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APB subm,SCR Kilmainham Res.Oct 2015.pdf

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South Circular Road, Kilmainham Residents Association Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny Joe Ruane __________________________________________________________________________________________ Page 1 of 28 513 South Circular Road Kilmainham Dublin 8 01 October 2015 Re: Planning Application Reference PL29N.PA0043, Hospitals & Construction Compound at Davitt Road, Dublin Dear Sir / Madam, We write in relation to the above planning application to detail concerns that we have about the proposed development of the National Children’s Hospital on the site of St. James’ Hospital. We represent the South Circular Road, Kilmainham area – from Bulfin Road to Rialto Bridge. We would firstly like to recognise that we are fully aware that our neighbour is St. James’ Hospital and that we have always had a good working relationship with this hospital. We fully support the development of St. James’ as an institution of national importance. St. James’ has also always recognised our position as an area of Zone Z2 Residential Conservation – as can be seen by the developments on this
Transcript
  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 1 of 28

    513 South Circular Road Kilmainham

    Dublin 8

    01 October 2015

    Re: Planning Application Reference PL29N.PA0043, Hospitals & Construction

    Compound at Davitt Road, Dublin

    Dear Sir / Madam,

    We write in relation to the above planning application to detail concerns that

    we have about the proposed development of the National Childrens Hospital

    on the site of St. James Hospital. We represent the South Circular Road,

    Kilmainham area from Bulfin Road to Rialto Bridge. We would firstly like to

    recognise that we are fully aware that our neighbour is St. James Hospital and

    that we have always had a good working relationship with this hospital. We

    fully support the development of St. James as an institution of national

    importance. St. James has also always recognised our position as an area of

    Zone Z2 Residential Conservation as can be seen by the developments on this

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 2 of 28

    western boundary down the years the red brick, low rise buildings that blend

    so well into our neighbourhood.

    We support the building of the National Childrens Hospital, but not on the

    grounds of St. James. We would recommend that the initial co-location be

    with a Maternity Hospital and that if it is deemed necessary to be tri-located

    close to St James then the site behind the Coombe Womens Hospital would

    be the best location. This would still achieve the required regeneration for

    Dublin city centre in line with the Dublin Corporation Proposals. It would also

    allow for the managed expansion of St. James in a manner that is

    commensurate with the environment of our road, i.e. lower lying buildings at

    the perimeter of the site, adjacent to low-rise residential buildings.

    We object to plans as outlined by the NPHDB on the following grounds:

    Lack of adherence to Dublin City Council Guidelines

    Health and Safety for our residents

    Lack of amenity for our residents.

    We enclose 50 in payment of the prescribed fee for making a submission.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 3 of 28

    1. Elements of the design that are contrary to the Dublin City

    Development Plan.

    1.1 Size, scale and Impact on our area:

    The zone attached to our neighbourhood is Residential Neighbourhoods

    (Conservation Areas) Zone Z2. The stated objective of this zone is to protect

    and/or improve the amenities of residential conservation areas. We recognise

    that the plans relate to an area zoned Z15, however we again draw attention

    to the Dublin City Council Development Plan Section 15.10.15 which states In

    addition, development at the perimeter of the site adjacent to existing

    residential development shall have regard to the prevailing height of existing

    residential development and to standards in section 17.9 in relation to aspect,

    natural lighting, sunlight, layout and private open space.

    We contend that this development does not satisfy these guidelines as it has a

    materially adverse impact on the local area adjacent to the proposed site due

    to its size and the negative impact it brings in terms of long-term traffic

    generation and for the duration of the construction works.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 4 of 28

    1.2 Abrupt Transition with Residential Zone

    Dublin City Council Development Plan states that there shall not be an abrupt

    transition with a residential zone.

    In Section 15.9 TRANSITIONAL ZONE AREAS the plan states that the land-use

    zoning objectives and control standards show the boundaries between zones.

    While the zoning objectives and development management standards indicate

    the different uses permitted in each zone, it is important to avoid abrupt

    transitions in scale and use zones. In dealing with development proposals in

    these contiguous transitional zone areas, it is necessary to avoid developments

    which would be detrimental to the amenities of the more environmentally

    sensitive zone. For instance, in zones abutting residential areas or abutting

    residential development within predominately mixed-use zones, particular

    attention must be paid to the use, scale, density and design of development

    proposals and to landscaping and screening proposals in order to protect the

    amenities of residential properties.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 5 of 28

    We consider that this development, right to the western border of the St.

    James Hospital site does not take this into consideration. The fact that

    existing trees, which were identified as aiding the transition between the much

    smaller proposed private hospital allowed for in 2010, are no longer

    accommodated in the plans means, that this criterion is not being met by this

    development. It is worth noting that the development in 2009 was set back

    12.5m from the site boundary, and that the higher levels were back another

    28m from the boundary.

    1.3 Height of the development in excess of Dublin City Development Plans

    St. Jamess Hospital campus is within the Inner City area, as shown on Map K of

    the Dublin City Development Plan. In this regard Section 17.6.2 of the

    Development Plan 'Definition of a High Building provides a definition of height

    for such areas as below 19m residential / 28m office.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 6 of 28

    The maximum height of the main body of this hospital is 34.95m. This is well in

    excess of the Dublin City Development Plan guidelines for our area and is

    another reason why this proposed development is not appropriate.

    1.4 Lack of sympathy with the local Redbrick Zone Z2 and Z1 residential

    areas.

    There is no attempt to harmonise the proposed building with the residential

    vernacular architecture.

    Par.17.1.1 of the City Development Plan states: "Dublin City Council will ensure

    that all new developments enrich the urban qualities of the city which means

    encouraging a distinctive response which complements the setting. A high

    standard of design is considered essential to this process, as well as the

    fostering of long term socially and economically viable communities. Creating a

    distinctive sense of place taking into account site history and setting is

    important. The analysis of any proposal shall assess the visual characteristics of

    the building form(s) and related elements, such as: aspect and orientation;

    proportion; the balance of solid to void; the shapes and details of roofs,

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 7 of 28

    chimneys, windows and doors and the materials used. Details of walls, gates,

    street furniture, paving and planting will also be noted. Roof forms should

    harmonise with and not clash with the citys traditional pitched roof forms."

    Policy SC30 of the City Development Plan states "To promote understanding of

    the city's historical architectural character to facilitate new development which

    is in harmony with the city's historical spaces and structures."

    Par.4.4.9.1 of the City Development Plan sets out the principle challenges in

    relation to architecture in the city and states: 'Encourage architecture which

    recognises and harmonises with the successful neighbourhoods, local character

    and the remaining historic fabric of the city."

    We contend that this building does not meet any of the above criteria and that

    it does not attempt to harmonise with our successful neighbourhood and with

    this historic Museum Quarter of Dublin City.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 8 of 28

    1.5 Finish on the building as proposed.

    Our road is zoned Z2, Residential Neighbourhoods (Conservation Area). The

    houses in the vicinity were built in the late 19th and early 20th Century. The

    houses are all Red Brick with wrought iron fencing. The proposed finish of the

    National Childrens hospital (the material proposed is stone with the favourite

    in terms of colour and grain being a mottled grey granite) is in stark contrast to

    that of the contiguous residential area.

    To date, St James Hospital has demonstrated cognisance and sympathy to its

    location close to a residential area. All the existing buildings on this western

    boundary, and the existing buildings on the Northern Boundary which are to

    be demolished, are finished in red brick to blend in with this existing historic

    area. Thus the proposed finish for the NCH suggest an architectural break in its

    relationship with the vernacular architecture.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 9 of 28

    1.6 Scale of the development on the city scape

    The scale and elevated skyline of the proposed building breaks with the Dublin

    City Development Plan.

    Chapter 17, Section 5 states that Dublin City Council acknowledges the

    intrinsic quality of Dublin as a low-rise city and it is policy that it should

    predominantly remain so.

    It goes on to state It is the policy of Dublin City Council to continue to protect

    and enhance the skyline of the inner city and to ensure that any proposals for

    high buildings make a positive contribution to the urban character of the city,

    and create opportunities for place-making identity in the outer city.

    We consider that the proposed National Childrens Hospital, on the St. Jamess

    Hospital site does not satisfy the above criteria as the scale and mass of the

    building result in a very imposing site on the skyline due to the naturally

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 10 of 28

    elevated nature of the site in the context of the city as a whole in general, but

    in particular in regard to the undulating nature of the contiguous residential

    areas.

    2. Health and Safety for us as a community.

    2.1 Duration of the Construction envisaged in this plan.

    This planning application is requesting permission, for a period of up to 10

    years, for the provision of a construction compound of 0.80 ha. on a 1.29 ha.

    site at the former Unilever Site at Davitt Road, Drimnagh, Dublin 12.

    This is to facilitate the construction of the National Paediatric Hospital

    development at St. Jamess Hospital campus in order to accommodate a dry

    storage and staging area during the construction phase.

    The NCHDB envisage movement of construction materials between St. Jamess

    Hospital and the Davitt Road compound for this duration.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 11 of 28

    We would like to object to the 10 year duration of this planning application as

    it will cause extensive disruption to this neighbourhood for an excessively

    extended period of time.

    2.2 Level of Construction Traffic through South Circular Road

    Should this development be allowed, construction traffic will have a significant

    negative impact on the residents of the area given the size of the excavation

    required.

    413,000 cubic metres (equal to 826,000 tonnes) of soil and made materials,

    together with an estimated 1,250 cubic metres of rock and 13,115 tonnes of

    other material will have to be transported from the site. In addition, a huge

    quantity of construction materials will have to be moved onto the site.

    Page 26 of the non-technical summary states that there will be a maximum of

    150 daily heavy goods vehicle (HGV) loads likely to be generated. However, the

    Engineering Report shows in Figure 13, Page 30, that for at least 12 months,

    there will be well in excess of 150 HGV/LGV average movements a day with 4

    of those months having over 200 lorry movements a day.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 12 of 28

    Again, the tables in the Traffic report refer to various levels of lorry movement

    during the 3 phases of construction. These are summarised in table 1 below.

    However, the tables do not contain information concerning the 20 30 lorries

    that will be required on a daily basis to remove the demolition materials as

    part of Phase 1. This will produce up to an extra 60 lorry movements per day.

    The impact of this traffic will be particularly difficult at the junctions of

    SCR/Bulfin Road/Suir Road and SCR/Mount Browne/ Emmet Road. In Section

    6.1.5 it states that the majority of heavy goods vehicles will have to use the

    SCR exit and thence the SCR/Suir Road/Bulfin Road junction to progress their

    journeys out of the neighbourhood.

    Table 1: Lorry Movements on / off proposed NCH at St. Jamess site

    Source: EIS

    The level of lorry movement on the South Circular Road is totally unacceptable

    with a lorry on the road every 90 seconds for over 3 years and with an

    approximate half a million lorry movements on the road for the planned

    duration of this work.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 13 of 28

    We consider that this is totally inappropriate for a residential area. In the Non-

    Technical Study, the NPHDB state Based on the modelling results, the impact

    of the developments in terms of ambient levels of PM10 and PM2.5 is

    considered imperceptible.

    We request that details of this model be reviewed by an independent body

    based on the numbers provided together with perhaps a 10% increase as a

    contingency to determine the real impact on this road. This needs to take into

    consideration the level of stationary time on the road while waiting for

    clearance through the junction.

    Furthermore, there are at least 18 months of excavation included in this plan.

    This is due to the fact that the building is too large for the site in question and

    has to go down 3 storeys to allow for the building of carparks and plant rooms,

    together with attenuation tanks.

    Even at this level of excavation, the main building is still significantly higher

    than what is allowed for this area under the Dublin City Development Plan.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 14 of 28

    2.3 Level of traffic that will be generated by the National Childrens Hospital,

    together with the planned growth of St. James Hospital (as outlined)

    There are fundamental errors in the methodology used to assess traffic levels.

    Significant assumptions are made in the Environmental Impact Study on Traffic

    regarding the existing volume of traffic and the projections.

    In the EIS (Chapter 6, p. 21), the study states that 108,247 vehicles were

    recorded daily in October 2014, May 2014 107,499 vehicles daily and May

    2015 107,975 daily, so the average of the three counts is 107,907 daily

    (rounded 108,000 daily). Over 12 hours the hourly rate is 9,000 cars per hour

    (see table 6.3, p. 21, E I S). This table refers to all junctions connecting to the

    South Circular Road, i.e., Mount Brown, Rialto, Suir Rd, Con Colbert Rd, and

    Kilmainham Lane.

    In chapter 6 of the EIS (p. 132), the applicants state that the projected increase

    in traffic during the morning peak period is relatively moderate due to the

    reduction in staff parking within St Jamess Hospital Campus. They also state

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 15 of 28

    that during the off-peak period the increase in traffic is expected to be

    between 300 to 400 vehicles per hour (two-way) (see table 6.58, p. 132). Over

    6 hours (9.30-3.30), this is a total of 1,800-2,400 car journeys.

    This projected additional traffic, plus the normal city traffic, will increase the

    daily hourly traffic turning onto the South Circular at the Suir Rd. junction to

    travel to the Brookfield Rd/ South Circular Rd junction (NCH entrance at

    Brookfield Rd) into the equivalent of a 10-12 hour rush hour.

    Further, there will also be 237 accident and Emergency cases per day going to

    the Childrens Hospital (122,438 A&E cases per year of which 72,238, 59% will

    be treated at St James Campus) (see p. 92, ch. 6, EIS). From a traffic

    perspective these patients can arrive at any time of day or night, thus not

    predictable methodologically.

    No consideration has been taken in regard to natural demographic growth,

    increased traffic due to the economic upturn and increased numbers at work,

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 16 of 28

    not to mention the proposed maternity hospital and the proposed increase for

    the Jamess hospital site, as set out in master plan.

    The total number of patients attending St. Jamess hospital is 400,000 annually

    (annual report). The projected figure for the New Childrens Hospital is 368,438

    annually. Total figures for both hospitals will be 768,438 annually, almost

    double the current numbers all moving within a confined space.

    These figures exclude visitors to both hospitals and do not include the Planned

    Maternity Hospital and the significant increase in patient treatment proposed

    as a result of St. James Hospital expansion as set out in the Master Plan for St.

    Jamess Hospital.

    We request that the traffic module be re-checked by independent traffic

    engineering professionals. We also request that a member of Dublin City

    Council traffic section attend the oral hearing. We require an explanation as to

    how the road infrastructure in the area can manage the increased traffic.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 17 of 28

    These calculations must now take into account the announcement on 22

    September 2015 that there will be no Dart Underground solution, and, per

    Dublin City Councils own forecast, traffic will increase of 10% between 2020

    and 2030 in Dublin City.

    We would also request that any traffic analysis needs to be stress tested to

    ensure that we do not allow a situation to arise where two of the most

    important hospitals in the country are developed in an area that cannot sustain

    potential traffic growth. We do not want to watch over a situation where the

    lives of sick people both adults and children are put at risk due to

    inappropriate traffic analysis at the outset.

    The proposed New Childrens Hospital will increase traffic congestion on all

    roads and junctions that connect to the South Circular Road, and will have a

    negative impact on the residents of this area due to increased pollution caused

    by both the increase in volume and the level of traffic congestion in the area.

    2.4 Way Finding Signs

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 18 of 28

    The Way Finding signs for the New Childrens Hospital are a good idea.

    Nonetheless, there are some implications that have hitherto not been

    considered.

    The hospital traffic coming from the Southern Counties will come through

    Inchicore. However the AA Route Finder from Inchicore shows the route to

    Brookfield Road is as follows:

    From Inchicore to Tyrconnell Rd., turn right onto Emmet Rd. From Emmet Rd

    turn right onto Bulfin Rd (through the Bulfin housing Estate) and continue

    straight onto the South Circular Road. Then, take a sharp left onto Brookfield

    Rd (Entrance to The New Childrens Hospital).

    The above impact has not been considered in in the traffic management plans.

    As stated in the planning application there will be no through traffic between

    the New Childrens Hospital and St Jamess Hospital, except for buses and

    ambulances. In consequence, the N4/N6 traffic will exit onto James Street and

    will have to travel via Bow Lane and Kilmainham Lane to get to Con Colbert

    Road (per the AA Route Planner). Alternatively, traffic will travel down Mount

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 19 of 28

    Brown to Inchicore and onto Con Colbert Road. All traffic for Dublin

    South/South East (e g Harolds Cross, Terenure, Sandymount, Donnybrook) will

    have to exit St. James hospital and turn left onto Mount Brown and towards

    the junction of South Circular Rd/Mount Brown/Emmett road, and then left at

    this junction to proceed onto the Canal via Suir Road. This traffic will be

    additional to the existing daily traffic and will also encounter the traffic

    entering the NCH car park on Mount Brown. Alternatively, as per the AA Route

    Planner, the route would be: turn right down Jamess St. and travel onto

    Clanbrassil St. via Frances Street and onwards from there. This impact on city

    centre traffic has not been considered in the traffic management plans.

    2.5 Proposed Bicycle Lane.

    The proposal incorporates a bicycle lane on the road within our area, between

    Rialto Bridge and the corner of the South Circular Road and Brookfield Road.

    This bicycle lane is planned to transition from the left side of the road to the

    middle of the road to allow for access to the hospital.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 20 of 28

    We believe that this is a flawed design and that this bicycle lane should actually

    be within the grounds of the development as set out in Section 15.10.14 which

    states With any development proposal on these lands, consideration should be

    given to their potential to contribute to the development of a strategic green

    network.

    Again, should this development be approved, we would ask that the buildings

    be moved back to accommodate such bicycle lanes to integrate with the

    Greenways as set out in Chapter 6 of the Dublin City Development plan. This

    would also aid in the transitioning of the site with our adjacent Residential

    Neighbourhood (Conservation Area).

    2.6 Helicopter traffic

    We note the proposed plan includes a Helicopter Pad on the 4th floor of the

    National Childrens Hospital, adjacent to the Linear Park and close to the South

    Circular Road. This will presumably provide helicopter access for St Jamess

    Adult hospital, The National Childrens Hospital and the Maternity Hospital.

    The noise from helicopters that are taking off and landing is very significant

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 21 of 28

    and as such we need to ensure that this will not have any adverse impact on

    the health and safety of our local residents.

    Is the impact of the resultant noise safe for the residential community? We

    would like a specialist from the Environmental Protection Agency to assess the

    acceptability of this proposal in terms of noise impact on residents.

    3. Impact on local amenity

    3.1 Impact of additional parking requirements on the neighbourhood.

    Disc parking is in operation in our immediate area from Monday to Saturday,

    with free parking on Sundays and at present it can prove difficult to obtain

    parking near ones house. Currently there is a significant strain on parking in

    the neighbourhood with overflow parking from Jamess Hospital coming onto

    our streets throughout the day from early morning till late evening.

    There is a recognition of this lack of parking problem provided by the NPHDB in

    their submission which includes as one of their Key Mobility Management Plan

    Measures on Page 22 of the Non-Technical Summary: The extension of the

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 22 of 28

    existing on-street pay parking system in agreement with the local residential

    community, where required. In addition, Section 6.1.4.5 of the Traffic Impact

    section contains a section relating to the impact on local amenity suggesting

    the additional burden on local residents as follows:

    Extend the On-Street Controlled Disc Parking Area. It is recognised that the

    proposed Transport Strategy, which limits car parking provision within the St

    Jamess Hospital campus, has the potential to increase parking demand on

    neighbouring roads and streets. This impact has also been highlighted via

    consultation meetings with resident groups in the vicinity of the St Jamess

    Hospital campus. To ensure parking restrictions within the St Jamess Hospital

    campus do not impact negatively on residential parking in the vicinity of the

    hospital, it is recommended to extend the pay parking zone in the immediate

    vicinity of the St Jamess Hospital campus. In addition, to the extension of the

    pay parking zone it is recommended to raise the cost of parking on the

    surrounding streets from the current rate of 1.00 per hour and investigate the

    possibility of introducing extended hours of operation.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 23 of 28

    This tacit acceptance that they are not providing adequate parking is totally

    unacceptable to the residents of this neighbourhood. It also impacts on the

    parents of the sickest children of our country. This fact further reinforces our

    belief that this site is not the appropriate site for the National Childrens

    Hospital.

    It is also of huge concern to us that this proposal incorporates an outline

    design for the campus which is of a significantly higher scale than currently

    exists. Again, there is no consideration to the impact of this scale on the local

    neighbourhood. The increase in traffic is regarded as minimal, despite the

    195% increase in capacity on the site. Taking into consideration that the new

    facilities will cover maternity and oncology, it is hard to understand the

    expectation in the use of public transport.

    4. Considerations requested should this development be allowed.

    Without prejudice to the objections raised elsewhere in this submission, we

    request that in the event of permission being granted for this proposal that the

    following conditions be attached to its decision:

    4.1 Working Hours

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 24 of 28

    We request that work should not commence before 8.00am Monday - Friday

    and that it finish at 6:00pm.

    Given the proximity to our residential neighbourhood, there should be no work

    on Saturdays at the site, however if there is then we request a commencement

    time of 9.00am on Saturday mornings and request that it finish at 1:00pm. No

    work at all should be permitted on Sundays, public or bank holidays.

    4.2. Road cleaning and maintenance

    Given the planned volume of construction traffic, and the duration of same, we

    request that conditions be attached to ensure the cleaning of this area of the

    South Circular Road on a weekly, or at least a fortnightly basis. This is to

    alleviate the dirt that will be caused by the construction traffic. We also

    request that due attention be paid to the road to ensure that all road

    maintenance is carried out in a timely manner, as a level of deterioration is

    bound to happen due to the weight of material that this road will be required

    to carry.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 25 of 28

    4.3 Vermin Control

    Due to the extent of the excavations that have to occur as part of this

    development, together with the redirection of the Drimnagh Sewer on the

    campus we have a serious concern regarding the disruption of rats and their

    dispersion into the local area i.e., our roads, gardens and houses. This is not

    covered at all by the developers and we require same to be controlled, due to

    the impact this may have on our children. We request that this matter be

    addressed by the developer with a view to reducing the impact on the local

    area. We also request that Dublin City Council be required to clean the leaves

    from this road on a weekly basis during the autumn as there will be an

    increased risk of vermin infestation due to this disruption.

    4.4 Landscaping

    We request that the building be moved back to allow for proper landscaping

    similar to the mature trees that are on the side boundary at present. We also

    request that the edge of the building be moved back to allow for both

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 26 of 28

    landscaping to the western border of the site, and to allow for bicycle lanes

    within the campus in line with the Dublin City Development Plan Section 15.3

    which has as a land use objective: To seek the co-operation of owners/

    occupiers of lands zoned, Z6, Z9, Z12,Z14 and Z15, towards progressing the

    green infrastructure network (see section 6.4.1. and 16.2). This shall include, as

    part of any redevelopment of the site, setting back of boundaries and/or

    adequate provision for greenways in accordance with routes illustrated and

    relevant local area plan content.

    5. Alternative sites & possibilities

    The Dolphin Report1 was a detailed analysis of the potential sites available for

    the New Childrens Hospital.

    The report, having examined many potential sites, concludes (p.79):

    The site adjacent to the Coombe is large enough to accommodate the new

    childrens hospital and to allow design flexibility.

    Furthermore, corridor-linked co-location of the new childrens hospital to the

    existing Coombe maternity hospital (or a new maternity hospital at St Jamess

    1 Source: http://health.gov.ie/wp-content/uploads/2014/08/Dolphin_Group_Report.pdf

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 27 of 28

    Hospital) can establish the maternity co-location conditions for a level 4

    Neonatal Intensive Care Unit as defined and recommended by the 2008 KPMG

    report.

    We believe that there are a number of possible solutions that could build on the

    strengths of the St Jamess and Coombe proposals, given their proximity to

    each other, if they presented a joint plan.

    We believe the choice of St Jamess Hospital as the potential site for the New

    Childrens Hospital did not take on board the suggestions and conclusions of

    this report.

    St Jamess Hospital is the countrys busiest hospital. It is the nature of

    hospitals to expand to meet the demands of global medical advancement.

    The NCH must be designed to satisfy the needs for future generations of our

    children, as would be best practice for such a significant investment.

  • South Circular Road, Kilmainham

    Residents Association

    Chairperson Secretary Committee Members Sean Cassidy Mary Kearney Tanya Kenny

    Joe Ruane

    __________________________________________________________________________________________

    Page 28 of 28

    However, this proposed site does not provide sufficient space for the future

    development and expansion requirements of a national childrens hospital.

    Accordingly and in summary, we request that you refuse planning permission

    for the New Childrens Hospital on the Jamess Hospital site on the grounds

    outlined in detail above.

    Yours sincerely,

    Sean Cassidy Mary Kearney

    Chairman Secretary

    _______________ _______________


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