service Executive

Kevin Moore
Senior Planning Inspector
July, 2015

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