PA0043 SUB DESMOND COX.pdf

Our Ref: 29N.PA0043 P.A.Reg.Ref:

Your Ref:

Desmond Cox 51 Dufferin Avenue South Circular Road Dublin 8

2nd October 2015

Dear Sir,

Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.

An Bord Pleamila

An Bord Plea mila has received your recent submission in relation to the above mentioned proposed development and will take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed.

The Board will revert to you in due course with regard to the matter.

Please be advised that copies of all submissions I observations received in relation to the application will be made available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County Council and at the offices of An 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,

Encls.

ADHOC/PA0043/0l

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Your Ref:

Paul O'Neill National Paediatric Hospital Development Board C/0 G.V.A. Planning & Regeneration Floor 2, Seagrave House 19-20 Earlsfort Terrace Dublin 2

5th October 2015

Dear Sir,


An Bord Pleanala

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,

En cis.

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Our Ref: 29N.PA0043 P.A.Rcg.Ref:

Your Ref:

Chief Executive Officer Dublin City Council Civic Offices Wood Quay Dublin 8

5th October 2015

Dear Sir/Madam,


An Bord Pleamila

Enclosed for your information are two copies of submissions received by the Board in relation to the above mentioned proposed development.

Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.

If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with the Board.

Yours faithfully,

· eran Somers cutive Officer

Direct Line:O 1-8737107

Encls.

ADHOCIP A0043/02

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Your Ref:

Chief Executive Officer Fingal County Council County Hall Main Street Swords County Dublin

5th October 2015

Dear Sir/Madam,





Yours faithfully,

Encls.

ADHOC/PA0043/02

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Your Ref:

Chief Executive Officer South Dublin County Council County Hall Tallaght Dublin 24

5th October 2015

Dear Sir/Madam,


An Bord Pleanala




Yours faithfully,

ran Somers cutive Officer

Direct Line:Ol-8737107

En cis.

ADHOC/P A0043/02

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The Secretary, An Bord Pleamila, 64-67 Marlborough Street, Dublin

30 September 2015

ANBORD

PL29N.PA0043- National Paediatric Hospital

Dear Sir,

51, Dufferin Avenue, South Circular Road,

Dublin 8.

I wish to make an observation in respect of the proposed development of the new National Children's Hospital on the St. James's Hospital (SJH) campus site. Enclosed with this submission is the statutory fee of €50.

An extensive discussion of tri-location of adult, children and maternity hospital services is set out in the application particulars and other supporting documents. The preferred model of healthcare is of important contextual interest in this application, and one which I fully accept.

Despite the unquestionable need for a National paediatric hospital, however, this remains a proposal for Strategic Infrastructure Development, in accordance with the provisions of the Planning and Development Act 2000 (as amended). Section 37(g) of the Act is clear that the Board, in making its decision in respect of such development proposals, shall consider "the likely consequences of the proposed development for proper planning and sustainable development in the area in which it is proposed to situate the development".

It is my submission that the proposed development will result in a permanent and profound adverse traffic impact for the receiving environment of Rialto, South Circular Road, Suir Road, Mount Brown and Kilmainham. This is as a result of the proposal depending on access via a highly constrained local road network, both in the construction and operational phases of the development.

There is a significant likelihood of traffic hazard arising from the fact that traffic, including emergency vehicles, staff and visitors travelling to and from the enlarged and intensive SJH complex, must access via an extremely narrow and congested part of South Circular Road. I address this issue in more detail further in my submission.

The model of tri-location, while appropriate in itself, is quite simply in my opinion being proposed on the wrong site. Moreover, it is the Government decision that such model of trilocation should be located at the SJH complex that is the root cause of such profound adverse impact. As a consequence of this, I submit that the proposed hospital development will have significant and adverse consequences for proper planning and sustainable development in the area in which it is proposed to situate the development.

The Context for Identifying the Proposed Site, and Consideration of Alternative Sites

To understand why the children's hospital development is being proposed on the SJH site, and for the Board to consider whether this site is the most suitable location for the proposal, from the perspective of proper planning and sustainable development, it is essential to review the entire consideration of alternative site options. In this context, it is somewhat odd that the 2012 Report of the Review Group on the National Children's Hospital (the Dolphin report), and the subsequent 2012 "Further Assessment of Planning Issues in Relation to Proposed Sites (the Clear/Martin report) do not form part of the application particulars, when they must be taken to form the basis for the Government decision to proceed with the proposed hospital development on the SJH campus.

In the context of the Board's statutory remit of proper planning and sustainable development, it is essential that the process of examining alternative sites, including as set out in the Dolphin and Clear/Martin reports is considered by the Board. Indeed, this exact point forms the second of the final recommendations of the Clear/Martin Report (Chapter 5). Under the heading of Consideration of Alternative Sites in the EIS", it states:-

"Under EU and Irish legislation, an EIS (which is mandatory for Strategic Infrastructure Developments) must contain an outline of the main alternatives considered by the applicant from an environmental perspective. In the previous application on the Mater site, the Board's Inspector was somewhat critical of the lack of appraisal of alternative sites, although this was not reflected in the Board decision itself. However, had permission been granted, such a decision might have been the subject of a judicial review challenge which, even if ultimately unsuccessful, could have delayed the project. To reduce the risk of such a challenge arising from any future decision, it is recommended that the EIS should address the issue of alternative sites from a planning I environmental perspective, including relevant material from the Dolphin Group Report. It is not necessary to show that the site selection process was based primarily on such factors - particularly when clinical outcomes may be more influential - but their contributory role should be acknowledged".

Given the critical importance of the Dolphin and Clear/Martin reports to the Board's consideration of alternatives sites in respect of the proposed development, I have made some observations in respect of both in the following sections, and have enclosed herewith.

The Dolphin Report The report of the Review Group, published in June 2012, presents a very clear and transparent consideration, at a certain strategic level, of various potential site options for the new children's hospital. It provides a comprehensive discussion of best practice of healthcare, and in particular, tri-location of hospital care, as well as the principles of "hub and spoke" healthcare provision.

What is clear from the report is that tri-location, the preferred model, is not based necessarily on adjacent or shared physical infrastructure (though this is beneficia · · ALA to and facilitation of shared synergies, such as specialists, research, qut;M~MP. why the Review Group invited the Coombe Hospital to present a ~al - givJ~~w._.--., support that would be available from the nearby St. James's adult teac ing hosp~B\· OCT 1.0\5

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Chapter 6 of the report addresses access and parking, and notes that about 90% of ED patients arrive by car. Presumably, the vast majority of the remaining percentage arrives by ambulance, meaning that road access is of critical importance. I note this as my fundamental concern with the proposed development on the SJH site is that the existing heavily constrained and congested local road network cannot facilitate such access, and that a profound traffic impact will arise, putting the lives of patients at risk. How will emergency vehicles and cars access the SJH site via the existing South Circular Road at Kilmainham when this road is congested on both sides with cars for significant periods of the day? Such congestion is a residual impact predicted in the EIS submitted with the application.

The report undertakes a very transparent filtering process of site options, and explains why a Dublin option is preferred; and further, why a city site served by good access and public transport links is optimum. I would fully concur with this conclusion.

Chapter 11 of the report set out at Table 1 a comparison of site areas proposed. Of particular note to my submission, the Coombe Hospital site offers a total of 8.49ha with 6.19ha for the children's hospital, while the SJH site only offers a total of 3.70ha, with only 2.44ha for the children's hospital. As noted below, in respect of the Clear/Martin report, the SJH site is clearly infeasible without "decanting" existing facilities from a wider part of that site to some other location.

It is also noted in the report that "St James's Hospital has indicated its support for the Coombe proposal in the event that its own proposal is not accepted". The proposal for the site involves immediate tri-location of services involving the existing maternity hospital, the new children's hospital on the adjacent site, and the nearby adult SJH (see Figs 1 & 2) .

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Fig 1: SJH complex (top of map) and Coombe Hospital In red, showing open lands to south-east of Coombe Hospital, and direct linkage vla South Circular Road and Reuben Street (approx. 600 metres). Source: Google Maps

3

Fig 2: Aerial photo of area, also showing LUAS alignment and Cork Street and South Circular Road bus corridors. Source: Google Maps

Each site option is assessed in terms of strengths and weaknesses in the report. In respect of the Coombe Hospital site option (pages 60-61 ), the significant strengths of this option are listed, including those related to ensuring best healthcare, as well as matters of proper planning and sustainable development such as site suitability, access, planning and design.

There are only three weaknesses/risks noted:-

(a) Requiring a walk to SJH across a busy street - it is subsequently noted in Chapter 12 (risk factors) that this can be resolved by improving pedestrian crossing of Cork Street (there are currently two pedestrian crossing points in the immediate vicinity of the existing maternity hospital), and by creation of a new pedestrian entrance into SJH at Fatima LUAS stop. In this latter respect, Chapter 7 of the EIS confirms that "In addition to the existing St James's LUAS stop, a new direct pedestrian access from the Fatima LUAS stop into the campus, will shortly be opened which will also facilitate additional connectivity to bus routes to the south of the campus, along Cork Streef'. The provision of such an access will overcome the identified weakness with the Coombe Hospital . ·

-~ (b) Site has to be acquired from multiple owners- however, the subs ~Ma ·

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(c) Site acquisition cost- however, any provision for "decanting" to this or any other site, will also have associated costs.

AN BORD PLEANALA TIME BY

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LTR·DATEO FROM In significant contrast, the assessment of strengths and weaknes ~. of the SJf'l site op·t.:.~:.....,:tf~t---a (pages 69-70) sets out a large number of weaknesses and risks, ,~, ., · _, · those criteria that inform considerations of proper planning and sustainable development in respect of the proposal. These include, minimising capacity for future further expansion of the adult hospital, traffic congestion near Rialto Gate, potential design issues, the need to decant existing uses from the site, with associated demolition and decanting costs (I have also addressed this above). It is important to note that the majority of these weaknesses are now reflected in the proposed development, and confirmed in the accompanying EIS.

Again with regard to risk factors (Chapter 12), the report notes risks such as physical trilocation compromising the ability of the adult hospital to meet its own future expansion needs; access issues associated with inner city locations; timelines, and in particular with site acquisition- "Where the site is wholly owned by the relevant adult teaching hospital, or where public sector co-owners have indicated their willingness to transfer their lands free of charge, risk of delay in acquiring the site will be minimised' (as confirmed in the Clear/Martin report this applies to both the SJH and the Coombe Hospital sites).

At a site-specific level, the risks associated with SJH option presented in the Dolphin report are significantly greater than those associated with the Coombe Hospital site option; moreover, the risks associated with the latter option- that of site ownership and acquisitionare addressed and reduced further in the Clear/Martin report.

The overall Conclusions and Recommendations of the Dolphin report (Chapter 13) is very clear in terms of preference for the Coombe Hospital site, from both a clinical and academic perspective, and from a design and planning perspective. At page 79, it is stated:-

"From a clinical and academic perspective, we identified StJames's Hospital as the existing DA TH that best meets the criteria to be the adult partner in co-location because it has the broadest range of national specialties and excellent research and education infrastructure. However, the proposed St. James's Hospital plan offers the smallest site for construction of the new children's hospital, albeit with greater site capacity overall (see Table 1 on page 48), has some drawbacks in terms of site suitability and is not without planning risk.

The site adjacent to the Coombe is large enough to accommodate the new children's hospital and to allow design flexibility. Furthermore, corridor-linked co-location of the new children's hospital to the existing Coombe maternity hospital (or a new maternity hospital at St James's 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 StJames's and Coombe proposals, given their proximity to each other, if they presented a joint plan.

5

From a design and planning perspective, the sites adjoining Connolly and the Coombe hospital offer the best potential for future expansion and a landscaped setting".

From the perspective of proper planning and sustainable development, it is my submission that the Coombe Hospital site option is the optimum location for the new children's hospital; this will allow direct physical linkage with the maternity hospital, and direct spatial linkage with the nearby adult hospital, facilitated by enhanced pedestrian access via Reuben Street and South Circular Road, and a new pedestrian access at Fatima LUAS stop.

On the other hand, the proposed squeezing of the new children's hospital, and subsequent maternity hospital onto the already constrained SJH site, can only occur with the decanting of existing facilities away from that site, and raises serious concerns in terms of significant traffic impact on access and accessibility, local road congestion, and on-site parking. While this is addressed in more detail below, the suggestion that any future maternity hospital on the SJH site would have absolutely no additional car parking is quite extraordinary, and reflects the difficulty of seeking to justify the merits of this sub-optimal site option.

The Clear/Martin Report The Clear/Martin Report was published just over four months after the Dolphin Report, with Terms of Reference essentially to provide a commentary regarding the potential risk for each hospital site (reduced now to 5 no. options) of not achieving planning consent.

Of signficance, the Terms of Reference of the report required the planning consultants to "examine the planning implications of developing the new children's hospital on the existing St James's Hospital campus if the Player-Wil/s!Bailey-Gibson/DCC site (adjacent to the Coombe Hospital) is made available as additional expansion space to allow for decanting of current non-core facilities from the St James's campus and future hospital-related development, as appropriate': This now comprises the proposal before the Board.

The justification for this element of the Terms of Reference is not explained. It certainly does not appear to follow directly from the content and conclusions of the Dolphin Report published only a few months previously. Given a lack of transparency on this issue, as well as any public consultation on the Dolphin Report, I hold the concern that a decision had already been made that the SJH was to be the site for the new children's hospital (and future maternity hospital), notwithstanding the clearly stated weaknesses with this option.

This would explain why the Clear/Martin Report, and the subsequent application particulars, read more as a justification of a Government decision already made, rather than as an open, objective and transparent consideration of alternative options from the perspective of proper planning and sustainable development.

The Clear/Martin report notes at the outset (Chapter 2) that "in spatial planning terms, it would be preferable to find a site on a campus that has room to accommodate expansion of ---· building laterally and additional new buildings over time comfortably within th \9{ the planning unit. Filling the campus space available from the o IBM ei:J for strategic planning reasons including future proofing". This is not proposal whereby the new hospital must depend upon the "de existing site, let alone ensuring space for future expansion of the

This, to my mind, reflects a fundamental deficiency of the proposal, whereby all the weaknesses of the SJH site, articulated as far back as 2012 in the Dolphin report, are reflected in the proposal in terms of potential impact. In particular, the residual significant adverse impact on traffic and access to the SJH site that is identified in the EIS, and which it appears to be acknowledged cannot be in any way significantly mitigated, was identified three years previously in the Dolphin report and in the Clear/Martin report, as well as by the Board in its pre-application consultation with the applicant. J,Q.~w· ·~~~~~!'P."Y:..,

decanting of facilities from the SJH site, upon which the propo ed ~~~ wholly dependent, is not clarified or assessed in any meaningful ay.1E BV ___ -1

The Clear/Martin report gives a useful detailed outline of the vari us site o(:iti~nQ~h~~\~r 3). Of note, the report acknowledges the good accessibility to ~~~e HosJPi\eMs....,i_te .... _.,

including major public transport infrastructure, and the ability to.1f~~jci!lilia::ta;a:te:csb~o~thp:::co;:n;:s;:tr=u=c=tio=n=== and operational traffic. It also reinforces the relative proximity of tn L.

One major error in the Clear/Martin report that was never rectified in the planning assessment relating to the Coombe Hospital site option, is the statement that "hospital use is not listed among the landuses which are permissible or open for consideration in the Z14 or Z6 zones" and that "the Z14 zoning does not explicitly support hospital development". The report concludes in this regard "that that there is a strong case for arguing that such development would not represent a material contravention of the City Development Plan, having regard to the objective to secure the physical, social and regeneration of these brownfield sites': While presumably seeking to articulate a low planning risk, this reference to the potential for material contravention is likely to have introduced consideration of planning risk into the mindset of decision-makers (or indeed it might have given justification to a prior Government decision to locate the hospital on the SJH site).

In actual fact, the Z14 land use zoning applying to the majority of the site includes "Buildings for the health, safety and welfare of the public" as a permissible use. Appendix 29 of the Dublin City Development Plan 2011-2017 sets out Land Use Definitions; the above use is defined as "Use of a building as a health centre or clinic or for the provision of any medical or health services .... Hospital.. .. ". In short, the proposed children's hospital would comprise a permissible use on the Coombe Hospital and adjoining brownfield site.

The overall planning assessment concludes that the Coombe Hospital site would be "Low Risk': Presumably, given that a hospital use is actually permissible in principle on the sitesomething that was not considered in the report - the risk would actually be negligible. In contrast however, in respect of the SJH site option, the report clearly accepts that the actual site cannot accommodate the planned children's hospital without the significant "decanting" of existing uses to some other location. Indeed in the summary table of overall planning assessments in Chapter 3, it is stated in respect of the SJH site that "Significant risk if the site of the Children's Hospital is limited to the initial2.44 ha area; moderate risk if the site area is increased to at least 3.5 ha (within the proposed overall site of 6.3 ha)':

It is also noted that in respect of Ease of Access the report cannot conclude (as it does for the Coombe Hospital site) that there is good access by road to the SJH site. Instead, the report highlights meetings with the City Council to discuss measures to overcome the deficiencies in the local road network in this area that it is clearly anticipated will be

7

exacerbated by the proposed hospital development. This even extended to an additional road lane from the Rialto Gate to merge into the South Circular Road as the road travels towards Rialto Bridge. It notes in particular, likely difficulties for construction traffic.

As addressed further in my submission, these concerns regarding access and vehicle movement are well founded, and cannot be overcome by mitigation measures that are now contained in the application and EIS in respect of the proposed development. I reiterate my view that the proposed hospital development is simply in the wrong place, as reflected in the conclusions and concerns expressed three years previously in the Clear/Martin report.

Chapter 4 of the Clear/Martin report focusses on the potential for decanting of non-core facilities from the SJH site, to make that site in any way feasible to accommodate the proposed hospital. Again, this chapter clearly acknowledges that the SJH option is infeasible without the associated decanting of existing facilities from that site. Therefore this development proposal must intrinsically include both the provision of the new hospital and the associated decanting of existing facilities.

I am very concerned that from the perspective of both proper planning and sustainable development, as well as from the perspective of the imperative need to assess the cumulative impact of the proposal, that there is no material detail in the application particulars relating to the planned decanting element of the project - such as specific siting, access, design and overall impact of such decanting. This is addressed separately below.

Even with the erroneous understanding of the land use zoning of the Coombe Hospital site, the Clear/Martin report confirms that the site has the lowest risk of the city sites from the perspective of proper planning and sustainable development. Given that the Dolphin report previously highlighted the preference for a city site, it can be reasonably concluded that the Coombe Hospital site is the preferred site from such perspective. I also think it is reasonable to conclude that the Coombe Hospital site emerges as the preferred site from a reading of the Dolphin report, even though it doesn't explicitly identify a preference In its conclusions.

The Dolphin Report and the Clear/Martin reports formed the basis for the Government decision regarding the location of the new National Children's Hospital. Whilst containing a major inaccuracy regarding the zoning of the Coombe Hospital site, the Clear/Martin report is based upon careful consideration of matters of proper planning and sustainable development. It is my submission that the Government decision, upon which this proposal is based, is not In any way transparent, and does not reflect the content and conclusion of those reports; nor does it reflect matters of proper planning and sustainable development.

Chapter 4 of the EIS Chapter 4 of the EIS addresses the issue of alternative sites, and states that "Informed by this comprehensive assessment of alternative sites the Government made the decision in November 2012 to locate the new children's hospital on St. James Hospital Campus". In fact, the Government decision was made just one month after the Clear/Martin report was published. No transparency is provided in this application, nor indeed elsewhere that report, or other criteria informed the Government decision. t.E.~l'l~~

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One thing that is apparent is that there was no public participation in the environmental decision-making process, which as the Board will be aware, is one of the key pillars of the Aarhus Convention. That is why it is imperative that the Board considers the entire process of site optioneering that has occurred in respect of the propose development, and offers it to the public for scrutiny and discussion. In this regard, I note the discretion of the Board to hold an Oral Hearing in respect of an application for Strategic Infrastructure Development.

Chapter 4 of the EIS seeks to stress that the decision to locate the new children's hospital on St. James Hospital Campus was "informed by a forensic and robust examination of the alternatives having regard to all relevant perspectives i.e. paediatric model of care, spatial planning, environmental considerations and site design". However, it is noted at the outset of the chapter that the applicant relies on the fact that "St. James Hospital Campus has been chosen at Government level as the location for the new children's hospital.. .In relation to Government level decisions, the EPA Guidelines acknowledge the role of the relevant higher authorities and the role of the Environmental Impact Statement (EIS) in the context of same". It is further stated that 'While .... environmental considerations informed the Government decision, they were not the primary consideration in choosing St. James's Hospital Campus as the location of the new children's hospital': Such considerations are of extreme importance however, and it is the Board which will decide whether the proposed development, arising from the Government decision, r planning and sustainable development. AN BORD P

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It is subsequently stated in the Chapter that:- - 1 OCT 2015

·~s the core purpose of the new children's hospital will L~Dery of tlfB.tiMst clini outcomes for children and young people the Governme tP~..ecision to choose St. Jam Hospital Campus as the location for the new children's ho · , o e supporting planning and environmental conclusions of the Report of the Dolphin Group, was " ... led by clinical considerations". Following numerous assessments and analysis St. James Hospital Campus has been established as the best site for the location of the new children's hospital not only from a planning and environmental perspective but also in terms of the implementation of the Model of Care".

I am hugely concerned that the lessons arising from the Board's previous decision in respect of the National children's hospital development have not been learned. While as a parent I am concerned to ensure a timely provision of high-quality paediatric healthcare, this cannot be at the expense of a profound impact upon the receiving environment in which it is located, and indeed the impact upon the operation of the entire hospital complex in terms of access for staff, patients and visitors.

Chapter 4 addresses the Dolphin report, and confirms, as I have noted above, that the report concludes that the Coombe Hospital site offered the best potential for future expansion and a landscaped setting. The discussion notes, as also addressed above, that the SJH site can only be feasible if existing facilities are decanted to another site.

There is also a justification for the SJH site in terms of proximity to public transport, community benefit etc. These of course equally apply to the Coombe Hospital site, given that these two sites are only 600m apart. Indeed, the Coombe Hospital site has a direct access

9

to the Fatima LUAS stop, but is in immediate proximity to the major public transport corridor of Cork Street. The development of either site will promote the growth of these existing city communities including the re-development Herberton (Fatima) area.

Equally in this regard, the EIS sets out the community benefit of the proposed development at Sections 14.2.1, 14.2.2 and 14.2.3. Such benefits clearly relate to this part of the inner city, and not specifically to the area of the SJH. In this context the conclusions are correct, but equally apply if the proposed hospital was on the Coombe Hospital site.

In addition to this, the application identifies strategic Regional and Local Development Plan policy that supports the development of the children's hospital (a) as part of an accepted model of National-scale healthcare, and (b) in the south-west inner city area. For example, Policy RE19(ii) recognises the role all hospital complexes play in the life of the City and their importance as not only a service provider but as an employer, as a generator of economic benefits and as a promoter of the knowledge economy. However, it is also clear that there is nothing in terms of planning policy or development standards that distinguishes the SJH site as more appropriate for the proposed development from the Coombe Hospital site.

On the basis of this, but also the superior qualities of the Coombe Hospital site as reflected in the Dolphin and Clear/Martin reports, it is extraordinary that the EIS concludes that "the St. James Hospital Campus site is the most sustainable of the sites examined from an environmental and planning perspective". This is clearly not the case, and gives substance to my concern that the EIS is a vehicle to justify an inappropriate Government decision, rather than being an objective statement.

The SJH site is also justified in Chapter 4 on the basis of construction timeframe, concluding that "Based on the detailed information available from the Dolphin process, it is confident that the hospital can be and will be built as quickly as possible on the St James's site." The speed of construction is not a matter of proper planning and sustainable development, but this statement suggests that this issue has unduly influenced selection of the proposed site.

In conclusion in this regard, I consider that, from the perspective of proper planning and sustainable development, the proposed SJH site is not the optimum site for the proposed National children's hospital. It is clear from all public reports in respect of considering site options that the Coombe Hospital site is the better option.

There is nothing in terms of models of healthcare that appear to justify the SJH site over the Coombe Hospital site - indeed it is acknowledged in the supporting reports that the provision of a paediatric hospital immediately adjacent to the existing maternity hospital would offer a high-quality neo-natal facility. This would occur in close proximity to the adult hospital.

I reiterate my conclusion that, having regard to all the supporting reports, to the lack of transparency in Government decision-making, and to the somewhat inconsistent identification of risks and weaknesses of the various site options, the proposed site at th SJH campus is the wrong option from the perspective of proper planning an le development in comparison with the Coombe Hospital site, and · ~ or the resulting profound and unnecessary adverse environmental i c~ I 1nev- · .

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Traffic Impact of the Proposed Development

AN BORD PLEANALA TJME BY

The Existing Congested and Constrained Local Road Network - J OCT 20J5 To understand the profound adverse traffic hazard that will in ~t§J5l~T~ur wilfROMe proposed tri-location hospital development on the SJH site, the B~ ~must understand the~--r existing local road network in the vicinity of the Rialto Gate.

The South Circular Road (SCR) has three right-angle bends in this area: one at Rialto and the Rialto roundabout; one at the Rialto Gate immediately proximity to the LUAS bridge and the existing entrance to St. James's Hospital; and one at the junction of SCR with Suir Road and Bulfin Road. This causes considerable daytime (particularly morning and evening) congestion on the local road network. Moreover, such congestion cannot be ameliorated, for example by road widening, as it is compounded by signalised junctions further along this network for example the junctions of SCR and both Mount Brown/James's Street, and with Bow Lane, and the junction of Suir Road with the Canal Road. The LUAS bridge and Rialto roundabout are also road constraints which cannot be overcome by this proposal.

The significant daytime congestion is confirmed in the EIS, which in Chapter 7 notes that "In terms of the local road network and onward connections to the regional and national road network, the baseline appraisal identified that, as with most other city centre locations, the local road network can experience congestion during both the morning and evening peak commuter traffic periods". Such congestion is caused, in part, by existing vehicles accessing and egressing from the existing SJH campus. However, it must also be noted that the SCR is a major South City distributor route to the N4/M4 and M50.

In contrast to the area of the SJH site, that portion of the SCR in the vicinity of the Coombe Hospital site is generally straight, with signal controlled junctions at Donore Avenue and Cork Street. Cork Street itself is a wide 4 lane carriageway. No such constraints occur on this part of the SCR as occur in the vicinity of the Rialto Gate. Moreover, the westbound carriageway of Cork Street leads to the Crumlin Road, which has a signalled controlled junction at Sundrive Road with a northbound filter lane. This allows traffic to easily access the Canal Road. It offers an easy and well controlled route from the area of the Coombe Hospital site, including to the area of the proposed construction compound on Davitt Road.

The EIS gives a relatively faithful summary of existing traffic conditions in the vicinity of the subject site:-

• Fig. 6.22 confirms that 67% of staff at the existing SJH arrive in the peak period 7-8.30am while Fig. 6.23 confirms that 63% depart in the peak period 4.30-6pm. This is unlikely to change with the proposed children's hospital, and the future tri-location campus. However, it obviously equates with general (non-hospital related) peak-time traffic movement in this congested city area.

• Section .6.1 .3.1. in respect of Road Network Regional Road Access states that 'The location of the site to the west of the core City Centre, means that it is within easy ·access of the M50 motorway, via the N4 Chapelizod bypass and the Naas Road from the N7 Red Cow Interchange". This statement misses the crucial point that it is not within EASY access of these trunk roads, because of the location of the Rialto Gate at the apex of the

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I pinch points of SCR/Kilmainham, and SCRILUAS/Rialto. This is reflected in journey times to the MSO as captured in the EIS - "journey times to the StJames's Hospital campus vary between 15 minutes and 25 minutes with the N4 access route along Chapelizod Bypass slightly quicker during the morning peak period. During the off-peak periods the journey times are between 10- 15 minutes with access via the Chapelizod Bypass slightly quicker ... the journey time between the StJames's Hospital campus and the N41nterchange via the Chapelizod Bypass (in the evening peak time) is between 30 and 40 minutes with delays experienced on both South Circular Road and the Chapelizod Bypass exiting the city'~ This, of course will be the time when many visitors and staff can be expected to be entering or exiting the hospital.

• At the SCR/Suir Road junction, the EIS reports that the junction "is approaching, or at capacity during the morning and evening peak periods. However, traffic conditions at this junction are impacted by traffic queues which develop along South Circular Road approaching the junction of Mount Brown/South Circular Road, with longer queues and delays experienced approaching this junction during peak periods. The analysis of the junction has reflected this impact on queuing by reducing the available green time for traffic turning onto South Circular Road during the peak periods".

• SCR between Suir Road and Rialto Gate is reported as supporting high traffic volumes, particularly during the peak hour periods. In the morning peak, this is in both directions, "with queues and delays experienced at the various traffic signals located on the South Circular Road in Kilmainham, including the recently upgraded Rialto Roundabout". In the evening peak, traffic conditions travelling westbound towards Kilmainham and northbound towards Con Colbert Road are reported as being "generally very slow with queues extending back through the various junctions located along this route". In the eastbound direction the level of queuing is not as extensive with some slow moving queuing generated northbound approaching the Rialto Roundabout.

• At the Rialto Gate of the hospital campus queuing is reported at the Brookfield Road/SCR signalised junction. The EIS states that "the analysis of the existing operation of the junction indicates that during the morning peak period the junction operates at capacity with queues forming on approach to the junction from both directions along South Circular Road'~ During the evening peak period the extent of queuing exiting the Hospital is reported as "more pronounced" with vehicles queuing within the campus waiting to exit. Much of this queuing is associated with standing queues on the South Circular Road, particularly on approach to the junction of Suir Road/ South Circular Road. During off-peak periods the Rialto Entrance and its associated signalised junction at the intersection of Brookfield Road/ South Circular Road generally operates well, with limited queues experienced on all approaches to the junctions.

There is absolutely no question that the local road network in the vicinity of the Rialto Gate i severely constrained, and as a result severely congested. The nature r 'nt derives from the existing junctions, meaning that no road wi ~~ e can in any way improve this fundamental infrastructural deficiency. a'l

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Public Transport in the South-West City Area The EIS addresses public transport in the vicinity of the SJH site, and quite correctly notes the availability of capacity to meet travel demand by bus and rail. The EIS notes that "In overall terms, the regional population catchment which can access St James's Hospital campus within one hour by public transport is just over one million". Furthermore, it is noted that "Ongoing and planned improvements to public transport in the Greater Dublin Area will improve accessibility to St James's Hospital campus even further prior to the completion of the new children's hospital. These improvements include the LUAS Cross City project currently under construction and continuing upgrading of the level of bus service, including three Swiftway, Bus Rapid Transit routes proposed to cross the city".

This is entirely correct. It also absolutely applies to the Coombe Hospital site as much as to the SJH site. This is the merit of a tri-location hospital s · - st inner city area. The SJH site cannot be considered to be more prefera e t~H dl08QMt!eAI~ the basis of public transport, particularly when a new P'i!~trjan acceBtf to the located adjacent to Fatima is identified in the EIS.

- f ocr 2o1s An Asp/rational Approach to Modal Shift LTR·DATED FR Unsurprisingly, given the inevitable traffic impact of th Fllroposea=t"Jsoelcip~M-........ ~ site, the EIS lists the various transport policies which a car usage. Again, it is noted that such benefits in terms of modal shift, if it can be imp emented would apply to both the SJH and Coombe Hospital sites, given their proximity to high-quality public transport, pedestrian and cycle facilities.

Notwithstanding this, I note that the EIS is dependent upon aspirational statements of various strategies, Draft plans and other documents. There are no real concrete plans upon which the proposal can actually depend to ensure an adequate modal shift from private car use (with 54% of staff currently driving to work). Moreover, there is no demonstrable confirmation that such modal shift is achievable in practice - for example agreements with Trade Unions regarding such significant change to existing staff conditions and facilities.

This is of critical importance as it forms the basis for the proposed reduction in staff car parking on the SJH site. It is of particular concern, given that Figure 6.24 confirms that the home locations of staff at St James's Hospital are spread throughout the wider Dublin area, with concentrations in areas of south west Dublin (e.g. Rathfarnham, T empleogue) and west Dublin (Ciondalkin, Celbridge, Lucan and Blanchardstown), meaning that they cannot reasonably access by foot or bike, and only with considerable difficulty by public transport.

The EIS makes the extraordinary suggestion that "It is reasonable to assume that, in time, the new children's hospital staff population will reflect a similar geographical pattern to that of the existing StJames's Hospital, as staff choose to live in areas with greater accessibility to StJames's Hospital compared to their current Hospital location. There is absolutely no basis for this ·assumption that people settled in various residential areas as outlined in the EIS will leave those a·reas to live closer to the new hospital. The level of assumption and presumption in this traffic analysis is extremely concerning, and in my view in unduly relied upon to justify the necessary reduction in staff car parking on the site in order to facilitate the new development. This actually simply reflects the inadequacy of the proposed site.

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Of course, if there is not an actual modal shift arising, it will simply mean that private cars will be forced to park on the local road network. The EIS addresses this by stating that "To ensure parking restrictions within the St James's 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 James's 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". This is considered to constitute an indirect adverse impact on local residents and their visitors, and arises primarily from the inability of the SJH site to adequately and appropriately facilitate the proposed children's hospital, let alone any future maternity hospital on this site.

Based on this aspiration of modal shift, much is made of the proposal that there will be an overall reduction in staff car parking within the St James's Hospital campus from 1,124 spaces currently to 880 spaces, "equating to 244 Jess parking spaces". Of course this is not a reduction in car parking spaces, only in staff parking spaces. It is also proposed that there will be an increase from 467 patient/public spaces to 1,131 spaces, equating to a net 664 additional visitor spaces. The new children's hospital includes a proposed net gain in on-site parking of 420 spaces. The entire quantum of parking provided on campus will be approximately 2,000 spaces. The traffic arising from the proposed development cannot be divorced from that arising from the existing hospital.

This results in another extraordinary presumption in the EIS, that "The car parking stock and appointment schedules will be actively managed to provide a high turnover in parking spaces ensuring that all patients wishing to avail of parking will be facilitated". I cannot understand how this could possibly be managed, given that the hospital will be undertaking the most acute paediatric care, requiring all-day parent attendance. In this regard, it is noted that "84% of the out-patient clinics will be provided at the new children's hospital on the St James's Hospital campus with the remainder provided at the satellite centres. With respect to urgent care cases it is envisaged that 59% will be treated at the new children's hospital with the remainder split evenly between the two satellite centres". As noted above, the Dolphin report estimates that 90% of emergency cases will arrive by private car.

From a parking management perspective, this simply cannot be controlled, given the significant variety of care cases that will arise at the hospital. Again, however, these presumptions and assumptions are being relied on to justify the proposed development, and its impact. The Board cannot reasonably be satisfied that such presumptions will occur in practical reality.

Traffic Impact during Construction The EIS suggests that "the greatest traffic impact during construction will be as a result of the export of material from site during basement excavations, over an approximate 18 month period, and the import of materials (including concrete deliveries) for the construction process. In terms of the former, at peak excavation, approximately 150 daily heavy goods vehicle (HGV) loads are likely to be generated. In terms of material im o · · 100 HGV's per day are likely to be generated during the peak pe . ·AN BORO PLEA

11ME _aY ___ , - _ 1 OCT 20\5

This is undoubtedly a significant impact. However, even though the construction period is 18 months for the proposed children's hospital (the EIS unfortunately does not adequately consider the additional construction period that will be required to facilitate construction of the future maternity hospital, and the cumulative impact thereof), this will be a temporary impact, or at least an impact with an· end. The ongoing operation of the hospital will result in a profound adverse and permanent traffic impact on the receiving local environment.

It is very concerning that "Two construction access routes are proposed, one via South Circular Road/Mount Brown and the second via the South Circular Road/ Suir Road". In other words, ALL construction traffic will be required to traverse on the most congested and constrained part of SCR, as confirmed by the EIS, and as summarised above. Fig 6.71 unfortunately does not note the essential fact that, for very good reasons, there is no right turn from Mount Brown westwards onto SCR, as this would obstruct a major route into the city from the N7 via lnchicore. As a consequence, construction traffic would be forced to access through lnchicore village. Such construction traffic impact, over the 18 month period of construction would be profound and adverse.

This contrasts fundamentally with what would be experienced at the Coombe Hospital site, whereby construction traffic would access either onto Cork Street, or onto a wide and generally straight stretch of SCR. From here, as noted above, there is easy and signal controlled vehicular access on the Crumlin Road to Sundrive Road, and therefrom to the proposed compound at Davitt Road.

The Traffic Impact Arising During Operation of th Pr~@Q!fleYp~JM~ Given the articulation of the existing constrained an l11t!Jested locaa~ad networ in the vicinity of the proposed development, it is inevitable ere will be such mi!n'tl~""-""""' arising to SCR as set out in the EIS. - 1 OCT 2015

In this regard, the EIS concludes that "Following ·ldren's hospital, it is acknowledged that the surrounding stli rience traffic queuing and delays at some periods through a typical week day. The mitigation proposals included as part of the Transport Strategy for the StJames's Hospital campus and the new children's hospital will ensure however that the increase in traffic levels and associated impact during these periods are kept to a minimum'~ There is no doubt, however, that even keeping such impact "to a minimum" the permanent impact upon the local road network of SCR and Kilmainham will be profound and adverse.

The EIS sets out the predicted traffic impact of the proposal at various junctions:

• At the SCR/Suir Road junction the EIS predicts that "there will be little change in prevailing conditions during the morning peak period. During the evening peak period the proposed development does result in a small increase in traffic through the junction resulting in a slight increase in queuing". However, as noted in the baseline, the junction is already at capacity with significant queuing, so any increase will inevitably increase that queuing. No meaningful mitigation that can alter this situation can be proposed; ·capacity at this junction simply cannot be increased. The EIS suggests that junction movements might be improved by the removal of parking and loading outside the various retail outlets in Kilmainham village. Of course, this is far outside the control of the

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applicant, and is not therefore proposed in this application. The applicant cannot possibly rely on this as a mitigation measure.

• At the SCR/Brookfield Road junction, it is accepted that "The new children's hospital is expected to have a marginal impact on the operation of the junction during the evening peak period and the junction is expected to remain close to capacity, with its operation impacted by downstream conditions". These "conditions" essentially relate to the SCR/Suir Road and SCR/Mount Brown junctions. Again, no substantial mitigation can be provided to reduce this significant adverse impact, given the right angle turn in the SCR at this location.

In conclusion in this particular regard, I reiterat~ my consideration that the SJH site at Rialto Gate is the wrong site for this hospital development. The traffic hazard that will arise from the additional traffic and parking occurring at the site, despite all aspirations of modal shift and hospital parking management, will result in a profound adverse impact on the local receiving environment. In addition, the predicted congested local road network will hamper emergency access to the hospital by ambulances as well as by private cars. This is entirely contrary to principles of proper planning and sustainable development.

It is submitted that such level of adverse impact would not occur in the scenario of the children's hospital development being located at the Coombe Hospital site at the junction of SCR and Cork Street.

Inadequate Cumulative Assessment of the Proposed Development

The relatively recent O'Grianna judgement, with which the Board will be entirely familiar, has reinforced the requirement for the Competent Authority to be able to undertake an assessment of the proposed development in cumulation with other development.

In this instance, the proposed development of the children's hospital must be assessed in cumulation with other planned development in particular, I suggest, including the "decanting" of certain facilities from the existing SJH site to make space for the new hospital, and the planned maternity hospital at the SJH site.

Such cumulative assessment contained in the EIS is entirely inadequate, and gives no understanding of either what is proposed in respect of these two essential elements, and the environmental impact of same in cumulation with that impact arising from the proposal.

Decanting of Existing Facilities from the SJH Site Section 2.4.1 of the EIS confirms that "The proposed development includes the demolition of 20,539 sq.m. of existing buildings at St. James's Hospital campus to facilitate clearing the site for the proposed new buildings". These are identified in Figure 2.16 of the El N~~

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....... __ -----e.--.-·---111. -c... By any standard, this is a significant existing floorspace that is being removed from the site. It is entirely unclear from the proposal where and how this will be facilitated. It is simply stated at Section 18.2.1.27 that '7he St. James's Hospital decanting programme involves the movement of existing operations to other locations within the campus. Certain building upgrades and modular buildings are being constructed to accommodate these changes (DCC Reg. Ref. nos. 2787/15,2761/15, 2625 and 3069/15 refer)':

This lack of clarity in terms of the wider cumulative proposal means that it cannot be possible for the Board or the public to understand the full nature and extent of the proposed development of the National Children's Hospital.

In this latter regard, I have previously noted that a specific Terms of Reference of the Clear/Martin report was to "examine the planning implications of developing the new children's hospital on the existing StJames's Hospital campus if the Player-Wills/BaileyGibson/DCC site (adjacent to the Coombe Hospital) is made available as additional expansion space to allow for decanting of current non-core facilities from the St James's campus and future hospital-related development, as appropriate': I hold a significant and reasonable concern that such decanting to the Coombe Hospital site will inevitably require to occur, but that this has not been considered, confirmed or assessed as part of the wider overall development proposal.

In terms of cumulative impact, Section 18.2.1.27 of the EIS simply states in respect of the decanting programme that '7he permitted buildings are not likely to give rise to significant external environmental impacts in combination or singularly. The decant programme comprises uses that are accounted for in the various topic assessments in this EIS. The demolition of the buildings that are being vacated has been applied for in this application and the impacts of these have accounted for in this document". I suggest that this level of information is wholly inadequate for the Board to undertake cumulative impact assessment, particularly having regard to the obligations for same under the governing Directive, and the provisions of the O'Grianna judgement.

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New Maternity Hospital Section 2.2.6 of the EIS addresses "Emerging Plans for the Maternity Hospital at St. James's Hospital Campus", and notes that "The Department of Health's decision to tri-locate the Coombe Women and Infants University Hospital on the St. James's Hospital Campus was only made in June 2015 when the application for the National Paediatric Hospital was at a vel}' advanced stage". In addition, the Clinical Case report submitted with the application notes that ':4t present the timeline for the development of the Maternity Hospital on the St James's Hospital campus has not been established. No work on the planning of the Maternity hospital has commenced".

Notwithstanding the lack of specific detail of the planned maternity hospital, as per the principles espoused in O'Grianna, it is incumbent upon the applicant to at least attempt a cumulative impact of the current proposal with a reasonable understanding of the likely nature and extent of the future maternity hospital. For example, the EIS is able to confirm that any such Maternity Hospital would be located to the east of the proposed new children's hospital, and therefore cumulative visual impact assessment could have been attempted. In addition, in the absence of such specific proposal, would it not have been reasonable to base any cumulative impact upon the nature and scale of development that currently occurs with the existing Coombe Maternity Hospital? Could this not have formed the basis for calculation of construction and operational traffic movements?

The justification for the absence of such cumulative impact appears simply to be that (a) the decision to tri-locate was only taken shortly (in actual fact two months) before the application was submitted, and that (b) there is insufficient detail. Specifically, the EIS states that '7he Maternity Hospital proposals are at an early stage and there is no permission to build them. Given the absence of information it is not possible to assess the impact of this development, either singly or cumulatively, other than at a vel}' high lever.

In my view, and having regard to the judgement in O'Grianna this cannot justify why cumulative impact assessment of a maternity hospital as part of a tri-location campus appears not even to be attempted. A high-level cumulative impact assessment on the basis of assumed development would have been preferable to no such assessment.

The purpose of cumulative impact assessment is to capture the overall impact of development upon a receiving environment. For example in this case, it is imperative to understand how the profound adverse traffic impact occurring as a result of the existing adult hospital and proposed children's hospital will be further compounded with the future provision of a maternity hospital.

I reiterate my concern that these assumptions are being made solely in order to make a trilocation hospital facility work on an overly constrained site. This is not appropriate, particularly in consideration of the intended cumulative nature and extent, and residual environmental impact, of this tri-location development.

Overall, I am of the opinion that the level of information contained in the application particulars concerning the combination of the proposed children's hospital development even simply with other associated aspects of the development of a tri-location hospital campus at the SJH campus, is wholly inadequate for the Board to undertake cumulative impact assessment. It is also inadequate for the p stand the overall impact that will arise in this receiving environment from the p nrMitS011miCJIII! ~

TIME BY ___ _, Conclusions - I DCT 2015

This application is primarily focussed on ~&Rdfiag_ the rl'\EtiB,;>f tri-loc tion of hospital facilities, with clear messages of complian I 'th internabonal be · e in this regard. Such model of healthcare appears to be entirely a med.

It is considered that this application and EIS is a (reasonable) attempt to justify a misguided Government decision in terms of the siting of such a tri-location healthcare campus. The identified environmental impacts arising, particularly in terms of a profound adverse impact on traffic, derive from the decision to pick a constrained site served by a constrained local road network, which cannot facilitate such scale of development, and traffic arising.

The consideration of alternative sites also is little more than a justification of the Government decision to select the SJH site. Such consideration does not reflect the provisions of the preceding Dolphin report and Clear/Martin report which identified the Coombe Hospital site as being less constrained, and less susceptible to planning risk. The Government decision does not appear to have allowed sufficient time for careful consideration of the issues, risks and weaknesses clearly identified in those reports. The Government decision was also taken without any transparency in the decision-making process, or with any meaningful opportunity for public participation in such environmental decision-making, which is a key pillar (Article 6) of the Aarhus Convention.

The application and EIS concludes that "Inevitably a project of this scale will result in some local impacts. A considerable amount of time and effort has been expended by the relevant authorities in appraising alternative sites for the scheme. This work clearly points to the St. James's as the most appropriate have regard to health care delivery; planning policy and development management considerations".

In actual fact, the end result of this poor approach to decision making by the Government, is a proposal now before the Board that is contrary to principles of proper planning and sustainable development. The proposal relies on unsubstantiated presumptions and assumptions regarding access to the hospital campus by staff and visitors. I hold a reasonable and significant concern that such presumptions and assumptions are reliant upon many externalities that are not within the control of the applicant to effect or implement, such as the enhancement of public transport within the Greater Dublin Area, traffic flow improvements within Kilmainham, and acceptance of altered conditions by hospital staff.

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What is an actual reality is the inability of the local road network between Rialto, Suir Road, Mount Brown, Kilmainham and the Con Colbert Road/N4 to facilitate existing levels of traffic, let alone the likely significant additional traffic that will occur at the children's hospital and overall SJH campus. This will result in both traffic hazard, but of more concern may put patient lives at risk as emergency vehicles and private cars in an emergency situation will not be able to travel with any speed down a highly congested local road network.

It is welcome to note that my concerns are entirely shared by An Bard Pleanala. From its earliest pre-application meetings with the then prospective applicant, the Board raised core issues such as consideration of alternative sites and the constrained nature of the site and capacity for tri-location, traffic impact arising including emergency vehicular access and modal spliVcar parking arrangements.

In particular, the record of Meeting 6 (June 2015) states that:-

"the Board reiterated that it was likely transport and access issues will be a considerable concern in the application and it advised the prospective applicant of the need to have a robust response with respect to such issues. The Board said it would be important the prospective applicant can demonstrate that all target figures are feasible and that assumptions made to base targets and projections are reasonable and explainable. Noting this, the prospective applicant said that it is collaborating closely with the relevant local authorities and the National Transport Authority. With respect to the St. James' Campus it said that the key objective is to ensure that the existing road network can cater for all uses".

The subsequent application and EIS has, in my opinion, not been able to adequately resolve the Board's concerns raised in Meeting 6, and has not been able to ensure that the existing road network can cater for the uses that this orbital route of the SCR currently serves.

Having regard to all the above, I am of the opinion that the proposed children's hospital development, notwithstanding its clear strategic necessity and benefit, is - due to its selected location on a constrained site within a congested local road network - contrary to the proper planning and sustainable development of the area.

Yours faithfully,

h~~

AN BORD PLEANALA TIME ___ av ___ _,

-1 OCT 20\5

L.'\'R·DA'TEO ____ FROM __ "'""

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..

New Children's Hospital:

Further assessment of planning issues in relation to proposed sites

Report submitted to Dr. James Reilly T.D., Minister for Health, by Simon Clear and John Martin

19 October 2012

Contents

Chapter 1 Introduction

Chapter 2 General approach

Chapter 3 Planning assessment of proposed sites

Chapter 4 Planning implications of potential expansion site at South Circular Road

Chapter 5 Recommendations

Glossary of technical terms


Terms of reference: The Review Group chaired by Dr Frank Dolphin submitted its report, which assessed potential sites for the new Children's Hospital, to Minister Reilly in June 2012; the report will inform the decision on location to be made by Government.

In addition to the consideration of planning and other issues contained in the Dolphin report, and in view of the critical importance of minimising the risk of another planning refusal, and to support Government in making its decision on a location, the Minister has decided that a detailed planning assessment of each of the possible sites is required which would:

• be based on the information provided by the hospitals under consideration;

• assess the likelihood of securing planning permission for a I rar:e~~MMd.scD~;,.,~IJI:i~iiS;rt:I:-:A;;~A'!""-----. proposed, a maternity hospital, on each of the sites, having elfMS to all other ~ LA developments proposed for the hospital campuses; - - Y _

1 -----.1 • take account of all relevant planning considerations; - ocr 2015

LTR·DAT~n • draw attention to planning risks, challenges and opportuni~ "1_ and, Wf.l,ere, FROM

appropriate, mitigation measures; • - ----~

• have regard to any relevant An Bord Pleanala concerns, as expressed in their consideration of the previous application for planning permission for this hospital on the Mater campus; and

• make such other recommendations as appear relevant.

The sites to be examined are those proposed by Connolly Hospital, the Coombe Hospital, the Mater Hospital, StJames's Hospital and Tallaght Hospital. In addition, the report should examine the planning implications of developing the new children's hospital on the existing St James's Hospital campus if the Player-Wills/Bailey-Gibson/DCC site (adjacent to the Coombe Hospital) is made available as additional expansion space to allow for decanting of current non-core facilities from the St James's campus and future hospital-related development, as appropriate.

The assessment should provide the clearest possible and the most robust advice to Government on the likelihood of planning refusal on each of the sites. The aim is to support Government in ensuring that, once it has made its decision on a site, the project can proceed securely to completion. The report is required by close of business on Friday 19 October 2012.

Simon Clear and John Martin, both professional planners, were commissioned to carry out this further planning assessment. We were members of the Review Group and received copies of all submissions made to the Group, including site feasibility studies prepared by the major adult teaching hospitals in Dublin.

Important caveat: It is mandatory that An Bard Pleanala will consider the proposed Children's Hospital as "Strategic Infrastructure Development" onder the Planning Acts, i.e. that any planning application will be submitted directly to the Board for decision.

As indicated above, we are required to assess the likelihood of permission being granted for the paediatric hospital (and for a new maternity hospital, where proposed). We wish to clarify at the outset that:

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a) The Board is an independent statutory planning body which carries out its functions in accordance with the rules of fair procedure. This means that it decides an application only after careful and impartial consideration of all the documentation submitted (including an environmental impact statement [EIS] for all Strategic Infrastructure Developments), the submissions made by all relevant parties, and the report of its Inspector.

b) Pending selection of a site by Government, no detailed plans or EIS have been prepared, and neither the relevant planning authority nor members of the public have had an opportunity to comment on those plans.

c) It follows therefore that this assessment can only be of a preliminary nature, based largely on feasibility studies prepared at short notice by the various adult teaching hospitals in Dublin and submitted for consideration by the Dolphin Group. In the case of the Mater site, we have benefitted from being able to consider the Board's decision on the previous application, together with revised proposals prepared by the design team intended to overcome the reasons for refusal of permission.

d) Following site selection, a design team will prepare detailed plans (or revised plans, in the case of the Mater site) for pre-application consultation with the Board, the relevant local planning authority, and other statutory consultees. Those consultations, together with any recommendations arising from the EIS process, will help shape the final design.

AN BORO PLEANALA TIME BY

Chapter 2 General appr

____ ... - ' ocr 2o1s

In strategic national planning terms it is important that a long-term perspective be held on the future suitability for service, adequacy of facilities and capability for change. Change may be technological, collaborative or spatial in nature.

It is essential that the new facility be "future proofed" and that there be significant room for manoeuvre, including spatially, in any new hospital campus arrangement.

Therefore, in spatial planning terms, it would be preferable to find a site on a campus that has room to accommodate expansion of building laterally and additional new buildings over time comfortably within the confines of the planning unit. Filling the campus space available from the outset is not recommended for strategic planning reasons including future proofing.

Site assessments Our assessment is based firstly on the documentation submitted to us as members of the Dolphin Group, and secondly on our experience as planners. Aerial photos showing the location of each of the specified potential sites for the Children's Hospital are included in the Group's report.

For each site, we have identified a range of planning issues which are likely to be considered by An Bord Pleanilla in assessing any planning application. We have assessed how well each site performs in relation to each issue; in some instances, where the performance is less than satisfactory, we have suggested possible mitigation measures. However, as stated in chapter 1, only the detailed design and EIS process is capable of fully identifying problem issues on a particular site and selecting the most appropriate design solution. In some cases, the problem may be of a more fundamental, site-specific nature, and not easily overcome.

Broadly speaking, the range of planning issues includes: • Degree of compliance with development plan objectives. While the Board may

grant permission for a proposed development which materially contravenes the relevant plan, it will only do so if it considers that the overall proposal is in accordance with proper planning and development. To the extent that a proposal significantly breaches plan objectives and normal standards, the risk of refusal is increased.

• Potential adverse impacts on the surrounding area, such as on residential amenity or on the built or natural heritage.

• Ease of access for vehicular traffic and public transport. • Availability of essential infrastructural services. • Amenity considerations.

In the case of the Mater site, we have carefully analysed the Board's decision to refuse permission In February 2012, havir'!g regard to the notes of the pre-application consultations with the Board, the plans and EIS submitted to the Board, the Inspector's report, and the reasons for refusal cited by the Board. We have also taken note of the Board's subsequent response to a request by the National Paediatric Development Board for consultations on a revised proposal, intended to overcome those reasons.

s

Our planning assessment of the potential hospital sites is essentially risk-based; we do not wish to appear to second-guess any future decision by the Board on an application we have not seen.

Finally, in accordance with our terms of reference, we have included some best practice recommendations which apply to whichever site is selected.

Chapter 3 Planning assessment of proposed sites for the Children's Hospital

Introduction In accordance with our terms of reference, planning assessments are provided below in relation to the sites proposed by Connolly Hospital, the Coombe Hospital, the Mater Hospital, St. James's Hospital, and Tallaght Hospital. E · e same planning criteria, and an overall risk assessment is pro de . ~~liPUf.AN~su es which could mitigate planning risk are suggested. TIME BY

1. Site proposed by Connolly Hospital - J OCT 20J5

LTR·DATEO·---FROM Brief site description: The lands available to Con noll Aflealth Campus comp•?~e~-+f-AI ha (hectares) within the existing established hospital cam ed by National Sports Campus Development Agency (NSCDA). The combined tota site comprising c.58 ha is all within State ownership. The Children's Hospital would be located with the NSCDA lands, occupying 16 ha to accommodate 1 08,000m2 hospital area, with 20 hectares designed to provide a parkland setting and park facilities for the children's hospital, to accommodate future expansion of the Children's Hospital and a new maternity hospital. There are no site acquisition costs and the lands are available immediately. The proposed development requires no decanting of existing buildings and no site clearance or significance on-site or external enabling infrastructure, being a greenfield area.

a) Landuse zoning: The land on which the development is proposed is zoned Open Space in the Fingal County Development Plan 2011-2017. While An Bard Pleanala is not bound by development plan zoning when determining applications for Strategic Infrastructure Development (SID), it would minimise any planning risk if Fingal County Council introduced a Variation of their County Development Plan to facilitate hospital development on the Sports Campus lands within the proposed site.

b) Density I plot ratio standards1: With a very extensive campus proposal, plot ratio

will be low and will not be a significant planning risk consideration. Nor will site coverage, for the same reasons.

c) Building height standards: With an extensive land area available no issue of height should arise as a factor in relation to the proposed development. The building design is set out as relatively low - rise building in a series of linked pavilions of 4/5 stories. This is not significantly inconsistent with the scale of existing adjoining buildings. A tall flagship building is a feature at Blanchardstown nearby.

d) Impact on the built and natural heritage: The lands when inspected by the review group were in agricultural use with dispersed clumps of mature trees that give maturity to the landscape. There are heritage buildings in the vicinity, which would not be impacted by the layout proposed, which buildings are located on the National Sports Campus Lands. The buildings would not impinge upon any Natura 2000 designations.

e) Ease of access:

1 Please see Glossary at the end of this report for an explanation of technical terms.

7

• Access by road: The site will be accessed in operational mode directly from the Connolly Hospital road Infrastructure, which has dedicated access directly from the M50 free flow interchange via a slip ramp on the M50/N3 interchange. Underpass access from Blanchardstown Village can be made available via Mill Road for local access. There is a separate staff access via Waterville Road linking from Snugboro Road, with controlled barrier access.

• Access by public transport: There is reasonable access by bus public transport, which can be readily enhanced, with regional bus routes 105, 109, 111 stopping at Blanchardstown on the N3 and Dublin Bus services 37, 38, 38a, 38b. There is access to mainline rail, Dublin- Longford line, via Castleknock train station.

f) Availability of public services: The proposed development places no significant additional demands on the Ringsend Waste Water Treatment Plant in that, any proposal located in the Dublin area will feed into Ringsend. Plans are underway for the provision of a new Regional Waste Water Treatment Plant in Fingal, anticipated for operation by 2020. The Leixlip Water Treatment Plant has adequate capacity to serve the proposed development and any future developments. Local reservoirs provide future water sources to serve the development. Surface water attenuation can be achieved on the extensive lands available within the site and the lands discharge to the Tolka River, which runs in the adjacent valley.

g) Compliance with any other site-specific development plan objectives: None required.

h) Amenity considerations: In an edge-of-city context, the 36 hectare site on the National Sports Campus lands offers an attractive parkland setting and practically limitless scope for future expansion.

Suggested mitigation measures: Mitigation of planning risk primarily relates to ensuring that the development plan context is fully in line with the proposed land use by the time of the date of decision by An Bard Pleanala on the project. The elected members have indicated their willingness in principle to introduce a Variation to the Fingal County Development Plan. Risk mitigation in planning could be eliminated in respect of zoning by such Variation, which is a minimum 18 weeks statutory period, which can run concurrently with project development to planning application. In practice, An Bord Pleanala will determine a planning application by reference to the development plan in effect on the date of its decision, not on the date on the planning application is made.

Overall planning assessment: Low risk.

2. Site proposed by the Coombe Hospital

AN BORO PLEANALA • TIME BY ____ .,

- 1 OCT 2015 the hospital. The Coombe is an existing maternity hospital blft·ffJit~DJeded to~lxpanded rebuilt at some future stage, adjoining lands owned by thEl pity Coun'ell could' oe pw ..~UQ subject to agreement of the Council.

a) Landuse zoning: The major part of the site, together with the adjoining St Teresa's Gardens, is zoned Z14 and is designated as a Strategic Development Regeneration Area in the Dublin City Development Plan 2011-2017. It has the objective to provide for the social, economic and physical development/rejuvenation of the area, of which Z6 would be the predominant uses. While hospital use is not listed among the landuses which are permissible or open for consideration in the Z14 or Z6 zones, the City Council's objective to promote economic regeneration in this part of the inner city would be supported by the substantial direct and indirect employment potential generated by the location of the Children's Hospital. A small area of the site in the SW corner fronting onto South Circular Road is zoned Z6, the purpose of which is to provide for employment opportunities.

b) Density I plot ratio standards: The Children's Hospital with a floor area of 1 08,000 sq metres on a site of 6.2 ha would yield an effective plot ratio of 1.7:1 on the site allocated to that building. The long term development of the overall site with a maternity hospital of 25,000 sq metres and allowance for expansion totalling 165,000 sq metres on the overall site of 8.3 ha would yield an effective plot ratio of just under 2. 0:1. While this is higher than the plot ratio of the lands immediately around it, this plot ratio is not abnormal for urban sites in Dublin.

c) Building height standards: Both the Bailey-Gibson site and the John Player site were the subject of applications for mixed use developments in 2006/2007. Following third party appeals against the decisions of Dublin City Council in 2006/07 to grant permission, permissions were granted on appeal by An Bard Pleanata in April 2008 on both sites, comprising office, retail, residential educational (new primary school) and other uses. The combined gross floorspace in the application was 98,767 sq metres on about 4 ha (Neither permission was implemented). In the Board's decision, a building height up to eight storeys was acceptable. While it is probable that floor-tofloor heights for the Children's Hospital would be greater than those for a mixed use development with a significant proportion of residential, the Board had taken into account the need not to unduly overshadow the playing field, which now forms part of the proposed development site and is no longer an issue. That being so, it is reasonable to assume that a development rising from a lower height at the perimeter up to 7 storeys in the centre is likely to be acceptable.

d) Impact on the built and natural heritage: There are no protected structures on the site, although the Board's permission specified that the front section of the old John Player building was to be retained. There is no Natura 2000 site in the immediate vicinity.

e) Ease of access: • Access by road: There is good access for private cars from the national

network with a reasonably direct route from the M50 at its junction with the N7 (approxi.mately 6 km from the site) via the Long Mite Road. The site has substantial frontages and established entrances on Cork Street, South Circular Road and Donore Avenue, which should also facilitate

· · construction traffic. The proposed development permitted by the Board

9

would have provided for 730 parking spaces; the Children's Hospital could require about 1,000 spaces, depending on the travel management measures proposed.

• Access by public transport: The site is well served by public transport with good access to public transport systems. It is located about 600m from the LUAS line which provides connections to mainline rail stations at Heuston and Connolly and to the Park-and-Ride carpark near the Red Cow M50 junction. Peak time tram frequencies are every 5 minutes, with 10 minute frequencies off-peak. The site also adjoins Quality Bus Corridors along Cork St and the South Circular Rd. and is served by six bus routes that connect it with the city centre and a number of suburbs at frequencies ranging between 10 minutes and one hour.

f) Availability of public services: Water, drainage and gas supply are available. It may be necessary to upgrade the electricity supply dependiAg on the load required, but this could be done during the design I planning I construction period if needed.

g) Compliance with any other site-specific development plan objectives: The inclusion of shops, cafes, etc. within the hospital, and accessible to the general public, could contribute to the mix of uses advocated by the Development Plan

h) Amenity considerations: The size of the proposed site would facilitate the provision of some green spaces at ground level.

Suggested mitigation measures: As outlined at (a) above, while the Z14 zoning does not explicitly support hospital development, we believe that there is a strong case for arguing that such development would not represent a material contravention of the City Development Plan, having regard to the objective to secure the physical, social and regeneration of these brownfield sites (see page 229 of the Plan), and to the fact that the development would represent an extension of the established hospital use on the Coombe site. A statement to this effect from the City Council would be helpful, were the site to be selected by Government. It would also help matters if there could be clarity around the future of the existing maternity hospital - is it to be replaced on adjoining lands owned by the City Council, or could it be located on the St. James's Hospital campus, which the Review Group accepted as being within co-location distance?

Overall planning assessment: Low risk, having regard to the scale of development permitted by the Board on a somewhat smaller portion of the proposed site.

3. Site proposed by the Mater Hospital

Brief site description: The site area allocated is 2.47 ha allocated to the Children's Hospital including the 1861 buildings complex and Hostel. The proposed Maternity Hospital site is 0.53 ha. The new Mater Adult Hospital site is 2.36 ha, including the 'ambulance street', which will be shared with Children's Hospital. The ownership of the site of the original planning application was transferred to the HSE (2.04 ha) within the Mater campus. Th owners of the remainder of the Mater campus, comprising the old and new M , t hospitals and the hostel, will make the 1861 and hostel buildings avail !Er~. d Children's Hospital I Research & Education uses without 0 ~ange ownership. p.." __,.,.0

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- t ocr 2ots a) Landuse zoning: The site was zo JdR~e~ instit11Ji91PI

hospital use) in the current Dublin Development Plan~~~!ll Arising from the judgement of the Hi~~~~~~- ~~~~~==~ zoning, which related to residential development, the City CounCI a ed a Proposal for inclusion in the Development Plan to replace those aspects of the development plan now quashed. The Proposal currently on display for public consultation requires the preparation of an agreed Masterplan, which is to incorporate specified elements, for large development sites. Hospital development accords with the revised zoning objective.

b) Density I plot ratio standards: The building area, including the Children's Hospital, the old Mater Hospital 1861 building and the Hostel building, is a total area of 139,960m2 above ground. This gives a plot ratio of 5.66:1 on a net site of 2.47 ha. The floor area of the Maternity Hospital is 30,375m2

above ground giving a plot ratio of 5.73:1 on a net site of 0.53 ha; it is not clear at this stage that there is capacity on the site for the addition of this hospital. The combined proposals, with 170,335m2 above ground, would have a plot ratio of 5.67:1 on a net site area of 3 ha. This is allied with a high site coverage, which leaves minimal amenity or lateral expansion space around completed buildings. The weaknesses that worked against the Mater site in the original application have not been substantially mitigated by the addition of the 1861 building complex of Protected Structures, which will add site area but not significant building capacity land.

c) Building height standards: A complex building mass design will be proposed, which will require very specific site assessment by An Bord Pleanala. While the height has been reduced to a maximum 10 storey central element, the massing at height is extensive and may continue to present a challenge in a context where there are known important views extending from the city centre, the city approaches and locally important vantage points, such as the Temple Street access. Risk is this context cannot be eliminated.

d) Impact on the built and natural heritage: The 1861 Mater Hospital stone buildings complex is included in the list of Protected Structures and must be dealt with sensitively in the conservation architecture and heritage context. The lands are city centre brown field, with no anticipated impact on natural heritage.

e) Ease of access:

·-

• Access by road: Traffic to the Mater campus will be better distributed as a result of recent and proposed developments. With the completion of the new Adult Hospital the focus for access and emergency will transfer to North Circular Road (NCR). Access for ambulance to the Children's Hospital will be via an ambulance avenue from NCR. Access to underground car parking for the Children's Hospital will be shared at NCR and will also be available from Eccles Street. Taxi concentration will also be dispersed away from Eccles Street. An Bord Pleanala fully assessed the proposed operational access arrangements in the previous planning application as a city centre site; in ·principle, multi-modal access is established and has to be accepted. However, planning risk in this context cannot be eliminated, as the contribution of the proposed maternity hospital to traffic load in the

11

area was not assessed in the previous application, and may serve to strengthen the weight of objections to any future application.

• Access by public transport: The locality is very well served by numerous Dublin Bus routes. Over 1900 buses per day pass and stop within a 5-minute walk of the site. Drumcondra commuter mainline railway station is a 1 0-minute walk.

f) Availability of public services: Availability of all services was demonstrated in the previous application, was not and is not anticipated to be a planning risk.

g) Compliance with any other site-specific development plan objectives: No issues arise.

h) Amenity considerations: The available net area is approximately 3 ha (30,000 sq.m) on the ground. The adjoining lands are occupied by the new adult hospital and the Mater private hospital. When constructed all land within this block will be fully built out at a high plot ratio. Other than incidental spaces there is no land allocated to amenity or structural urban improvement.

Suggested mitigation measures: See "Overall planning assessment", below.

Overall planning assessment: Significant risk. The likelihood of securing planning permission for a paediatric and a maternity hospital on the net area of the Mater campus allocated is not high due to required significant over-development of a compact site to its full capacity in the first wave of development, leaving no room for amenity, urban infrastructure improvement, or capacity for future strategic development. Engagement which has taken place with the Board with regard to the revised proposals earlier this year has clearly indicated the following concerns relating to: -

~ Design, massing, and functionality of the proposed hospital building, together with the issue of visual impact;

~ Proposals for the maternity hospital appear to represent an intensification of the use of the site;

~ Further consideration is needed to be given to the overall levels of activity on the Mater campus;

~ The inclusion of the old Mater building raises considerations in terms of functionality and architectural heritage.

4. Site proposed by St. James's Hospital (SJH)

Brief site description: A site of 6.3 ha is proposed within the SJH campus (near the Rialto Gate) to accommodate both the children's and maternity hospitals, as well as research and hostel facilities. The 6.3 ha site is made up of a number of sub-sites:

• An initial 2.44 ha site for the proposed Children's Hospital, in the south-west corner of the campus

• An adjacent site (currently occupied by the Outpatients Department and a car park) of 1.26 ha which is intended to facilitate future expansion of the Children's Hospital

• A 2.42 ha site north of the internal hospital road near the Rialto Gate, proposed to accommodate a 42,000 sq metre maternity hospital and a hostel for parents of child patients. There are also a number of existing buildings on this site which would ne ::..:.ed;,.----. to be decanted to facilitate redevelopment. j:..~

• A 0.18 site near the entrance off James's Street, for resear ·~iJ~tl There are a number of buildings I uses on the proposed Childr 's I!IM s1te .h ww· ~-need to be decanted prior to redevelopment. These inclu ~~armacy

- \ OC1 1tl\5 12

fRO~ \.'tR·O~'tEO---

Department, staff canteen facilities, HSE child guidance clinic, 270 space staff car park, chapel, administration and out-patient buildings (further decanting would be required to enable construction of the maternity hospital). Dublin City Council has offered to make available a small strip of amenity land adjoining the Grand Canal linear park at the Rialto Luas stop.

a) Landuse zoning: The site was zoned for institutional/hospital use (Z15) in the current Dublin City Development Plan 2011-2017. Arising from the judgement of the High Court in relation to the former Z15 zoning, Dublin City Council adopted a Proposal for inclusion in the Development Plan to replace those aspects of the development plan now quashed. Hospital development accords with the revised zoning objective.

b) Density I plot ratio standards: The 2.44 ha site for the Children's Hospital would yield a plot ratio of 4.4:1, assuming a floor area of 108,000 sq metres. This is relatively high for the area, necessitating relatively high buildings (see below). However, the adjacent 1.26 ha site would permit future building expansion (say 20% or 21,600 sq metres); the overall Children's Hospital site would have a lower plot ratio of 3.5: 1.

c) Building height standards: Most of the existing buildings on the SJH campus are relatively low-rise (up to three storeys), and there are two-storey terraced houses to the west of the Rialto Gate. The SJH feasibility study indicated that the height of the Children's Hospital (on the initial 2.44 ha site) would range from 3 storeys on the western side of the site to 9 storeys on the eastern side, with the aim of minimising adverse impacts on those houses, i.e. the impact of the tall buildings would mainly be within the SJH campus itself. In 2010 An Bard Pleanala granted permission for a colocated hospital on a 1.15 ha site within the site now proposed for the Children's Hospital; the permission is valid until 2015, although it is not proposed to implement it. The permission establishes a number of planning precedents, including a maximum building height only slightly lower than that currently proposed, albeit for a much smaller building (29,600 sq metres). However, the City development plan indicates a general maximum building height of 28 metres in this area, and, while the Board is not bound by this standard, it should be feasible to adhere to it as closely as possible.

d) Impact on the built and natural heritage: There are no protected structures on the proposed 6.3 ha site. Permission was granted by An Bard Pleanala in 2010 for the demolition of the late 19th century chapel within the 2.44 ha site. No part of the site is affected by nature conservation objectives. Only the northern and eastern parts of the SJH campus lie within the zone of archaeological interest as shown in the City development plan, but it would be prudent to ensure archaeological oversight during any development within the 6.3 ha site.

e) Ease of access: • Access by road: At present, public vehicular access to SJH is from James'

Street, with exit only via the Rialto Gate; this measure was introduced to prevent rat-running through the campus. Access to the Children's Hospital and maternity hospital will be permitted through the Rialto Gate, which is about 6 km from the Red Cow interchange on the M50. SJH has held meetings with the City Council regarding traffic access to the campus, resulting in the following proposals:

o An additional road lane from the Ri.m~~!"t!,...,tef!!le-4MB-U~~u&b Circular Road as the road travels to ard~cfil~8Q EANALA

o A new vehicular entrance at Mount r~ which wouldv emove sam of the traffic currently entering off Ja es's Street.

· · - 1 OCT 20t5

LTR·OATED FROM Pl --~

However, the fact that the long, linear campus has only one through route is likely to create difficulties for construction traffic for such a major development.

• Access by public transport: The SJH campus is exceptionally well served by public transport. The Luas Red Line trams link the campus (which has 3 stops) with Heuston and Connolly mainline rail stations, Busaras, and the Park-and-Ride site at Red Cow; the Rialto stop is immediately adjacent to the proposed Children's Hospital. There are also a number of Dublin Bus services which enter the campus.

• Parking: It is proposed to provide a total of 1500 basement parking spaces -750 each under the children's and maternity hospitals; however, about 270 spaces would be reserved to replace the existing staff spaces near the present Hospital 7, leaving a balance of 1230 spaces. It is understood that there are about 1290 spaces on the current campus; the net addition of 1230 spaces would bring the total to 2520, which is c. 1000 more than the upper limit envisaged in the non-statutory SJH Development Control Plan. Dublin City Council has indicated to SJH that the campus could accommodate about 2000 spaces.

f) Availability of public services: : lnfrastructural services are available on site, although a number of existing services will have to be diverted to facilitate redevelopment. An upgraded high voltage electricity connection may be required, but this could be provided (if needed) within the design I planning I construction period for the Children's Hospital.

g) Compliance with any other site-specific development plan objectives: Not applicable.

h) Amenity considerations: There is a linear park (shared by the LUAS line) along the former Grand Canal, to the south of the SJH campus. It is proposed to remove some or all of the existing boundary wall, which would open up views southwards. Feasibility drawings for the Children's Hospital also show landscaped spaces between the 3-storey wings of the hospital at ground level.

Suggested mitigation measures: The nature and location of the site pose a number of planning issues which would need to be resolved if the planning risk is to be reduced:

• Building height: A Children's Hospital building of up to 9 storeys is proposed on the initial 2.44 ha site (i.e. without adding the proposed adjacent expansion site of 1.26 ha), which would be about 10m higher than the City Council's guideline maximum of 28 m in this area. While the Board is not bound by the City development plan, and while there is an existing permission on the site with buildings up to 35 m high, 9-storey buildings could appear visually obtrusive and I or could cause overshadowing to adjacent buildings. It is therefore recommended that the height be reduced to 6 I 7 storeys by increasing the site area by at least one hectare within the proposed expansion area of 1.26 ha, although this would entail decanting of existing hospital buildings. Ideally, a revised master plan setting out a clear vision for the entire campus, including the proposed new hospitals, research and hostel facilities, should be prepared prior to the design of the new developments, and agreed with Dublin City Council.

• Access: Firstly, to reduce the traffic impact on the local road network, the overall extent of parking on the SJH campus would have to be limited to about 2,000 spaces. In order to provide for essential patient I visitor pj~~p· r~ for the all of the existing and proposed hospitals on the cam ' ~ high level of existing staff parking must be r arget through travel management plans which are cu en~t\i p ace. Tfih"

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parking layout, incorporating new vehicular access points to the campus, would form a key element of the masterplan suggested above. Secondly, a detailed construction access programme would need to be agreed in advance with Dublin City Council to avoid undue disruption, especially to the operation of the SJH campus itself; a temporary construction access may be needed.

Overall planning assessment: There would be a significant risk if the site of the Children's Hospital were confined to the initial site of 2.44 ha, i.e. without including the proposed expansion site of 1.26 ha. The initial site would result in buildings which are likely to be of excessive height. If the site can be enlarged to a minimum of 3.5 ha (within the overall site of 6.3 ha as put forward by SJH), the planning risk can be reduced to a moderate level, having regard to the favourable zoning objective for the SJH campus and mitigation measures.

5. Site proposed by Tallaght Hospital

Brief site description: The concept of a Tallaght Medical Quarter is jointly proposed by South Dublin Co. Council and Tallaght Hospital. The idea is that a tri-located Children's Hospital could form the centrepiece of a medical district based in adjacent commercial zones which could accommodate related research and biomedical clusters. The site is 6.6 ha in area. 3.16 ha (located east of the existing hospital entrance) would be allocated to the Children's Hospital, 1.18 ha to the maternity hospital, and 1.33 ha reserved for future expansion. The remainder is taken up by the hospital entrance road. The site of the Children's Hospital is Ushaped, and wraps around a mixed-use residential I community development known as Exchange Hall, which ranges in height from 3 to 6 storeys.

a) landuse zoning: The site Is zoned for town centre uses, including hospital development.

b) Density I plot ratio standards: South Dublin Co. Council (which co-sponsored the concept of a Tallaght Medical Quarter with Tallaght Hospital, and which owns part of the site) estimated in its submission that the overall site of 6.6 hectares could accommodate about 180,000 sq metres in accordance with the Town Centre local area plan. This exceeds the estimated 165,000 sq metres required to accommodate the Children's and maternity hospitals, as well as facilitating future floorspace expansion.

c) Building height standards: Indicative plans submitted by the Council and Tallaght Hospital propose a maximum height of 9 storeys for the Children's Hospital. The local area plan would facilitate a landmark building up to 10 storeys on the site, provided that the height did not exceed 50m above ground level, as Tallaght Town Centre is located within the runway approach to Casement Aerodrome which limits the height of buildings. Allowing for an average of 4.3m per floor, the indicative height of the hospital is below this limit.

d) Impact on the built and natural heritage: There are no protected structures or Natura 2000 sites on or near the proposed hospital site.

e) Ease of access: • The site is accessible from the M50 (junctions 9, 10 and 11), from the N7

(Kingswood and Newlands Cross junctions), and the N81 Oublin-Biessington road. According to figures supplied by th , ""nr .~ 6

... , ··~ - I population is within 1 hour's drivetime of T ~~~~~ ~fiflf!AfM~riv , and 91% within 3 hours' drive. There arE ,-fl¥bsals to ,upfide Newlanc s Cross to a grade-separated junction.

- 1 OCT 2015 5

LTR·DATED FROM PL ----~

• Tallaght Hospital is served by the Luas Red Line, which provides frequent services to Heuston and Connolly mainline rail stations, Busaras, and the Park-and-Ride at Red Cow. Quality Bus Corridors connect Tallaght town centre to the city centre, Blanchardstown and Dun Laoghaire. Again based on figures supplied by the proposers, over 35% of the population of the greater Dublin area can access the site within 1 hour by public transport, and almost 60% within 80 minutes.

• The existing hospital entrance road would have to be re-aligned to the west, creating a 0.73 ha plot of land which would be used initially as a surface car park and ultimately to provide expansion capacity for the Children's Hospital.

f) Availability of public services: The site is capable of being fully serviced.

g) Compliance with any other site-specific development plan objectives: not applicable.

h) Amenity considerations: There is no green space in the immediate vicinity of the proposed Children's Hospital.

Suggested mitigation measures: Alternative access to Tallaght Hospital would require to be provided in advance of any works required to re-align the existing hospital entrance.

Overall planning assessment: Low risk.

Summary table of overall planning assessments:

Site proposed by Connolly Hospital Low risk Site proposed by the Coombe Hospital Low risk Site proposed by the Mater Hospital Significant risk as the effective

building site is limited to 2.5 ha Site proposed by St. James's Hospital Significant risk if the site of the

Children's Hospital is limited to the initial 2.44 ha area; moderate risk if the site area is increased to at least 3.5 ha (within the

_proposed overall site of 6.3 ha) Site proposed~ Tallaght Hospital Low risk

low risk: A competently-prepared planning application would have a reasonable expectation of obtaining permission. Moderate risk: While the proposed development is considered acceptable in principle, identified planning issues would need to be mitigated during the planning and design process. If this is achieved, the risk level would be reduced to low. Significant risk: While the proposed development is considered acceptable in principle, it is not clear at this stage If all of the identified planning issues are capable of being resolved satisfactorily, having regard to inherent site restrictions.

Hospital Connolly Coombe Mater StJames Tallaght

Land use Open Space Z14; SRZ Z15: Z15: Town Centre zoning Institutional Institutional

Density Low Medium Very High High Medium Plot ratio Low< 1:1 1.7:1-2:1 5.73:1 ; 4.4:1 ; 3.5:1 <3:1

5.67:1 Building Low rise 8 storeys Risk 8 storeys 1 0 storeys to Height permitted identified permitted 50m limit Standard Built & Natural Nil Nil Nil Nil Nil Heritage Ease of Access: (a) Car (a) Very good (a) Good (a) Good (a) Good (a) Good

(b) Public (b) Moderate (b) Good (b) Good (b) Very good (b) Good

Transport (best)

Availability of Public " " " " " Services Compliance No issues Mixed use in No issues No issues No issues Other Devt. schemes Plan Objectives Amenity Excellent Good Poor Can be Poor/ Consideration improved moderate Mitigation Devt. Plan Devt. Plan Numerous Masterplan Access Measures variation zoning amenity improvement

/commitment improvement Overall Low Low Significant Significant Low Planning Risk risk as the risk if the site Assessment effective of the

building site Children's is limited to Hospital is 2.5 ha limited to the

initial 2.44 ha area; moderate risk if the site area is increased to at least 3.5 ha (within the proposed overall site of ~.,

. ~ . AN ~ORO PLEA" ALA t TIME BY

.,

- 1 OCT 2015 '

LTR·OATED FROM

PL 17

Chapter 4 Planning implications of potential expansion site at South Circular Road

Our terms of reference require us to "examine the planning implications of developing the new children's hospital on the existing StJames's Hospital campus if the Player-Wills/BaileyGibson/DCC site (adjacent to the Coombe Hospital) is made available as additional expansion space to allow for decanting of current non-core facilities from the St James's campus and future hospital-related development, as appropriate."

Zoning objective As stated in the previous chapter in relation to the site proposed by the Coombe Hospital, the lands off the South Circular Road are comprised of the disused Players Wills and Bailey Gibson factories (4.3 ha) and former playing fields owned by Dublin City Council (1.9 ha). The major part of the site is designated as a Strategic Development Regeneration Area in the Dublin City Development Plan 2011-2017. It has the objective to provide for the social, economic and physical developmenVrejuvenation of the area, of which Z6 (the purpose of which is to provide for employment opportunities) would be the predominant uses. A small area of the site in the SW corner fronting onto South Circular Road is zoned Z6.

We have identified that the employment potential of hospital development rendered such development compatible with the fundamental objectives of the City Development Plan for the area, although hospital use is not explicitly listed among the permissible or "open for consideration" uses in zones Z14 or Z6. While this argument was identified in the context of a potential site for the Children's Hospital, we consider that it applies equally to any hospitalrelated uses and activities which might be decanted from the St. James's Hospital (SJH) site, should the lands at South Circular Road be acquired as a strategic land bank. The likelihood that such developments could be low-key in nature and would have a significantly smaller footprint than the 108,000 sq metre Children's Hospital, would facilitate a more open and permeable layout on the lands.

Potential strategic land bank The report of the Review Group noted that there are a number of possible solutions that could build on the strengths of the proposals presented by SJH and the Coombe Hospital, given their proximity to each other.

Should the Government select the SJH site as the location of the Children's Hospital, we are satisfied that the overall 6.3 ha site being offered is capable of accommodating both that hospital and a 25,000 sq metre maternity hospital, together with a further 32,000 sq metres expansion capacity, subject to satisfactory resolution of the planning issues identified in the previous chapter.

Should the Government also decide to acquire the 6.2 ha site off the South Circular Road as a strategic land bank, we believe that this would not only significantly enhance the planning and development context for the two new hospitals, but would also offer a more sustainable future for the entire SJH campus (and potentially also for the Coombe Hospital, given its proximity to the 6.2 ha site).

We recommended in chapter 3 that if the Government decides to locate the Children's Hospital at SJH, one of the first planning ·actions should be the preparation of an up-to-date master plan setting out a strategic vision for the overall campus, in order to provide a coherent context for the accommodation of detailed plans for the Children's Hospital and Maternity hospital. This master plan, developed with a view to producing a medical cam1-1w...-~ that is generou~ in amenities. as well ~s cli~ical excellence, co~ld (inter alia) id. · . , ~1).~1>.~

• A hospital campus 1n the c1ty w1th space and env1ron · isP~t as medicine and research I education I" &'I

't\tAE .......------" 'l\)\~ .. , oc, '" 1s fRO~

\.~~·Ott.~EO~_....,.,--::~:::::::::::=::=::_...,.

• Hospital uses which need to be decanted to make space for the new Hospitals; • Existing buildings which, on account of their condition and I or low density, require to

be re-developed; • Hospital uses which, while ancillary to the primary hospital buildings, could be

located adjacent to but not necessarily on the campus; and • Surface car parks which make inefficient use of valuable inner city land.

We believe that preparation of a master plan for the SJH campus could be carried out in tandem with preliminary studies for the planning application and environmental/ appropriate assessments required for the Children's Hospital, including a detailed programme of decanting of existing uses and buildings on the proposed hospital site.

Creation of this land bank would significantly benefit the general approach to future-proofing of new hospital development referred to in chapter 2 above.

Tt:eN BORo PLEANALA - BY -

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19

Chapter 5 Recommendations

Our terms of reference encourage us to provide recommendations which may facilitate the planning process, regardless of which site is selected by Government.

1. Early consultation with An Bord Pleanala The Board may give advice to prospective applicants for Strategic Infrastructure Development (SID), including advice regarding "what considerations, related to proper planning and sustainabl~ development or the environment, may, in the opinion of the Board, have a bearing on its decision in relation to the application• (Section 37B of the Planning and Development Act, 201 0). While such consultation took place in relation to the original application on the Mater site, it happened too late in the design process, because prior to the coming into force of the 2010 Act, preapplication consultation had already taken place with Dublin City Council, and work on the design was well advanced when the Act required the application to be submitted to the Board. It is strongly recommended that in the case of any new application, consultation with the Board should be arranged at the outline design stage, so that any planning or environmental issues raised by the Board may be fully addressed in the planning application and I or environmental impact statement (EIS) and Appropriate Assessment.

2. Consideration of alternative sites in the EIS Under EU and Irish legislation, an EIS (which is mandatory for Strategic Infrastructure Developments) must contain an outline of the main alternatives considered by the applicant from an environmental perspective. In the previous application on the Mater site, the Board's Inspector was somewhat critical of the lack of appraisal of alternative sites, although this was not reflected in the Board decision itself. However, had permission been granted, such a decision might have been the subject of a judicial review challenge which, even if ultimately unsuccessful, could have delayed the project. To reduce the risk of such a challenge arising from any future decision, it is recommended that the EIS should address the issue of alternative sites from a planning I environmental perspective, including relevant material from the Dolphin Group Report. It is not necessary to show that the site selection process was based primarily on such factors - particularly when clinical outcomes may be more influential - but their contributory role should be acknowledged.

3. Urgent care centre(s) As stated in the Review Group report, it is estimated that about 80% of patients expected to attend the Emergency Department (ED) of the Children's Hospital will come from the greater Dublin area; data from the three existing children's hospitals in Dublin shows that about 90% of ED patients arrive by car. As the new hospital could not cope on its own with large numbers of ED patients, the vast majority of whom do not require tertiary-level care, about half of them will be treated in one or more urgent care centres in Dublin. The public perception of the oral hearing into the original planning application in relation to the Mater site was dominated by alleged difficulties in accessing that site by car; it would greatly clarify matters in a subsequent application if the potential traffic impacts of any selected site could be distributed between that site and the site(s) of one or more urgent care centres, throu h Government decision on the role, location and timing of such a cent P,.LA

,. N eoRO pt.; "" eY ____ , 1\ME----~

4. Planning peer review service _ \ OC1 1\l\S

..

Tender procedures issued by many government departments for large-scale infrastructure developments do not identify the planning service as a discreet discipline in the preparation of proposals that would be brought to An Bord Pleanala as SID. When queried the awarding departments have indicated that the planning service will be seen as part of architectural or other technical services.

Planning peer review is a high level independent service that is not embedded in the design teams, which can identify at an early stage that the development is proceeding on lines contrary to those that could be acceptable to An Bord Pleanala as a "planning body". National agencies such as National Roads Authority and the Rail Procurement Agency now use peer review planning professionals to independently scrutinise draft documents in preparation on planning, EIS & Appropriate Assessment parameters, to receive feedback at an early stage to ensure the project remains on track within the area of focus of An Bord Pleanala.

It is suggested that all government departments involved in strategic infrastructure developments that will be dealt with by way SID should consider the appointment, separately from other tenderers, of a senior, highly qualified and independent planner. In this context it is envisaged that peer review planners would have approximately twenty years professional experience after qualification and continuous professional engagement directly in the planning sphere in Ireland.

Simon Clear John Martin

19 October 2012

21

Glossary of technical terms

Density of development: This reflects the intensity of development (in terms of both structures and land use) on a given site. For non-residential development, two measures of density are commonly used in development plans:

a) Plot ratio: The amount of floor area of buildings at ground level and above (i.e. excluding any basement levels) is divided by the net site area; the result is expressed as a ratio. For example, a building of 20,000 sq metres on a site of one hectare (or 10,000 sq metres) would have a plot ratio of2.0:1. A high plot ratio, typically found in inner city areas, would imply a higher number of storeys than a low plot ratio.

b) Site coverage: This measures the ground floor footprint as a percentage of the site area. Thus, in the example given above, suppose the 20,000 sq metre ·building consisted of four storeys of 5,000 sq metres each on a one-hectare (10,000 sq metres) site: the site coverage at ground floor level would be 50%. Again, higher site coverage is the norm on inner city sites.

Environmental impact statement (EIS): This is a document prepared by the developer for certain forms of major development specified in an EU Directive and Irish planning legislation, which is submitted with planning applications for such development. The purpose of an EIS is to identify potential significant adverse impacts on the environment, including impacts on human beings, and to propose measures aimed at eliminating if possible, or at least mitigating, significant impacts. It is a statutory requirement that each EIS must include a non-technical summary. A copy of the EIS must be made available for public inspection and comment before the application is decided, and the planning authority and I or An Bard Pleanala must take the EIS, and any submissions relating to it, into account in reaching its decision.

Strategic Infrastructure Development (SID): The 2006 Planning and Development Act introduced the concept of SID, whereby certain classes of proposed development were deemed to be of strategic national or regional importance; planning applications for specified classes of SID are required to be submitted directly to An Bord Pleanala, rather than being submitted in the first instance to the local planning authority, and then possibly being the subject of a planning appeal. The 2010 Planning and Development Act added certain types of health infrastructure (including hospitals) to the SID list.

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. .

Review Group on the National Children's Hospital

Report to the Minister 7 June 2012

1

2

Foreword by Or Frank Dolphin, Chairman of the Review Group

It is with great pleasure that I present the Minister for Health, Dr James Reilly T.O., with the report of the Review Group on the National Children's Hospital.

Our work began at the request of the Minister following the refusal of An Bard Pleam31a last February to grant planning permission for the hospital. Our Group, appointed by the Minister, involved a highly motivated team of experts determined that this project should go ahead as quickly as possible. They have given unstintingly of their time, their knowledge and their expertise. It has been an honour to work with them on this project which is of such fundamental importance. I would like to thank all concerned for their huge commitment over the punishing schedule of the last ten weeks.

I would also like to thank all of those groups and individuals who met with us and made submissions to us, often at very short notice, and this report should be read in conjunction with those submissions.

I believe that the work of the Group provides the groundwork on which a viable decision can be made. While it was not our role to select the site we have taken care to consider the most viable and practical options available.

Let us not forget that this issue is first and foremost about children and more importantly about children who are ill and their families. It is about giving them the hospital they need and the services they deserve. It is above all about the adults of this nation committing unambiguously to our children. It is a once in a lifetime opportunity to get this right.

Or Frank Dolphin

~ bt£f-Chairman

3

Acknowledgements

Special thanks are due to the following, who provided assistance and support to us in our

work over the past ten weeks.

• Ms Clare McGrath, Commissioner of the Office of Public Works, and Mr liam Egan,

Assistant Principal Architect and Mr Gerard Bourke, for preparing technical

assessments of proposed hospital sites

• Mr Niall Cussen and Mr Catha I Black, Department of the Environment, for their

assistance with preparation of maps of the proposed hospital sites

• Ms Rachel Kenny, Senior Planner, and Ms Fionnuala May, County Architect, Fingal Co.

Council, and their colleagues in the County Council, who prepared detailed design and

planning briefings on a range of possible sites within the County, and particularly in relation

to the site adjoining Connolly Hospital

• Eddie Conroy, County Architect, and Paul Hogan, Senior Planner, South Dublin Co. Council,

and their colleagues, for their detailed design and planning feasibility study of the proposed

site adjoining Tallaght Hospital

• John O'Hara, Deputy City Planner, Dublin City Council, and his colleagues in the Planning

Department, for advice on possible sites within the City

• Mr Paul de Freine, HSE Estates, who provided assistance and information to the

Group

• Ms Simonetta Ryan, Ms Celeste O'Callaghan, Ms Frances Norton and Ms Sinead

Curristan, Department of Health who provided the secretariat

We also want to particularly thank the following members of the Youth Advisory Council,

who took the time to meet with us and to give us their views and insights on the new

children's hospital:

• Ms Erika Shine

• MsAine Fox

• Mr Leon Ennis

• Ms Sinead McGuiness

• Mr Kevin Brennan

AN BORD PLEANALA TIME BY ----.a

• Ms April McCabe - 1 OCT 2015

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4

on its environment. The capacity of the site to accommodate the building and future

potential developments was also considered. Traffic, accessibility for ambulances and cars,

commuting options for staff, and parking were all considered. Specific scales of parking

were considered as were their impact on the local road network. Up to 90% of children

presenting at the Emergency Departments of the three existing children's hospitals

currently arrive by car.

The group received a large number of unsolicited site offers. It is important to emphasise

that these were unsolicited. In some cases, offers of land were made free of charge and we

would like to acknowledge the generosity of the landowners involved. However, only sites

that were supported by a Dublin Academic Teaching Hospital were considered.

Should the Government decide to choose a greenfield site option, we believe that this will

need to include an adult teaching hospital and may have ramifications in terms of zoning,

planning, procurement and time.

We note the National Paediatric Hospital Development Board was established by Statutory

Instrument in 2007. Its brief has been to build the hospital on the Eccles Street site. It does

not have wider responsibility for the governance, management and integration of the new

institution. We believe such integration would better serve the overall project

One of the outcomes of this review has been to highlight the potential for cost savings for

this project. On the other hand, in our research we noted that the ICT budget for this project

was not included in the original envelope. We strongly recommend that it is now

incorporated given the level of savings that have been indicated to us and the critical role of

ICT in the future functionality of this hospital and its integration with the numerous

satellites that will be part of it. We believe this to have been a significant omission in this

project to date.

The group also met a wide range of interested parties, some of whom asked to meet us and

others who were invited because of their specialist knowledge and expertise. In all we met

21 groups (see Appendix 1}. For our part, we found this exercise extremely informative

because in many cases it provided expert opinion and practical insights and perspectives.

The groups varied from professional bodies to young people who are patients of the existing

children's hospitals. We also received many written submissions and letters. There was a

consistent message of urgency and a unanimous desire to see the new children's hospital

built.

This decision is not only about site location. It is also about vision, it is about the service that

will accrue from that vision and about how it improves the care of our children. It is a

complex decision.

AN BORD PlEANALA TIME BY

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Executive summary

Our Review Group was appointed in March 2012 to advise the

options for the new children's hospital, following the refusal by ~A~n~B~o~r~~~~~~~;d planning permission for the proposed National Children's Hospi~al at a site on Eccles Stree .

We were given specific terms of reference and a short deadline.

Over the past six years, there have been a number of reports and reviews relating to the

proposed new children's hospital (McKinsey 2006, Joint Task Group 2006, KPMG 2008,

Independent Review 2011}. In all cases, the reports and review concur that co-location with

an adult teaching hospital and preferably tri-location with a maternity hospital is the

optimal choice. Having reviewed the reports already prepared and considered their analysis

and opinions, and having also consulted with a wide range of professionals in the field, we

are also of the view that co-location is essential and tri-location optimal. We recommend

that the Minister remains on this path.

A new children's hospital is not only a significant building that will serve our children for

many decades. It also embodies our vision of care and health of our children. From here

international best practices are established, while at the same time a full range of local and

national services are provided. Also, co-location with the right partner(s) should enhance

synergies and opportunities for all, creating a dynamic powerhouse of research, innovation

and education. We developed a process for site selection which prioritised co-location with

an existing adult teaching hospital lin Dublin (70% of the children attending the new hospital

will come from the Greater Dublin Area.)

We wrote to six Dublin teaching hospitals inviting a proposal for the new children's hospital

to be located on their site. We also received a proposal from the Coombe Hospital which

was supported by StJames's Hospital. St Vincent's Hospital chose not to submit. The

proposals from the hospitals were considered in detail under the terms of reference

specified by the Minister. We would like to acknowledge the large volume of work and

excellent proposals that we received within a very short period of time. We acknowledge

that these are indicative proposals requiring further scoping and analysis if selected.

We assessed each of the proposals having regard to our terms of reference. We also visited

the sites. Having reviewed the sites, and the options presented to us, we are in a position to

present these options to the Minister. Each option brings with it strengths and weaknesses.

In all except two cases, the land is in the ownership of the State or its agencies. Some have

clear sites while other sites require preparation. While some hospitals bring an immediate

range of specialties and research capacity, others bring flexibility and longer term

opportunities.

Having reviewed in detail the An Bord Pleamila decision of 23 February 2012 we believe it is

important to consider the scale and size of this building and the impact such a building has

5

Table of Contents

TIME ____ BY ___ --1

Part 1 Introduction and background to the rep rt - 1 OCT 2015

Part 2 Assessment criteria

4. Children's healthcare issues 22 5. Research and education issues 27 6. Access, planning and design issues 30

7. Cost and value for money 34

8. Project time lines 37 9. Guiding principles 40

Part3 Assessment and recommendations

10. Outline of unsolicited site offers 44

11. Assessment of strengths and weaknesses of co-location proposals 48

12. Identification of risk factors and suggested mitigation measures 74

13. Conclusions and recommendations 78

Appendices

1. list of meetings

2. Sample of letters to hospitals

3. Correspondence from An Bard PleancUa to NPHDB

4. Greenfield and urban sites: note on the cost issues

5. A note on planning context

7

8

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Part 1

Introduction and background to the report

9


Appointment of Review Group

The Review Group, chaired by Dr Frank Dolphin, was appointed in March 2012 by the

Minister for Health, Dr James Reilly, T.D., to consider the implications of the decision of An

Bord Pleamila in February 2012 to refuse planning permission for the proposed new

children's hospital on a site at Eccles Street, Dublin 7.

Membership of the Review Group

Dr Frank Dolphin (chair)

Mr Simon Clear

Mr Michael Collins

Professor Jonathan Hourihane

Professor B.G. Loftus

Mr John Martin

Professor Clodagh O'Gorman

Ms louise Shepherd

Professor Owen Smith

Terms of Reference of the Review Group

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• To inform itself about the planning considerations and processes affecting this

project.

• To consider the different options which now exist for progressing the construction of

a national children's hospital having regard to-

(a) Government policy on the delivery of health services, including accessibility and

paediatric services in particular and best clinical practice considerations,

(b) the cost and value for money considerations of the different options,

(c) the likely timelines associated with the different options,

(d) the implementation risks associated with the different options.

• To advise him, in the light of these considerations, on the appropriate next steps to

take with a view to ensuring that a national paediatric hospital can be constructed

with minimal delay.

• To report to the Minister within 56 days of the first meeting of the group.

Structure of the report

The report is structured to address the Terms of Reference as follows.

10

Part 1 outlines Government policy on the delivery of health services, with particular

reference to the new children's hospital, and sets out the history of the project leading up

to the refusal of planning permission in February 2012. It analyses the planning implications

of that decision in relation to the Eccles Street site. It outlines the Group's approach, which

entailed considering a wide range of potential sites. The Group devised certain criteria for

assessing the suitability or otherwise of all suggested sites. The Group's consideration of the

complex issues involved was greatly facilitated by meetings with a large number of groups

and individuals with relevant expertise and/or involvement in paediatric healthcare and

research.

Part 2 sets out the detailed issues relating to children's health, planning and design, access,

cost and value for money and programme delivery. It concludes with a set of guiding

principles developed by the Group following its consideration of these issues.

Part 3 applies the Group's guiding principles to all the suggested sites and then assesses the

strengths and weakness of those sites which meet the fundamental requirement of offering

co-location with an adult hospital and at least potential tri-location. Implementation risks

associated with the different categories of site locations are identified, and appropriate risk

mitigation measures are proposed. Finally, the Group's conclusions and recommendations

are set out.

Supplementary information is provided in the Appendices and at www. [to be completed].

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11

-1 AN BORD PLEANALA

6'1 -TU.\E - --

I

- \ OCT 20\5

Chapter 2 The new children's hospital: policy and .... l!n FROM __ _,

•u ...... - - .. , :Jlf e•taftts -

PL Introduction

The purpose of this chapter is to outline Government policy in relation to the new children's

hospital as it has developed since 2005, and to set out the chronology of events which

preceded the submission of a planning application to An Bard Pleanala in 2011. The final

section will analyse the planning implications for any revised application on the site at Eccles

Street of the Board's reasons for refusal.

Children's Health First, 2005

In 2005 McKinsey and Co. were engaged by the Health Service Executive (HSE) to advise on

the provision of tertiary paediatric care nationally and the provision of secondary care for

the Dublin area. Their report Children's Health First in 2006 recommended that:

• The population of Ireland and projected demand could support only one world-class

tertiary centre. This centre would have the following attributes:

o It would be in Dublin

o It would ideally be co-located with a leading adult academic hospital, to

capture relevant sub specialist and academic linkages

o It would have space for future expansion, including education and research

facilities

o It would be easily accessible through public transport and the road network.

• The centre would be at the nexus of an integrated national paediatric service, and

would also provide care for all the secondary needs of the Dublin area.

Decision to build on the Mater campus, 2006

The Government accepted these recommendations in 2006. A Joint HSE/Department of

Health and Children Task Group was established to advise on the optimum location in

Dublin of the National Paediatric Hospital, as recommended by McKinsey. Although at that

stage the outcome of the later KPMG review was not known, the Task Group decided that

potential sites would need to demonstrate the capacity to accommodate a maternity

hospital on site, as well as being co-located with an adult teaching hospital. Following a

consultation process with the six Dublin adult teaching hospitals and with patient

advocacy/representative groups, the Task Group advised that the new National Paediatric

Hospital should be built on the Mater Hospital campus. This recommendation was endorsed

12

AN BORD PLEANALA TIME ___ BV ___ -t

- 1 OCT 2015 by the Board of the HSE and by Government. RKW, an estab t~Ri~~hcare p~g

consultancy, was engaged to prepare the high level framew< r~rief for the new hos::-:pr:t!'!!c;a:'f"e .. -. --t

National Paediatric Hospital Development Board established, 2007

The Government established the National Paediatric Hospital Development Board (NPHDB)

in 2007 to deliver the project.

The RKW report was presented to the newly established NPHDB. RKW reviewed demand

and capacity requirements, appropriate space standards for a world-class tertiary hospital

(including research and education), and the preferred physical configuration of services on

the Eccles Street site. The RKW report provided the framework for the preparation of a

detailed design brief in 2009.

KPMG report on maternity and gynaecology services in the greater Dublin area, 2008

In 2007 consultants KPMG were commissioned by the HSE to review maternity and

gynaecology services in the Greater Dublin Area. Their report in 2008 recommended that:

• Maternity services should be co-located with both adult acute services (to allow the

mother access to a full range of medical and support services should the need arise)

and paediatric services (when foetal or neonatal surgery or other interventions are

required), i.e. tri-location of maternity, paediatric and adult services.

• Three new facilities should be developed in Dublin to deliver maternity and

gynaecology services. Two of these facilities should be co-located with an adult

hospital (Tallaght and St. Vincent's Hospitals) and one tri-located with the proposed

National Paediatric Hospital on the Mater campus at Eccles Street.

While the planning application submitted in 2010 for the new children's hospital did not

include the proposed new maternity hospital (to replace the services currently delivered at

the Rotunda Hospital), provision was made for that hospital within the Mater campus on a

site immediately adjoining the new children's hospital, to facilitate corridor access between

them.

2009

An integrated design team was appointed by the NPHDB to prepare a planning application

and environmental impact statement. Initially, pre-planning consultation meetings were

held with Dublin City Council which is the relevant planning authority for the site, but

changes to planning legislation in 2010 required that planning applications for such major

13

healthcare projects, being strategic infrastructure developments, be submitted directly to

An Bord Pleanala.

2010

Pre·planning consultations with Bord Pleanala officials took place in late 2010 and early

2011. The officials advised that the pre-application process was not designed to assess the

particular planning merits of the proposed development but indicated that issues around

the size and mass of the proposed building and the restricted nature of the site would need

to be addressed in the planning application.

In 2010, the NPHDB published the National Model of Care for Paediatric Healthcare in

Ireland, which included the provision of an Ambulatory and Urgent Care Centre (AUCC) at

Tallaght Hospital. In line with international best practice, the model of care requires a shift,

where appropriate to the patient' s condition, from inpatient care to ambulatory or short

stay care, and from hospital-centred care to home-based care. Inpatient care should be

reserved for those children with acute severe illnesses and chronic complex conditions. The

National Model of Care envisages ambulatory care- including outpatient clinics, surgical

and medical day care procedures, nurse specialist and allie ~'P!I:AN~ being provided at the new children's hospital on the Mater the AUCC iraVCt llaght an

at regional and local hospitals throughout Ireland. - t OC1 20\5

2011

The Minister for Health commissioned an Independent Revie~P~Lg:a;a:g;:;;~;:iftirraaF:=::=:::a number of issues relating to the location of the new hospital on the Mater Campus. The

Review was carried out under the joint auspices of the National Association of Children's

Hospitals and Related Institutions and the European Health Property Network. The

independent experts who formed the Review Team, having examined all the issues in

accordance with the Terms of Reference set by the Minister, strongly endorsed tri-location

with adult and maternity services and made a unanimous and unequivocal recommendation

that the development of the new hospital should proceed on the Mater Campus. The

Minister confirmed the Government's acceptance of the recommendation of the Review

Team and requested the NPHDB to proceed with a planning application to An Bord Pleanala.

The application was lodged in July 2011, and a 10-day oral hearing was held later in the

year.

Planning decision by An Bord Pleanala, 2012

Planning permission for the new children's hospital on the Eccles Street site was refused in

February 2012 for the following reasons:

14

Mater Campus, (circa 2 hectares}, has resulted in a pro~p~o~s;anl f~o~rla~~ttiPDfii~~~J building in terms of bulk and height, including a 164 metre long ward block, rising to

74 metres above ground. Notwithstanding the general acceptability of the proposal in

terms of medical co-location on this inner city hospital site, it is considered that the

proposed development, by reason of its height, scale, form and mass, located on this

elevated site, would result in a dominant, visually incongruous structure and would

have a profound negative impact on the appearance and visual amenity of the city

skyline. The proposed development would contravene policy SC18 of the Dublin City

Development Plan, 2011-2017, which seeks to protect and enhance the skyline of the

inner city and to ensure that all proposals for mid-rise and taller buildings make a

positive contribution to the urban character of the city.

Furthermore, the development as proposed, notwithstanding the quality of the

design, would be inconsistent with, and adversely affect, the existing scale and

character of the historic city and the established character of the local area and would

seriously detract from the setting and character of protected structures, streetscapes

and areas of conservation value and, in particular, the vistas of O'Connell Street and

North Great George's Street.

Having regard to the site masterplan for the Mater Campus submitted with this

application, it is also considered that the proposed development, as configured, would

constitute overdevelopment of the site.

The proposed development would, therefore, be contrary to the proper planning and

sustainable development of the area."

It is standard planning practice to cite all relevant substantive reasons for refusal, to assist

applicants in deciding whether to submit revised proposals. It is important to note that

there was no planning objection in principle to the proposed location of the new children's

hospital. The Board's reasons for refusal were based solely on grounds of overdevelopment

and consequential adverse visual impacts. It should also be noted that the Board did not cite

difficulty of access to, or lacking of parking at, the Eccles Street site as reasons for refusal.

In the considered opinion of the Review Group, based on the drawings and photomontages

submitted with the planning application, the element of the proposed design which most

contributed to the refusal of permission was the excessive height and bulk of the proposed

ward block (floors 9- 16), which surmounted the podium block. Such overdevelopment of

15

_I - - • ~ ---·- ~ -

the site could only be alleviated either by substantially reducing the proposed floor area of

the new children's hospital- which would be unlikely to meet the requirements of the

design brief- or by enlarging the site and thus reducing the overall height.

More recently, the NPHDB's design team has held preliminary consultations with An Bord

Pleamila regarding a modified design which involves a significant reduction in the height of

the proposed building and which would relocate research and education uses into the 1861

"Old Mater" building (see chapter 11).

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16

Chapter 3 Approach adopted by the Review Group

Documentation

We were provided with copies of all relevant previous reports, and sought further detailed

or current information from the various hospitals, represent< tiv~ szroups and individual

experts as the need arose. AN BORD PLEANALA TIME BY

-----1 Formation of sub-groups - 1 OCT 2015

To make most efficient use of the training and experience of t!T~Sirs, two ~roups

were formed to report back to the Group on issues assigned.=.8;.1t;;,:tlleJ::::::m::·:::· =========I

a) The clinicians' sub-group examined issues relating to clinical specialties and sub

specialties, transitional care for adolescents, co-location and tri-location (see chapter

4), and the integration of paediatric health research and education into the new

children's hospital (see chapter 5).

b) The technical sub-group addressed planning, design and construction issues such as

access and parking, cost and program delivery comparisons (see chapters 6 to 8

inclusive), identification and mitigation of implementation risks (see chapter 12).

Ms. Louise Shepherd made a presentation to the Group on child-centred hospital design

based on the consultation process for the new Alder Hey Hospital, liverpool (see chapter 6).

Meetings with representative groups and key experts

The Group received many requests to meet representative groups, and endeavoured to

accede to as many of these as possible. We also requested meetings with relevant agencies,

interest groups and individual experts. We appreciate the time and effort devoted by all

those we met and we benefited greatly from their first-hand experience of the issues

involved in the new children's hospital project.

The full list of meetings is given in Appendix 1.

Meetings with hospitals proposing sites for the new children's hospital

We invited the National Paediatric Hospital Development Board to present their revised

proposal for the Eccles Street site.

17

We wrote to the Mater Hospital asking if it wished to make a submission to the Group

separate from that being made by the NPHDB. In response, the Mater Hospital, Children's

University Hospital Temple Street and the Rotunda Hospital made a joint submission to the

Group which they subsequently presented.

We wrote to the other four Dublin Academic Teaching Hospitals (OATHs) and Connolly

Hospital, asking if they wished to offer a co-located site for the new children's hospital and a

new maternity hospital. Beaumont, Connolly, St. James's and Tallaght Hospitals responded

with specific site proposals, which they subsequently presented to us. St Vincent's chose not

to submit a proposal.

On the basis of recommendations from the two sub-groups, 'r~~~~~W~W.ii~~

offers which were supported by a OATH should be considere . o~JiJQ;IjPJtl.i~ Coombe Women and Infants University Hospital to make a p ei~~~ieR of tbei~~ o

us. - 1 OCT 2015

Arising from the varying level of information at the presenta

floor area and cost data from all six hospitals in a standard fca:tllal~=t!~~!:!~e!!:!!~:::l

Sample letters to the hospitals seeking further information, are given in Appendix 2.

Site visits

To familiarise ourselves with the location and character of the potential sites, we visited all

six hospital sites. Members of the Technical Group also visited the Belcamp site.

Technical assistance

The Office of Public Works provided us with a planning and construction appraisal of five

hospital sites (the Mater site had been the subject of appraisal by An Bard Pleanala) to

assess those sites technically and to form a view as to their suitability.

Assessment process

Having reviewed policy and best practice regarding children' s health, we agreed that the

best health outcomes would be achieved by co-locating the children's hospital with an adult

teaching hospital in Dublin. Ideally, tri-location with a maternity hospital should be sought in

the interests of seriously ill mothers and newborn babies.

Accordingly, we confined our detailed assessment of potential sites to those offered by, or

supported by, the OATHs. We devised assessment criteria derived from our terms of

reference including clinical synergies, depth and breadth of research, access, planning and

18

20

design issues, project timelines, and value for money. The strengths and weaknesses of each

potential site were assessed under each heading.

19

partl

Assessment criteria

AN BORD PLEANALA TIME BY. ___ _.

- t OCT 2015

LTR·OATEO FROM ---t

Pl

21

Chapter4 Children's healthcare issues

The new children's hospital represents the largest piece of infrastructural investment in

healthcare in the history of the State. It will send a signal of national intent on the

prioritisation of children into the future. Ireland has the highest birth-rate and the largest

population proportion of children within the EU. Ireland has the potential to develop an

innovative and exemplary model of paediatric care, with a single national tertiary children's

hospital setting the standard for the delivery of best attainable health outcomes across

primary, secondary and tertiary care.

The purpose of this chapter is to set out children's healthcare issues which need to be

considered in assessing the suitability of potential sites to accommodate the new children's

hospital, and possibly a new maternity hospital also. This chap ,

important issues with regard to the future development of chi reM~~~c~re.8V NALA TIME __ _

Co-location and tri·location - 1 OCT 2015

LTR.OAiEO FROM The case for a single tertiary care children's hospital for Ireland as been ge"!' ally acce"""",....-'"1

Development of this hospital on the same site as an adult terti~~tmitall:mlii:Cca:ma~=:::s hospital is also generally accepted as the ideal "tri-location". Co-location with an adult

hospital is the norm internationally, driven by four major advantages:

• access to adult specialists

• access to expensive equipment (such as PET, MRI scanners)

• research and educational synergies

• facilitation of continuity in the care of the adolescent/young adult with chronic

disease.

Tri-location of maternity with adult and paediatric hospitals has advantages for mothers in

providing rapid and ready access to non-obstetric specialist expertise, and to specialist

surgery and intensive care in the case of major obstetric emergency; and for infants with

congenital malformations, or complications of prematurity which require surgery. Better

imaging allows for pre-birth diagnosis of serious congenital malformations in many cases.

These infants can then have planned delivery at a co-located maternity hospital to give

them the best chance of a good outcome.

It is acknowledged that over time, paediatric hospitals' dependency on adult specialists will

decline as paediatric sub-specialties develop. We also acknowledge that while physical co-

22

AN BORD PLEANALA TIME ___ BV ___ _.

- 1 ncr 2n1s location will facilitate the benefits outlined, it does not gui: antee them. Co-local1on and

integration must overcome the following challenges: LTR·DATED FROM ----1

PL

• the fragmentation of adult specialties, and the freestanding nature of the maternity

hospitals in Dublin, means that there is no readymade ideal tri-location site

• research and educational synergy depends on meaningful regular interactions

between clinicians, and requires planning and effort on both sides

• transitional care of adolescents with complex problems requires a willingness of adult hospital services to take on a new and challenging case load, the development of new skill-sets, and a different orientation of paediatric care

• the advantages of the individual co-location proposals must be balanced against the respective design compromises necessary to achieve them

Nevertheless, we concur that tri-location of the new children's hospital with an adult

hospital and a maternity hospital is the ideal.

Adolescent healthcare

In recent years, questions have become more prominent about how adolescents'

health care should be managed. It is now widely accepted that traditional models of

care do not adequately meet the needs of teenagers and young adults. Many young

people do not feel comfortable within the hospital setting as they have unique needs

of privacy and socialisation that do not fit well either in paediatric wards focused on

younger children and infants or in adult services. Indeed the provision of a more

consistent medical therapeutic and supportive care approach addressing the unique

educational, psychosocial, and emotional needs of this population in an age

appropriate facility translates into better outcomes. Therefore, whenever possible;

• adolescents receiving care should be provided with their own space so that

they can mix with their own peer group in an age appropriate environment,

preferably across existing traditional disease/condition-specific ward

configurations

• access to disease specific or treatment specific expertise should be available as

required (such as infection isolation)

• adolescents' clinical care should be undertaken by appropriately trained staff,

namely experienced professionals who care for them and are able to help them

23

with their individual needs and in doing so co-ordinate their care across the

whole system and at all stages of the patient pathway.

Developing these services for adolescents within the new children's hospital will be

challenging. Co·location presents a unique opportunity to deliver innovation and

patient focused, rather than disease focused, care. Adolescent medicine and

transitional care must be forged from both sides of the paediatric and adult

disciplines that will be co·located. Both are evolving specialties which cross many

boundaries and will challenge many entrenched beliefs and ways of working. Getting

this aspect of Ireland's model of care right will alscw~MM!tift~m'ltmmtmm:iitiaiiarl approach. TIME BY ___ -t ----The Model of Care - 1 OCT 2015

Health services should provide safe effective care a \-6~t~p9QSsihle~~~rs~S"!!PI"Mla~ intelligent network of primary, secondary and terti tflc2!;!;fttii=xaibd:lm::z:m1113:i;t;~n's hospital, as the centre for tertiary care, will be at the apex of the care network, will set the

standard in secondary care, and will also inform the organisation and delivery of primary

care. Within the greater Dublin area, the organisation of secondary care, in particular the

role of urgent care centres, will depend on the location and capacity of the new children's

hospital.

All children in Ireland should have equal access to excellent healthcare, and this should be

provided quickly and close to the child's home whenever possible.

The new children's hospital will be part of two hub-and-spoke models of Irish children's

healthcare. It will be the hub for the secondary level healthcare for all children in the

Greater Dublin area, and it will be the hub for tertiary level healthcare for all children in

Ireland. It must have dedicated outreach to other facilities to deliver secondary health care

in Dublin and to deliver tertiary healthcare in partner hospitals throughout Ireland (see

Figure 1).

We understand that the development of the HSE's Clinical Care Programmes in paediatrics

and neonatology will consider many of the issues relating to how care is delivered.

Primary healthcare

As well as being beneficial for patients, the provision of care that is safe, efficient and

effective through primary care centres close to the patient's home reduces the risk of

secondary and tertiary centres becoming overloaded with low acuity work to the detriment

of true secondary and tertiary care.

24

Figure 1

NATIONAL MODEL OF CARE

0 NEW CHILDRENS HOSPITAL INCLUDING REGIONAL CHILDRENS HOSPITAL FOR DUBLIN AREA

e REGIONAL CHILDRENS HOSPITALS

• EMERGENCY & AMBULATORY CENTRES

• PRIMARY & COMMUNITY CARE CENTRES

GREATER DUBLIN AREA

25

Secondary healthcare

Secondary care requires specialist paediatric input as inpatient or outpatient, much of which

can be provided at urgent care centres linked to the tertiary children's hospital- examples

include gastroenteritis with dehydration (inpatient care) or troublesome asthma (outpatient

care). Children living in proximity to an urgent care centre will not be required to travel to

the new children's hospital for treatment of minor injuries or illnesses.

Outside of the Greater Dublin Area, secondary paediatric care will continue to be delivered

In over 16 hospitals as at present. These services will require adequate resources to deliver

safe effective care, minimising inappropriate use of the tertiary hospi al. AN BORD PLEANALA TIME BY

Tertiary healthcare (complex conditions)

- 1 OCT 2015 While the new children's hospital will be responsible for the provisio mtt9~ef)Y care foFmJM

children in Ireland, outreach delivery of tertiary paediatric care by su l!5eecialists from the ___ ,..

new children's hospital should be available, to minimise multiple unnbc:~:,~mc"""iau,f;,~ .. ~-"·c;ori,;;t;. Mi~===:l to Dublin for some children.

Emergency and non-emergency transport

A dedicated paediatric transport system is urgently required to safely transfer children

requiring high dependency or intensive care to the new children's hospital.

Urgent care centres

The number and location of urgent care centres in the Dublin area can only be determined

once the site for the hospital is selected. We consider that care must be taken in defining

the clinical objectives of these urgent care centres, which should not be so large as to

undermine the effective working of the new children's hospital itself.

These urgent care centres should share a common IT platform with the hospital to ensure

ease of information and patient transfer.

ICT

Information and communications technology systems are required to support the provision

of electronic patient records. This is particularly important for the safe operation of the

urgent care centres and in delivering timely clinical care at the bedside, without the reliance

on manual delivery of cumbersome paper records. Electronic patient records will facilitate

audit, clinical and population research, and clinical governance.

26

Tl:eN BORD PLEANALA ____ BY

Chapter 5 Research and education issues ~---..

- 1 OCT 2015 __ FROM

One of the greatest success stories of modern medicine e surviVal rat~....,.._.. childhood cancers which have quadrupled over the past 40 years an no d

over 90% for acute lymphoblastic leukaemia, the most common cancer in children). This

progress has been driven, not only by new therapies, but by the clinical research process.

Excellence in modern paediatric clinical practice cannot be provided except in the context of

basic science research-led enquiry and Its translation into clinical practice, which is often

called the journey of a discovery "from the bench to the bedside." At hospitals where

clinical research is a major activity, a rich web of interactions can be found among clinical

research, basic research and clinical practice activities.

Such improvements have resulted both from specific, step-by-step refinements in therapy

but also from improved scientific insights into these diseases. Therefore, basic, translational

and clinical research must be a primary focus of the new children's hospital if it is to become

a world class paediatric academic health centre. To achieve this, positive relationships

between the research laboratory and the clinic need to be encouraged. In doing so, the new

children's hospital will generate an environment of research enquiry among staff and

students -an approach known to improve health care outcomes for children and

adolescents.

Top quality research-led clinical care within the new children's hospital will undoubtedly

attract the best students to paediatrics and the best Irish and non-Irish clinical and basic

scientists to train and work there. Consolidation of diverse research activities in the new

children's hospital will make it easier for Irish researchers to establish joint research

programmes and student exchanges with internationally renowned paediatric research

centres as well as other research hubs affiliated with the Dublin universities and elsewhere

in Ireland.

The need to engage in research is increasingly understood by families and the wider public.

Many adult diseases have their origins in childhood, and many childhood conditions

continue through to adulthood. Paediatric research has the capacity to improve the

treatment and prevention of childhood, adolescent and adult diseases. It will be crucial for

the new children's hospital that its child health care professionals and scientists engage with

their patients, families and the public, advocating for paediatric research.

The biggest challenge for the new children's hospital will be to provide outstanding patient

care. This can only be achieved if the appropriate research and educational infrastructure is

in place on the hospital site. Having the clinical research laboratories and the

inpatient/outpatient clinical areas on the same campus will greatly enhance the hospital's

27

mission to carry out the best clinical care and research and to enhance the education of

health care and scientific research staff.

AN BOAD PLEANALA TIME av ___ .,.

- 1 OCT 2015

LTR·DATED •FROM __ -t

PL·· .. • f

28

Chapter 6 Access, planning and design issues

The purpose of this chapter is to set out important access and parking, planning and design

issues which need to be considered in assessing the suitab r. 1 y · · to

accommodate the new children's hospital, and possibly a ~at~~~ltiU\4JIR:.A - _BY

Access and parking issues

patients and their parents, staff, and visitors to the children's hospital have somewhat

different access and parking needs.

It is estimated1 that about 75% of inpatients will come from the Greater Dublin Area, as will

65% of day-care patients, 72% of out-patients, and 80% of Emergency Department (ED)

patients.

Very sick children first seen in secondary care hospitals outside the Greater Dublin Area who

require tertiary care will be transported by specialist ambulances to the new children's

hospital, with trained staff both stabilising the patient before the journey and transporting

him or her safely. The same applies to newborn babies who need to be transferred from

maternity hospitals. Because the new children's hospital will also have to facilitate some

patient transfers by air ambulance, a helipad should be provided on site, preferably at

ground level.

Access and parking for patients arriving at Emergency Departments

Data from the three existing children's hospitals in Dublin shows that about 90% of ED

patients arrive by car. As overall paediatric patient numbers are expected to increase by

13% between now and 2021, it would not be possible for any single hospital to cope with

such large numbers of ED patients, the vast majority of whom do not require tertiary care.

Accordingly, it is envisaged that almost half of such ED patients will be treated at one or

more satellite urgent care centres. Such centres are an essential and integral part of the

National Model for Paediatric Healthcare as outlined by the NPHDB. Had planning

permission been granted for the children's hospital at Eccles Street, a centre would have

been developed at Tallaght Hospital. The provision of satellite urgent care centres in

tandem with the children's hospital means that car-based traffic generated by ED patients

will be distributed between dispersed geographic locations in Dublin. We also note Census

1 Source: NPHDB

29

data which shows that levels of car ownership (28%) in Dublin's inner city in 2006 were

much lower than the average for the State (80%).

Nonetheless, it is to be expected that most ED patients who do attend the children's

hospital will arrive by car, and adequate on-site parking needs to be provided for their

needs. We note that the approximately 750 public parking spaces proposed on the Eccles

Street site exceed the existing total number of such spaces at the three children's hospitals

in Dublin, and that An Bord Pleanala did not raise any planning objection to this level of

provision. This provides an indication of the minimum level of public parking spaces which

should be provided on whichever site is chosen for the hospital

required if the selected site has a lower level of public transport

Access and parking for out-patients and day-care requiremen - 1 OCT 2015

appointments at the children's hospital, to reserve parking spac .

car rather than public transport. Similarly, free parking should be provided where required

for parents of long-stay patients.

Directional signage

For those parents travelling by car from outside the greater Dublin area, clear roadside

signage on the national primary roads into Dublin should advise them which direction to

take on reaching the MSO, and should guide them from the appropriate MSO junction to the

fastest route to the new children's hospital.

Sustainable travel

Government policies on sustainable travel and climate change are designed to promote a

modal change from the use of private cars to walking, cycling and public transport, and

these policies have been underpinned by very substantial State investment in public

transport, both in Dublin and nationally. These policies are reflected in the statutory draft

Transport Strategy for the Greater Dublin Area prepared by the National Transport

Authority; the Authority is the prescribed body which will be requested to make a

submission to An Bord Pleanala in relation to the transport implications of any strategic

infrastructure application for the hospital. Also in accordance with those policies, most

Dublin hospitals have introduced Mobility Management Plans for staff in order to encourage

greater use of public transport. As the provision of free or inexpensive parking has been

shown to promote use of private cars, the trend has been to limit such parking to clinical

staff who need to travel between hospitals, and to staff whose shift work may not be

30

facilitated by public transport. The Review Group supports this a

to at least some categories of visitors to the children's hospital.

Planning issues

The new children's hospital will require a very large building o

metres. Depending on its location and the size of the site availa'ia:~=~~~~~~;j likely to range between 5 and 10 storeys. To avoid a risk of a further refusal of p an

permission, the relevant planning issues need to be fully addressed, particularly as the

submission of an environmental impact statement and appropriate assessment for such

major development is mandatory under EU and Irish law.

While An Bord Pleanala is not bound by the provisions of the local development plan in

determining a strategic infrastructure application, it will have regard to objectives relating to

zoning, development control standards (such as density and height), protection of the built

and natural environment etc. as representing good planning practice. We have identified

the following planning issues, inter alia:

• if the children's hospital (and possibly a new maternity hospital also) is to be built on

the campus of an existing hospital, the zoning will normally facilitate further similar

development

• average urban plot ratios (which indicate the amount of floorspace that can be built

on a given site without causing problems of overlooking, overshadowing, etc.) would

suggest the need for a site area of at least 5-6 hectares to accommodate about

165,000 sq metres (including expansion space) estimated to be required for both

new children's and maternity hospitals

• if the relevant development plan facilitates buildings significantly higher than 4-5

storeys, for example in certain inner city or town centre locations, a smaller site area

may be feasible

• on any site the impact of tall and/or bulky buildings on the amenities of

neighbouring houses, and the visual impact on historic buildings and vistas, needs to

be carefully assessed, as shown by the reasons for refusal on the Mater site

• the amount of parking to be provided on site will depend on a range of factors,

including how well the site Is served by public transport, and the capacity of the

surrounding road network to accommodate the additional traffic without causing

significant congestion

31

• how the parking is to be provided will depend on the size and location of the site:

deep basement car parking required on small sites is expensive to construct, while

surface car parks on extensive sites are wasteful of land and may require long walks

to the hospital

• the planning history of the potential site may be relevant, particularly if there is a

recent but unused permission for development of a similar land use or quantum.

Such a permission may serve to indicate the acceptability from a planning viewpoint

of further hospital development, building heights, trar&•' .,.Jm~n~act~et~c-.. ---~-AN BORD PLEANALA

Design issues TIME BY ____ ...

We have identified the following key design issues. - 1 OCT 2015

Internal layout

LTR·OATEO FROM --- ---... PL _

A great deal of preparatory work (such as the high-level framework prepared by RKW

architectural consultants) has been done since 2006 in designing the capacity and internal

layout of the children's hospital, e.g. what functions have to be close to each other, the

need for single bedrooms, etc. This design work has also been the subject of considerable

consultation with staff and patient representatives. It is our understanding that should the

Minister and the Government choose a site other than the Mater, much of this work may be

transferable.

The Youth Advisory Council, representing young patients, which has been part of the

consultation process referred to above, outlined to us the importance of:

• Single rooms, with a pleasant outlook

• A spacious and welcoming entrance concourse, with 24/7 shops and cafes

• Age-appropriate play spaces and meeting rooms

• Bright and cheerful decor throughout

• Rooms and amenity spaces where parents can relax when not with their sick

children.

Child-friendly design

International best practice- including the design of the new Alder Hey Children's Hospital in

liverpool - indicates that child patients place a high value on an attractive, landscaped

setting (http://www.youtube.com/watch?v=iyCOAhVQ7KI). There is some academic

research which points to better healthcare outcomes in such cases, although it is important

32

-AN BORD PLEANALA I

TIME_ BY

Chapter 7 Cost and value for money issues - -----.1

- t ocr 201s

Costs LTR·DATED_ FROM PL_ - ___ __,

The Review Group sought castings for each proposal supported by a Dublin Academic

Teaching Hospital. Apart from the NPHOB which has been working on the project for some

time and which has had the benefit of a detailed knowledge of the proposed building, the

indicative costs received from the other groups were prepared in a short time-frame and

based on concept designs comprising little more than block plans and using rates per square

metre taken from published industry cost bands (generally between €2,000 and €2,600 per

square metre). Some adopted a conservative approach while others were more optimistic. It

serves little purpose, therefore, to take these figures as a basis for like-for-like comparisons

between the proposals. We therefore sought to assess in broad terms whether costs are

likely to be higher or lower on the potential alternative sites, having regard to location, size

and shape and also make some estimate of the order of magnitude of such variations.

Urban versus greenfield sites

For the purposes of this exercise, a comparison was made between a 10 storey hospital

building of 100,000 square metres with multiple basement carpark and plant spaces on a

tight urban site, and a similar sized building on a large greenfield site with an average height

of five storeys above ground. (A copy of the study is included at Appendix 4). The size of the

site will influence the design of the building and the time required to construct it, which in

turn will affect the cost. In the case of the urban site, the floor layout will be more compact

with less horizontal travel distances, stairs and lifts, albeit serving more floors. On the other

hand, the structure, facades and building services are likely to be more expensive.

Overall, the difficulties of building taller buildings on a tight urban site have a significant cost

implication, which is estimated to be in the order of 10% more than a building of this size on

a greenfield site.

There are also significant differences between the cost of providing car-parking in multiple

basements as opposed to surface parking or multi-storey carparks above ground. The

following is the indicative cost of providing car-parking alternative formats.

Type of car-park Indicative cost per car Indicative cost for 1000 car

space spaces

Surface €2,000 €2,000,000

Multistorey €5,000 €5,000,000

Multi-basement level €35,000 (35,000,000

34

to note that the improvement is not comparable with that resulting from the scale of

activity and range of sub-specialties which can be achieved in a major children's hospital.

Nonetheless, if a parkland setting for the children's hospital is not possible on a given site,

there is much that can be done through the creation of garden spaces at lower levels or by

means of enclosed green spaces at higher levels. Some of the

Capacity for expansion

The new hospital will have a design life of 50-100 years. H

technology, and patient demand will occur over such a lon;g:,p:e:ri:o~,~=~~~~~~J design of the hospital allows it to change and grow. While ;orne expansion capacity

provided elsewhere in the healthcare system -in regional hospitals and urgent care

centres, for example- best practice indicates that at least 20% capacity should be provided

on or adjoining the site. There are a number of ways of achieving this:

• The building can be designed to be extended outwards or upwards, subject to future

planning permission

• Lateral capacity is more beneficial, as adding floors is more expensive and creates

operational problems for the hospital

• The site may be large enough to accommodate numerous additional buildings

• Vacant buildings or sites may be available in the immediate vicinity, which are

suitable for ancillary uses which are not required to be located on the site

• It is also assumed that the proposals would be future proofed and have the capacity

for an increase in capacity and usage and the ability to physically expand if the need

arose.

33

The combination of surface and multi-storey car-parking that is likely to be adopted in

greenfield sites is likely to result in a further saving in the order of 10% to 15% of the overall

construction cost when compared to a tight urban site.

Site costs

All of the subject sites with the exception of the Coombe Hospital's proposal and

Beaumont's Belcamp proposal are in the ownership of public bodies and are understood to

be available at no cost other than the actual cost of conveyancing from one State agency to

another. In the case of the Coombe Hospital, it is understood that part of the site is in the

ownership of Dublin City Council while another part is owned by a property company which

is under the control of NAMA. This site will require due diligence ·~;~;~~~~~,_ __ conveyancing issues resulting in some cost and time. The lands atl t

the control of NAMA.

Site clearance and decanting

Decanting and replacement of existing buildings on the sites of

hospital is a significant issue in the case of Beaumont, St James~'s~a;n~d~t~o~ii;i8:~q;~~;~J the Mater site. Existing buildings will require demolition and the site will require to be

cleared of debris. Some replacement buildings will be required on all of the sites, as will the

diversion of underground services. Demolition and clearance of existing single storey

buildings is required on the Coombe Hospital extended site, along with the removal of some

contaminated soil and underground services. For the Tallaght Hospital and Connolly

Hospital proposals, the sites are substantially free of existing buildings and services.

Other costs

Planning and services connections and other external costs are likely to be broadly similar

across all of the options. Professional fees for design and preparation of tender

documentation are likely to be of the order of 5% of the construction cost, while VAT will be

of the order of 13.5% of the construction cost. These figures will therefore vary in

accordance with the cost of the basic building.

ICT costs

The cost of providing a computerised patient management system that is fully integrated

and linked to urgent care centre(s) is not included in the current model of costs for this

project. Instead it is seen as a service that is the responsibility of the HSE and will come

under their budget. In our view this presents a significant risk to the project and every effort

should be made to include the technology as part of the service.

35

AN BORD PLEANALA TIME BV ___ -1

- 1 OCT 2015

LTR·OATED FROM --- ---"'1 Risk and inflation Pl

A provision for risk and inflation should be applied at the same rate to all projects.

Sunk costs of existing development at the Mater site

It is estimated by the NPHDB that only 20% of the costs incurred to date on the Mater site

are recoverable which they estimate would lead to a write·off of €24m. This appears to be

on the basis that such infrastructural works and service connections that have been

completed would not be used, in the event of a new children's hospital being constructed

elsewhere. In that event, the installations will be available for use for any other building that

may be built on the site.

Sustainability and lifecycle cost

The design and location of the new hospital should have regard to the life cycle cost of the

building in addition to the initial capital cost. The building should be energy efficient and

require low maintenance and running costs. Floor space should be arranged in large regular

blocks with large spans and adequate space for building services. The flexibility to change

the internal layout and use of the building will ensure its sustainability into the future.

Operational savings

The operational savings achieved should be both clinical and in shared services. The shared

infrastructure that will exist in a co· or tri·location will also bring ongoing infrastructural

synergy and in ongoing costs in such areas as Central Sterile Supplies Department, waste

management etc.

36

ChapterS Project timelines

Our terms of reference require us to have regard to the likely timelines associated with the

different options.

Once a site has been selected, the various components of the project timeline are as follows

(some can run in parallel- see below):

1) Site acquisition, if required

2) Procurement of design team

3) Design development and preparation of planning application

4) Consideration of application by An Bard Pleanala

If permission is granted:

5) Procurement of construction contractors

6) Demolition/decanting of existing buildings, if required

7) Construction of new hospital

8) Commissioning of new hospital

1) Site acquisition, if required

Should the Government opt to purchase a greenfield site, the appropriate procurement

process will apply and it is estimated this would take at least six months to complete.

2) Procurement of design team

In the case of the Mater site, the design team is already in place. In all other cases, a

public procurement process will be required, taking about three months.

3) Design development and preparation of planning application

In all cases it is assumed that design development and the preparation of a planning

application will run concurrently. In the case of the Mater site, substantial design work

has already been carried out, including a revised design which seeks to address the

reasons for refusal of planning permission for the original design in February 2012. The

design development and planning application process could probably be completed in

about four months.

37

.. _- --.·-·--......... ··.: ~-~. ~ ---~ ' --=

In all cases other than the Mater site, it will be necessary to review the brief and

prepare a development control plan, preliminary and developed designs. Assuming a

significant part of the preliminary work done on the schedules of accommodation and

adjacencies prepared for the Mater hospital site would still apply to any alternative site,

it is estimated that nine months would be required.

4) Consideration of application by An Bord Pleanala

The time required to consider an application for strategic infrastructure development is

solely a matter for the Board. However, based on

application on the Mater site, around six months

process.

Assuming planning permission is granted:

- 1 OCT 2015

LTR·DATED ___ FROM __ --t

These stages can run in parallel, and about 14 months (11 months in the case of the

Mater site) should be allowed. This period also allows for ancillary certification, such as

fire safety and disability access.

6) Demolition/decanting of existing buildings, if required

The longest delay would arise in the case of Beaumont Hospital, where planning

permission would be required for a new multi-storey car park to replace the existing car

park which would have to be demolished. The new car park would have to be

completed before construction work could start on the children's hospital. Assuming no

planning appeal, this would take at least 20 months. lesser amounts of demolition or

decanting would be required on the St. James's site for which planning permission has

been granted. Demolition and decanting remain to be completed on the Mater site,

including the 1861 courtyard buildings. The Coombe site requires demolition of mostly

existing single storey buildings (for which planning permission has already been

granted) and no decanting. There is no demolition involved on the Connolly or Tallaght

Hospital sites for the children's hospital (demolition and decanting would be required in

relation to the proposed maternity hospital at Tallaght, but it is assumed that the

children's hospital would proceed initially.) As Belcamp is a greenfield site, no

demolition or decanting is required.

38

7) Construction of the new hospital

Urban sites may require deep basements for underground car parks, and existing

underground services may need to be rerouted. Because of limitations on access, site

storage, material handling and restrictions imposed by the potential effect of dust,

noise and other disruption on adjoining uses (especially so in the case of existing

working hospitals immediately adjoining the site), construction is more difficult on an

urban site. The design and structure of multi-storey buildings with multiple basements

also dictates that they be constructed in sequence starting from the bottom basement

level. No part of the structure of one floor can be started until the corresponding part

of the preceding floor is complete. While repetitive floors can lead to some economies,

every delay during the construction of the basic structural shell is critical to the overall

programme. Tall buildings in urban sites are more susceptible to wind conditions which

affect cranes with restricted operational arcs. Limitations on working times may make

it difficult to make up lost time.

Conversely, the ability to work with significantly less constraints on a greenfield site

makes for a quicker start to the works and also provides a better chance to maintain the

programme throughout the project. It also facilitates phased opening of separate

buildings.

Some of the timelines that have been received from the major hospitals are considered

to be unrealistic in indicating construction periods of two years or less. Given the scale

and complexity of the building it is estimated that it will take at least three to three and

a half years to construct on a relatively clear urban site. Reflecting the several practical

advantages in terms of relative ease of construction that a greenfield site has, it is

estimated that it could be constructed in a period which is 6 months less than an urban

site.

8) Commissioning of the new hospital

The installation and testing of hospital fittings and equipment can partly overlap with

the final phase of the construction process, but about four to five months following

completion of construction is normally required before the hospital becomes

operational.

39

r AN BORO PLEANA' LA'

TIME - BY - -----.J

- 1 OCT 2015 lTR·DATEO

- FROM PL -- -----~ - ~

Chapter9 Guiding principles

Previous chapters have set out the broad range of issues specified in our Terms of

Reference. Based on that analysis, this chapter identifies the important principles which we

recommend should guide the selection of a location for the new children's hospital and

which we have adopted in assessing the strengths and weakne sesA~IBOM~hiDAt:I~LA for our consideration. TIME BY ____ ""

Best clinical practice - 1 OCT 2015

LTR·OATED FROM __ _,

• Co-location with an adult hospital is necessary in our vie ~151nd tri-location is

optimal.

• There is no adult hospital which offers the entire range of subspecialist services to

complement the needs of the new children's hospital, but it is important that the

selected co-located adult hospital offers the best opportunities for improving health

outcomes for children from the island of Ireland for the next 100 years.

• Therefore, we have only considered in detail those sites which can offer co-location

with an adult teaching hospital immediately, and which (the Coombe, which is a

maternity hospital, excepted) have the potential to accommodate a new maternity

hospital as soon as funds permit. In our view, other sites are sub-optimal in terms of

potential best health outcomes for sick children and at-risk mothers.

Research and education

• It is crucial to both the success of the new hospital and of children's healthcare in

Ireland that it should deliver excellence in training, should have adequate space

within the core of the hospital to accommodate both research and education

facilities, and that there should be on-site capacity for future expansion, to meet

changing needs and new technology.

Access

• As about three-quarters of patients will come from the Dublin area- both inside and

outside the MSO- we agree with the McKinsey Children's Health First report from

that the hospital should be located in Dublin. We have not considered in detail sites

outside the area for that reason.

40

• There will be a need to provide adequate on-site parking for patients, parents,

visitors and staff at the new hospital; a minimum of around 1,000 spaces is likely to

be required, perhaps more if not supplemented by good public transport services.

• A balance needs to be struck between the need to provide parking and the capacity

of the adjoining road network to accommodate the approximately 10,000 daily trips

likely to be generated by the hospital (not all of which will be by car).

• A site which benefits from good public transport should be prioritised over one

which is largely car-dependent.

• A helipad should be provided within the hospital campus for air ambulance transfers,

preferably at ground level. AN BORD PLEANALA

TIME_ BY _____ ,., Planning and design

- J OCT 20f5 • To minimise the risk of a further refusal of plannir giJR~~~· the ~oWould be

large enough to accommodate a bulky and tall bu ling without causing a-a-tt~iio-.1'

impacts on the immediate surroundings or the skyline, a11u .m--·-relevant development plan/local area plan objectives and standards. As stated

earlier, this is likely to be at least 5-6 hectares, unless the relevant development plan

facilitates buildings significantly higher than 4-5 storeys.

• The site should also be large enough to facilitate future hospital and research

expansion (a minimum of about 20% is recommended).

• Ideally, the site should be large enough to provide a pleasant parkland setting; if this

is not feasible, a range of amenity and play spaces should be provided at lower levels

and enclosed "winter gardens" at higher levels.

Cost

• Having regard to the current state of the public finances, it is imperative that value

for money be achieved in delivering the children's hospital, by minimising both the

capital and operational costs.

• Where the site is in public ownership, no acquisition cost is involved.

• Significant ongoing operational savings will be achieved by combining the three

existing children's hospitals on one site; additional savings will accrue through co

location with an adult hospital (or tri-location with a maternity hospital}. While such

41

. - - - ~ ..... - - - ~ -..

savings are not dependent on location, the larger the co-located hospital, the greater

should be the scope for efficiencies of scale.

Programme delivery

• Having regard to delays which have already taken place, it is imperative for the sake

of sick children and their families that the new hospital be delivered as quickly as

possible.

• However, while any avoidable delay should be minimised, it is more important to

choose the right site which meets essential criteria over the long-term (say 50-100

years) than one which is merely the fastest in the short-term. This approach has

been endorsed by patients, parents, and health professionals who met us.

AN BORD PLEANALA TIME _BY ___ _.. -

- \ OCT 2015

L1'R·DAiED ___ FROM __ _..

PL

42

I I

Part3 Assessments and recommendations

43

Chapter 10 Unsolicited site offers

Sites offered free

The site offers received are identified on the map (Figure 2). The following sites were

offered free of charge and we wish to acknowledge the generosity of these landowners.

• Site of c.lS-20 acres, Newlands/ Belgard Road, adjacent to the MSO and the Naas Rd,

offered by Mr Philip Browne, IRFU (6}

• Site of c.8 acres at the west end of the former Phoenix Park Racecourse, offered by

Noel 0 Flaherty, Flynn & 0 Flaherty (12)

• Site of area within c. 200 acres, adjacent to Dublin Airport at Merryfalls/Silloge

offered by Mr Frank Connon (22)

• Site adjacent to the MSO and Dublin Airport, offered by Mr Philip Maguire, Ballymun

Regeneration ltd, Ballymun (23)

f ANBORO TIME PLEANALA -1

-· BY - ... ___ _j

- 1 ocr 201s -Other unsolicited offers

The following offers were also received. Those that are withi H~lbUII)'l area ace. numbered PL -- rftOM on the map (Figure 2). j • _ -- ____ _,

• Site of number 75, 76 & 77 Eccles Street, private property offered by Mr John

McGovern (1)

• Site of c.1.45 acres, Dorset Street, Dublin 1 offered by Mr Adrian Langan, Barina

Construction Ltd (2}

• Site of c. 8 acres at Heuston South Quarter, adjacent Royal Hospital Kilmainham

offered by Ronan Webster, Green Property Ventures (3)

• Site of c.lO.Sl acres, adjacent Tallaght Hospital offered by Mr Philip Harvey, William

Harvey & Co. for Allied Foods (5)

• Site of c. 32.5 acres, at Naas Rd, adjacent to Newlands Cross offered by Mr Noel

Smyth, Alburn (7)

• Site of c.lS acres N7, adjacent Red Cow Luas Stop offered by Mr Gregory Aiken,

Brunelle Developments Ltd (8)

44

• Site of c. 24 acres, at Naas Road, Dublin 12 adjacent to Luas and MSO offered by Mr

Robert Harris, Harris Group (9)

• Site of c.14.5 acres, Monastery Road, Clondalkin offered by Mr Finn Lyden, SIAC

Group (10)

• Site of c. 7 hectares at Adamstown, Co Dublin offered by Mr Hugh O'Neill,

Castlethorn Construction (11)

• Site of c.26 acres, N3 Navan Rd offered by Mr William Hynes, Downey Hynes

Partnership Ltd for Corner Park Group (13)

• Site of c. 100 acres, at The Ward, Cool quay, Dublin offered by Christopher O'Rourke

Group for Mr Noel Browning (15)

• Site of c.80 acres, R135, New Park, The Ward offered by Mr liam Miller for and on

behalf of Mr Simon Rutledge (16)

• Site of c.SO acres, Lissenhall, Swords offered by Mr Francis M Whelan, Broadmeadow

Healthcare Group (17)

• Site of c.11.19 acres, N1 Kettles lane, Adjacent Dublin Airport offered by Kevin Fox,

Property Team Auctioneers (18)

• Site of c. 14.8 acres at Mountgorry, Malahide, offered by Downey Hynes Partnership

Ltd for MJS Properties (19)

• Site of c. 16.2 acres, Clonshaugh adjacent MSO & M1 offered by Mr John Swarbrigg,

Savills Ireland (20)

• Site of c. 18-20 acres at Dardistown, Co Dublin (Metropark) offered for Mr Hugo

Byrne (21)

• Site of c.6.75 acres at Swords Road, Dublin 9 offered by Mr Adrian Langan, Barina

Construction ltd (24)

Sites not within the Dublin area

• Site of c. 9.4 hectares, adjacent to new Tulia more Re

Dominic Doheny, John Flanagan Developments

• Site of c.120 acres, at Dunboyne, Co Meath offered by Mr Shay Scanlon, Arc

behalf of a client

45

• Site of c. 386 acres, at Kilcock, Co Kildare offered by Mr William J. Coonan, Coonan

Real Estate Alliance & Knight Frank Ltd on behalf of the vendors

• Site of c.85 acres, Taghadoe, Maynooth, Co Kildare offered by Mr Will Coonan,

Coonan Real Estate Alliance, on behalf of the vendors

• Site of c. 40.76 hectares, Robinstown, Mullingar offered by Mr Billy Coughlan,

Westmeath County Council

Sites proposed by Fingal County Council

Fingal County Council proposed a number of possible sites within its area for the new

children's hospital. These are listed below (some were also proposed by the landowners also

or by hospitals).

• c.21.8 hectares, Connolly Hospitai/Abbotstown

• c.16.7 hectares, Phoenix Park Racecourse AN BORD PLEANALA

• 5 hectares & 110 hectares, Cappagh Hospital & Dunsink TIME BY ----~

• c. 44.5 acres, Balcurris Ballymun - 1 OCT 2015

• c129 acres/52.5 hectares, Merryfalls, Sillogue LTR·DATED FROM PL --- ___ ..,.

• c.139.4acres/56.4 hectares, 'MetroPark' Dardistown

• c.124 acres, Clonshaugh/ Belcamp

• c.122.6 acres, Belcamp

• c.50 acres, Lissenhall, Swords

Site in public ownership proposed

• A site on the lands of Sports Campus Ireland, adjacent to Connolly Hospital and the

M50, which is publicly owned was proposed to be made available by Mr leo

Varadkar TO, Minister for Transport. These lands are part of the submission from

Connolly Hospital. (14)

46

Figure2

UNSOLICITED SITES IN THE GREATER DUBLIN AREA

-

-

....

--... ... ... ~-.y

-

-

47

Bls: ----

-

__ -.... R_,_ llun6vn ~ - v.--

""*'"" -....

-AN BORO PLEANALA .,

TIME_ BY ·-

' ocr 201s -

lTR·OATEO FROM a

1PL_ -

Chapter 11 Assessment of strengths and weaknesses of co-location proposals

Site areas proposed

Table 1 sets out for comparison the site areas in hectares proposed for the new children's

hospital, a new maternity hospital and lateral expansion space where available, by the

various adult hospitals which made submissions to us.

Table 1 Site areas proposed (hectares)

Mater Beaumont StJames Tallaght Coombe Connolly Hospital Hospital Hospttal Hospital Hospital Hospital

Paediatric Hospital 2.47 2.80 2.44 3.36 6.19 16.00

Maternity Hospital 0.53 0.90 1.26 1.18 2.30 5.00

Total 3.00 3.70 3.70 4.54 ... AN BOR·o PLEANALA Lateral Expansion o• ol 2.62 2.06

4 TIME 15.oo BY

1: No significant expansion space outside the footprint of the building Is provided at the • ater and Be~Jo~CT 2015 2: The ambulance centre and part of the outpatients dept are proposed as expansion spa e b¥,.St James 3: Expansion space Into St Teresa 's Gardens is proposed at the Coombe Hospital but not' e~~ia9ATED ___ FROM ___ """'' 4: Lateral expansion space at Tallaght is proposed on the surface car park area Pl

L.:.:=====::t

48

Original proposal for the BEAUMONT HOSPITAL campus (April 2012}

Beaumont Hospital is located on the northside of Dublin, in Dublin 9. It is an adult teaching

hospital providing a number of national specialties including neurosurgery.

Who has made the proposal?

The proposal has been made by Beaumont Hospital.

Children's hospital site proposed

The proposed site for the children's hospital is 2.8 hectares on the Beaumont Hospital

campus near the entrance from Beaumont Road. Part of the proposed site is currently

occupied by a multi-storey public car park and other buildings. A further 0.9 hectares has

been identified for a future maternity hospital. The total site offered is 3. 7 hectares.

Ownership of the site

The hospital campus, including the site, is owned by the Beaumont Hospital Board.

Key features

• The design outline proposes a hospital of 10 storeys in total, involving a 7 storey

ward block over a 3 storey podium block. There would be little protected green

space in the vicinity of the buildings.

• The existing multi-storey car park, the Irish Kidney Foundation building and a

number of other buildings currently in use near the main entrance door to the

hospital would need to be demolished and replaced elsewhere on the campus

before construction of the new children's hospital could begin. In addition to existing

car parking it is proposed to provide a further 1,500 spaces on two levels in the

basement of the proposed children's hospital.

• The proposal offers co-location with an existing adult tertiary hospital, and future tri

location with a maternity hospital beside the children's hospital when constructed. -AN BORD PLEANALA r

TIME_ BY _____ _.

- I OCT 2ot5 LTR·DATEO ____ FROM

Pl_

49

AN BORD PLEA LA TIME BY _ _ _ "'1

--..-

Proposed Hospital Slt~s) Ovttrall Site

Ordnantr Sunoty lrtland Prrmil No. 8829 (c) Ord1111nct Sunory Ireland I Gonmmenl or Ireland

- 1 OCT 2015

so

BEAUMONT HOSPITAL: assessment of strengths and weaknesses

Criteria Strensths I opportunities Weaknesses I risks

Co-located with adult teaching . 820 bed hospital, largest hospital hospital on Dublin's northside . On site co· location . Paediatric beds on site currently . Space for maternity Included

Critical mass of sub-specialist care . National specialties x 5 . Some supra-regional specialties . Radiation oncology on site

Opportunities for transitional . Some established protocol·based adolescent service transition programmes in place . Further transitional synergy with

other core sub·spetlalties could be established -AN enD;;,..

EJCtent of consultant linkages with . Significant TIME ·- r· c..c:~u IALA-1 Dublin children's hospitals - av Oepth and breadth of clinical and . Smurfit Clinical Research Centre, -academic research Including neuroscience, vascular - 1 ocr 201s --

biology and respiratory . Wellcome Trust I HRB Centre for LTR·DATED Clinical Research (spoke in hub- J PL - FROM and·spoke model) - - .... .._

---. ~

Site suitability . In public ownership . Very restricted site -Access . 4kfromMSO . limited public transport . Congested local road access . Access to four bus routes

Planning and design . Site zoned for hospital use . Height and mass of proposed building on limited site likely to be problematic In suburban context . Number of car-parking spaces may have traffic implications outside the site.

Project delivery I timellnes . Significant preparatory demolition and rebuild required before construction can begin

I resulting In time delay I

. Restricted site for construction Value for money . Significant loss of value In

demolishing relatively new and viable eJCisting buildings

51

Alternative proposal by BEAUMONT HOSPITAL for a site at Belcamp (May 2012)


This alternative greenfield proposal has been made by Beaumont Hospital, supported by the

Royal College of Surgeons in Ireland.

Site proposed

The proposed site for the new children's hospital is 7.25 hectares, with a further 3.4

hectares for a new maternity hospital. The total site proposed is c. 32 hectares.

Ownership of the site AN BORD PLEANALA

The site is privately owned and is currently under the c l ft\M!Of NAMA. BY ____ .,

Key features - 1 OCT 2015

LTR·DAlED FROM __ _.,

• No design outline has been provided but the cor qftpt outlined is that o[;~ l:mrlcr~ ed

parkland setting.

• Two or three multi-storey car parks, with capacity for over 2,000 spaces, are

proposed to serve the campus.

• The proposal is for future tri-locatlon with a new Beaumont hospital (to be

redeveloped at Belcamp at some future date) and a maternity hospital, when

constructed.

• The site offers ample space for future expansion.

• The Royal College of Surgeons in Ireland has proposed a medical/biotechnology

Research and Development cluster on the Belcamp campus .

.a 11 ol

52

-............

Proposed Hospital Slte(s) Overall Site

Ordnance Survey Ireland Permit No. 8829 (c) Ordnance Survey Ireland I Government orlreland

53

0

- ' ocr 2o1s LTR·DATEo ___ FROM

PL - ---_.

BEAUMONT-BELCAMP: assessment of the alternative proposal

This alternative proposal, which was submitted by Beaumont Hospital in conjunction with

the Royal College of Surgeons in Ireland (RCSI), presents a proposal for the tri-location of the

new children's hospital with a new maternity hospital and a general adult hospital, in

association with a health sciences, education and research campus on the Belcamp site.

The proposal envisages the relocation of Beaumont Hospital onto the Belcamp site by 2021,

following the completion of the new children's hospital and the maternity hospital. On

review of the information provided and the presentation given, we consider that while the

Belcamp proposal involves co-location, this is currently aspirational and outside the control

of the proposers.

In relation to the suitability of the site itself, a preliminary assessment was done which

identified a number of weaknesses:

• part of the site is within the Dublin Airport outer noise zone, as indicated on the

Fingal County Development Plan, making it relatively unattractive as a site for a

children's hospital

• the site is poorly served by public transport when compared with any of the other

potential urban or suburban hospital sites

• neither Beaumont Hospital nor the RCSI has a legal interest in the site, which is

under the control of NAMA and which has not been offered for sale by its owner(s)

• it is likely that any planning application for proposed development at Belcamp would

have to await the preparation and adoption of a local Area Plan by Fingal County

Council. AN BORD PLEANALA TIME BY ____ ...

- f OCT 2015 LTR·DATED FROM PL ----~

54

Proposal for the CONNOLLY HOSPITAL campus area

Connolly Hospital is an adult teaching hospital located at Blanchardstown, Dublin 15 near

the junction of the N3 and MSO.


The proposal is made jointly by Connolly Hospital and Fingal County Council. It should be

noted Beaumont Hospital and Connolly Hospital propose to merge into one hospital on two

sites and, together with RCSI, form an Academic Health Centre. Beaumont Hospital (should

its own proposal not be accepted) and RCSI have indicated their support for the proposal.


A site of 16 hectares is proposed for the children's hospital out of a total site of 36 hectares

which is adjoining the existing hospital campus. The remaining 20 hectares is available for a

new maternity hospital, other developments if necessary and parkland.


The 36 hectare site is in the ownership of National Sports Campus Development Authority

and is publicly owned.

Key features

• The proposal is for a hospital within developed parklands and natural amenity lands.

• The outline design is for a relatively low-rise building (3 to 5 storeys), consisting of

pavilions set in a landscaped area extending from a central core, with 3 fingers

separated by parkland and buildings having internal courtyards.

• Car parking capacity can be provided on the site in surface and multi-storey car

parking to whatever quantum is required.

The proposal offers co-location with an adult secondary hospital and future tri-location with

a maternity hospital.

AN BORO PLEANALA TIME BY

- 1 OCT 2015

ss LTR·DATEO FROM Pl ----- -----~

AN aoRD PLEAN TlME BY---~

0 100m

__ ._, Ordnance Survey Ireland Permit No. 8829 (c) Ordnance Survey Ireland I Government or Ireland

56

CONNOLLY HOSPITAL: assessment of strengths and weaknesses

Criteria Streneths I opportunities Weaknesses I risks Co-located with adult teaching • 400beds hospital • On site to· location

• Spate for maternity hospital

Extent of relevant adult spec:ialitles • Sec:ondary hospital

• 58 consultants

Opportunities for transitional • Transitional synergy with core adolesc:ent service specialties to be established.

Extent of consultant linkages with • None Dublin children' s hospitals __...

NALA Depth and breadth of clinical and • RCSI teaching centre ""' ' " gur1 U 1""1..1:;1-academic research • Member of Academic Health TIME BY

Centre with Beaumont and RCSI

• Wellcome Trust I HRB Centre for - 1 OCT 20 5 Clinical Research ( spoke in hub· and-spoke model) and Smurfit

. LTR·DATED FRO ~ Centre on Beaumont site

I PI Site suitability • Co-located parkland hospital

opportunity

• In public ownership

• Extensive expansion potential

• Proximate to National Aquatic and Sports Centre

~cess • Motorway sllpway ac:cess.

• No parking restrictions .

• Bus services x 12 - 2 on site

• Walking distance from Castleknock train station

• Helipad at ground level possible

Planning and design • Capable of low rise design In • Development Plan Variation parkland setting required but has the support of

• Planning not envisaged to be Fingal County Council problematic

Project delivery I time • Ease and speed of construction

• Can be opened on a phased basis

Value for money • Greenfield status

• Minimal basement requirement

• No site ac:quisition costs

57

Proposal for the COOMBE HOSPITAL campus area

The Coombe Women and Infants University Hospital is one of the three maternity hospitals

in Dublin and is located in the south inner city.


The Coombe Women and Infants University Hospital has mk~~su:=.:b::m:=is:si~o~n~to~th~e;;:;Re;v:;ie;w~~ Group. StJames's Hospital has indicated its support for the ooAfll:!lit@At>i)bl~A~

that its own proposal is not accepted. TIME BY

Children's hospital site proposed - t ocr 2o1s LTR·DATED FROM

A site of 6.2 hectares is proposed for the new children's ho tlJt ~~--.~

Coombe hospital.


The proposed site is in the ownership of Dublin City Council {1.9 hectares) and Players

Square Ltd (4.3 hectares in total in two plots). The Players Square lands are under the

control of NAMA.

Key features

• A 7-storey building is proposed, in a landscaped setting.

• 1,500 carparking spaces are proposed for the site in a two-storey basement carpark.

• The proposal is for immediate tri-location of paediatric, maternity and adult services,

involving the existing Coombe hospital, the new National Paediatric Hospital and St

James's Hospital which is approximately 600m away.

• The proposal includes the replacement at some future date of the existing maternity

hospital with a new maternity hospital, partially on adjacent lands (possibly those

owned by Dublin City Council, subject to agreement).

58

__ ....., Proposed Hospltlil Slte(s) Overall Site

Ordnance Survey Ireland Permit No. 8829 (e) Ordnance Survey Ireland I Government of Ireland

59

_____ sy

- 1 ocr 201s LTR·DATEO PL - _FROM

COOMBE HOSPITAL: assessment of strengths and weaknesses

Criteria Strengths I opportunities Weaknesses I risks

Co-located with adult teaching . Immediate tri·location with adult . 8 minute uncovered walk hospital jwalking distance} and existing currently crossing busy street

maternity hospital (corridor linkage)

Critical mass of sub-specialist care . National specialties x 12 . Many supra-regional special es A N BORD PLEANALA . Radiation oncology . Irish Blood Transfusion Servi eTIM ~ . BY Cryobiology Storage Facility(EUTCD} - 1 OCT 2015 All based on SJH campus

·- ......... Opportunities for transitional . At SJH there are a number o I.II'V "'"'''"lol .- " "'" adolescent service established protocol-based PL

transition programmes In pi

Extent of consultant linkages with . SJH linkages significant, plus Dublin children's hospitals neonatologists at Coombe

Depth and breadth of clinical and . Institute of Molecular Medicine, academic research Wellcome Trust I HRB Clinical

Centre for Clinical Research (hub In hub-and-spoke model}, . Centre for Advanced Medical Imaging (CAM I} . Mercer's Institute of Research on Ageing . Institute for Cardiovascular Sciences . Research CT facility All based on SJH campus

. European Research Laboratory (Coombe) . Potential for Quest Diagnostics Laboratory (Coombe}

Site suitability . largest urban site of those proposed. Relatively clear site with substantial greenfield element. Instant maternity hospital co-location at no cost. Corridor linkage possible

Access . Possible multiple access locations . Good public transport· 8 minutes from luas (Fatima). Good access for cars and construction traffic . QBCs on Cork Street and SCR, 5 bus routes

. Planning and design . 8 storey buildings approved In

previous planning permission . Good community support . Scope for some soft landscaping at lower levels

Project delivery I tlmelines . Relatively clear site . Site has to be acquired from

60

• Good space for construction . multiple owners

Value for money . Continuation of use of existing . Site acquisition cost maternity hospital.

• Least costly urban solution

61

Proposal for the MATER HOSPITAL campus

The Mater Misericordiae University Hospital is located In the north inner city. It is an adult

teaching hospital providing a number of national specialties.


The National Paediatric Hospital Development Board, which was established in 2007 to

develop the paediatric hospital on the Mater campus, has made a submission to the Review

Group which outlines its proposed redesign for the hospital following the rejection of the

planning applicati'?n by An Bord Pleanala in February 2012.

The Mater Hospital, Rotunda Hospital and Children's J.&I;WE~Pr"I~~:M'"x:einal~ife;a come together to make a separate submission to the

site, highlighting their synergies and presenting an al


The site proposed for the children's hospital is 2.47 he·~~t:lll~==i;;;:t:Fi;:1iSnii! Hospital building, a protected structure. A further 0.53 hectares is offered for a future

maternity hospital to replace the existing Rotunda hospital. The total site available is 3

hectares.


The original site area of 2.04 ha has been ceded to the State by the Sisters of Mercy for the

purpose of building a children's hospital. The additional space has been offered by the

Sisters of Mercy on a long lease with nominal rent.

Key features

• The site now proposed for the National Paediatric Hospital is the original site plus

the 1861 Mater Hospital building which is proposed to accommodate research and

education.

• An outline redesign has been presented to the Review Group which would be lower

than the original building design. There would be 4 storeys fronting on to Eccles

Street, rising to 9 storeys in the main building behind, which is broadly comparable

with the new Mater adult hospital.

62

• There are no ground-level green spaces available to the children's hospital but

winter gardens (i.e enclosed gardens) at upper floors would be incorporated.

• Planned car parking on site is for approximately 1,416 cars, with 444 serving the

adult hospital and 972 for the new children's hospital

• The proposal offers co-location with an adult tertiary hospital, and future tri-location

with a maternity hospital when constructed. The present Rotunda Hospital is 1.4km

from the Mater campus.

• The National Paediatric Hospital Development Boa~:d considers that the revised

design could save about €20m on the capital cost of the project. However, the Mater

I Rotunda I CUH Temple Street hospital group believes that significant further

savings could be achieved.

63

__ _,


Onlnance Survey Ireland Permit No. 8829

AN BORD PLEAN TIME BY -----t

- 1 OCT 2015 LTR·DATEO FROM

----t

(c) Ordnaance Survey Ireland I Government of Ireland

64

MATER CAMPUS: assessment of strengths and weaknesses

Criteria Strengths/ opportunities Weaknesses I risks

Co-located with adult teaching • 600beds hospital • On site co-location

• Corridor linkage

• Space for maternity hospital

Extent of relevant adult specialities • National specialties x 6

• Some supra-re1ional specialties Opportunities for transitional • Established protocol-based adolescent service transition programmes In place.

• Further transitional synergy with other core sub-specialties could AN BORD PlEJ ~NALA be established. TIME BY

Extent of consultant linkages with • Significant 1 Dublin children's hospitals - OCT 20 5

Depth and breadth of clinical and • Wellcome Trust/HRS I Centre for . '-11'\•UAi t:O FRO ~ '

academic research Clinical Research (spoke In hub- PL and-spoke model)

• Institute of Radiological Science

• Institute of Ophthalmology '

Site suitability • Part of site In public ownership • Very limited room for lateral (no acquisition cost) expansion

• Masterplan configuration • Hi&h plot ratio and site coverage. complete • Capacity to accommodate

maternity hospital yet to be demonstrated

Atteu • City centre location • Oiff~eult traffic circulation pattern

• Parking c::apacity confirmed in vicinity

• Dedicated ambulance corridor

• Optimum bus services

• 10 minutes Drumcondra train station

Planning and design • Favourable zoning • Sensitive location

• Site cleared for construction • High plot ratio & site coverage

• Compact co-location linkages • Capacity for expansion limited

• Time line and planning for maternity hospital yet to be demonstrated

Project delivery I tlmeline • Substantial work done on revised • Very restricted site for design construction

• Enabling works partially complete

• NPHDB have project team In place

Value for money • No acquisition cost

• Cost of abandoning site estimated at€24m by NPHDB

65

Proposal for the ST JAMES'S HOSPITAL campus

StJames Hospital is located in the south inner city. It is an adult tertiary hospital with a

number of national specialties including the National Bone Marrow Transplant Unit and the

National Centre for Hereditary Coagulation Disorders.


The submission is made by StJames's Hospital. They are supported by Our Lady's Hospital,

Crumlin, which has written to the Review Group in this regard. The Coombe hospital has

indicated its support for the StJames's proposal should its own proposal not be accepted.


A site area of 2.44 hectares is proposed for the children's hospital. A further 1.26 hectares is

proposed for a future maternity hospital. The total site area, inclu ng ~~d ANA LA hectares. TIME ____ BY ____ _,

Ownership of the site - J OCT 2015 LTR·DATEO FROM

The site is leased on a long lease by the StJames's Hospital Board With the freeRbtll" in the----1

ownership of the HSE. StJames's Hospital has been advised that, s~oitiu~mi!~;;;;i~:a;c::=:=:d chosen as the site for the new children's hospital, a recommendation would be made to

Dublin City Council for the disposal of the appropriate portion of the linear park along St

James's Walk on the southern side of the hospital site to StJames's Hospital.

Key features

• The outline design is for a building rising from 3 storeys on the western side of the

site to 9 storeys on the eastern side.

• The design includes green spaces at ground level between "finger" blocks and at

third floor roof level and winter (enclosed) gardens beside the wards at higher levels.

• There is limited open space in the immediate campus (see above regarding the linear

park owned by Dublin City Council).

• Planned carparking on site is for 1,500 basement parking spaces over three levels for

both the proposed children's and maternity hospitals. Some existing staff parking

within the hospital campus would be relocated off·site.

66

• The proposal is for co-location with an adult tertiary hospital, and with space to

develop a new maternity hospital to offer future tri-location. The Coombe hospital is

850m away from the proposed site for the children's hospital (GOOm from the

proposed entrance to StJames's at the LUAS Fatima stop).

• There are a number of low-utility buildings on the proposed children's hospital site.

Planning permission has been granted for their demolition.

67

_.._,.......,

Proposed Site Existing Site

Ordnance Survey Ireland Permit No. 8829


- 1 OCT 2015

0 100m

(e) Ordnance Survey Ireland I Government of Ireland

68

STJAMES'S HOSPITAL: assessment of strengths and weaknesses

Criteria Strengths I opportunities Weaknesses/ risks Co-located with adult teaching • 1020 beds, largest hospital in the hospital. state

• Space available for a new matemity hospital on the SJH campus

Critical mass of sub-specialist care • National specialties x 12 • Many supra-regional specialties

• Radiation oncology on site

• Irish Blood Transfusion Service on -. I ANa site

• Cryobiology Storage TIME ORo PLEA Facility(EUTCDI on site ~ALAI ---- ay

Extent of consultant linkages with • Significant -----Dublin children's hospitals - 1 ocr 2015 LTDn

Opportunities for transitional • Many established protocol-based

l -··uc:u

adolescent service transition programmes in place PL ---FROM - .... ~ • Further transitional synergy with

other core sub-specialties could • be established -Depth and breadth of clinical and • Institute of Molecular Medicine, academic research Wellcome Trust I HRB Centre for

Clinical Research (hub in hub-and· spoke modell

• Centre for Advanced Medical Imaging (CAM I)

• Mercer's Institute of Research on Ageing

• Institute for Cardiovascular Sciences

• Research CT facility

Site suitability • 6.3 hectares available including • New children's and maternity

• expansion space hospitals will consume most of

• Entire site in public ownership capacity for expansion of adult hospjtal

Access • Excellent public transport services • Risk of traffic congestion near the

• 4 bus services Rialto Gate • Luas stop on campus • 2 others adjacent

Planning and design • Favourable zoning • Capacity to accommodate height

• Permission granted for and bulk of the proposed new demolition of existing buildings children's hospital building yetto on proposed new children's be demonstrated hospital site notwithstanding current

• New children's hospital site permission for private hospital on borders linear park along the the site LUASiine • Overall proposed level of parking

on the SJH campus likely to be an issue

Project delivery I timeline • Need to decant existing buildings/uses on proposed new children's hospital site could cause delays

• Difficult site to build on

69

Value for money • No site acquisition cost • Construction cost likely to be

• Potential for significant more expensive than on a operational savings arising from greenfield site co-location with large and well- • Demolition and decanting costs managed adult hospital

AN BORD PLEANALA TIME BV ___ -t

- 1 OCT 2015

LTR·DATED ___ FROM __ _..

PL

70

Proposal for the TALLAGHT HOSPITAL campus area

Tallaght Hospital is an adult teaching hospital located at Tallaght in West Dublin.


The proposal is made jointly by Tallaght Hospital and South Dublin County Council.


The proposed site for the children's hospital is 3.17 hectares. A further 1.18 hectares is

proposed for the maternity hospital. The total site is 6.6 hectares including expansion space.


4.0 hectares is owned by Tallaght Hospital; the remaining 2.6 hectares is owned by South

Dublin County Council.

TJ:CN BORo PLEANALA - BY -Key features

• The site is centrally located within the town centre of Tall a hL - t OCT 2015 ·c., R·DATED PL

• Up to 1,000 basement carparking spaces are proposed over two levels underneath

the children's hospital.

• The proposal is for co-location with an adult teaching hospital, in a Tallaght Medical

Quarter which could accommodate related research and biomedical clusters.

71

B

-~ -..-.--


Onlnnnce Survey Ireland Permit No. 88Z9 (c) Ordnance Survey lrelnnd I Government of Ireland

ANBORD TIME BY -------- --------~

- 1 OCT 2015

72

TALLAGHT HOSPITAL: assessment of strengths and weaknesses

Criteria Strengths/~ortunities Weaknesses/ risks Co-located with adult teaching • 600 beds hospital • On site co-location

• Space for maternity hospital

Critical mass of sub-specialist care • National Service x 1

• Some supra-regional specialties

Opportunities transitional adolescent • Few protocol-based transition service programmes in place.

• Further transitional synergy with AN BORD PLEANAU other core sub-specialties could TIME BY be established.

_t_

Depth and breadth of clinical and • Affiliated with Trinity Health I U'-' f lUJ:J academic research Ireland

LTR·DATEO FROM _m_

Site suitability • Entire site in public ownership ' cJvo.cn I+:> I is

constrained in s•ze ana sfllllpe ... , adjoining Exchange Hall complex

• New children's hospital would have very limited expansion capacity compared with the

_11roposed maternity ho~ital

At:cen • Very good public transport • Risk of traffic congestion near services Tallaght town centre at peak

• Luas stop at hospital shopping times • 11 bus services

• Good access to the MSO Planning and design • Favourable zoning • Unattractive visual setting to the

• Building likely to comply with north of the site density and height standards • Planned road through site will

disrupt internal circulation at ground and first floor levels

Project delivery I timeline • Cleared site for new children's • Construction likely to hindered by hospital constrained site

Value for money • No site acquisition cost • Construction cost likely to be

• Construction cost likely to be less more expensive than on a expensive than on inner city site greenfield site

• Potential for significant operational savings arising from co-location with large adult ho~pital

73

:. ::.,.. ... -- -

Chapter 12 Identification of risk factors and recommended mitigation measures

Our terms of reference require us to advise the Minister on the implementation risks

associated with the different options. Some of these risks appi~UJILUW~W~--~--.

locations, while others are site·specific. Where possible, we su gesAt.la~QIUii i~~LA factors. TIME BV ___ --1

General risk factors - 1 OCT 2015

LTR·DATED FROM ---t

a) Health outcomes: As previously stated throughout this report, we strongly believe

that factors which contribute to the best health outcomes for children are of

paramount importance. Tri·location with an adult tertiary hospital which offers a

wide range of relevant clinical specialities and clear synergies in research and

academic activities and which facilitates the provision of transitional services for

adolescents, and with a maternity hospital, is most likely to achieve such outcomes.

Conversely, building the children's hospital in the absence of such tri-location risks

sub·optimal outcomes.

Should the Government decide to choose the option of a greenfield site, we believe

that this will need to include an adult teaching hospital, and will have ramifications in

terms of significant capital funding, access, planning, procurement and delivery

t ime.

b) Site suitability: Smaller sites are more likely to raise planning and construction

issues, and to leave less space for future expansion. An issue for the adult teaching

hospital is whether the development of both a children's hospital and a maternity

hospital would compromise the ability of the adult hospital to meet its own future

needs for redevelopment/expansion within its campus.

c) Access: Inner city sites are more likely to be difficult for construction traffic to

access. To minimise such difficulties, early consultation with the relevant local

authority is recommended, particularly where temporary access may be arranged.

d) Planning and design: We do not wish to appear to prejudge any future planning

application, and it is important to note that, except in the case of the Mater site, we

have only seen preliminary feasibility drawings for the proposed sites which were

prepared within a very limited timeframe.

74

A large building of 108,000 square metres will inevitably be bulky, and except in the

case of the larger site at Connolly Hospital, is likely be 8 to 10 storeys in height and

will give rise to planning issues which can best be addressed at the detailed design

stage, in consultation with An Bord Pleanala and the relevant planning authority.

e) Timelines: Where the site is wholly owned by the relevant adult teaching hospital, or

where public sector co-owners have indicated their willingness to transfer their lands

free of charge, risk of delay in acquiring the site will be minimised.

Some of the proposed hospital sites will involve the demolition of existing buildings

and/or the decanting of existing uses to new accommodation within the hospital

campus. If one such site is chosen, the delivery programme could be expedited if

necessary demolition/decanting works were undertaken (where planning permission

for such demolition has already been granted) while planning permission is being

sought for the new children's hospital. While this involves an element of risk, the

cleared site may prove of benefit to the adult hospital even if the children's hospital

did not proceed for any reason; this is a decision which can only be taken by the

teaching hospital in the light of their particular circumstances.

In general, construction of the new hospital on a clears e ~f'ie¥JNR M~BrNALA TIME BY

more constrained urban sites.

- 1 OCT 2015 Site-specific risk factors

LTR·DATED ___ FROM

Implementation risk factors which relate to specific potential tJ PL. ""tlinan __ _.

below, with risk mitigation measures suggested where appropriate.

a) Beaumont Hospital:

A major risk is delay caused by necessary demolition of buildings and decanting of

existing uses, notably the public car park. Very little can be done to minimise such

delay, as planning permission will be required for replacement structures, which need

to be completed prior to commencement of construction of the children's hospital .

Way-finding to the northern entrance to the campus could be improved, to relieve

traffic volumes on Beaumont Road.

Similarly, given the relatively constrained site, it is difficult to see how the planning risks

associated with a new building of up to 10 storeys high in a low-rise housing area can be

minimised.

75

- -- -.::;: -·-- -- - ....,.

b) Beaumont Belcamp:

This is a greenfield site which envisages Beaumont Hospital moving to the site in 2021.

This would leave the new children's hospital in a suboptimal state for at least five years.

It would require a policy decision by Government and concomitant funding. Part of the

site is in the outer airport noise zone. Public transport to the site is currently

underdeveloped on the site. Time would have to be allowed for acquisition of the site

from its private landowners I NAMA.

c) Connolly Hospital:

Connolly Hospital is a secondary rather than a tertiary hospital, and has a limited

research infrastructure compared with the other Dublin teaching hospitals. Substantial

resources and time would be required to bring it to a comparable strength.

The current open space zoning does not facilitate hospital development. While An Bord

Pleancila is not bound by development plan zoning when determining applications for

strategic infrastructure development, it would minimise any planning risk if Fingal

County Council introduced a variation of their development plan to facilitate hospital

development on the Sports Campus lands adjoining Connolly Hospital. The elected

members have indicated their willingness in principle to do so.

d) Coombe Hospital: Tt:eN BORD PLEANALA Time would have to be allowed for acquisition of the ite fro"n'rlts pfi~Yi ndowners

NAMA and Dublin City Council. - 1 OCT 2015 LTR·DATED

Existing redundant factory buildings would need to ~Ldemolishee and ~emainin

ground contamination remedied. It would expedite~~;;;:Zia::tif~:!!~~~d required to furnish a cleared site prior to its acquisition.

Consideration should be given by both St. James's and the Coombe Hospitals, in

conjunction with Dublin City Council, to improving pedestrian access between both

hospitals, including crossing a busy road and the opening of a pedestrian entrance to St.

James's at the Fatima Luas stop.

e) Mater Hospital:

The original weaknesses identified in the Joint Task Force report in 2006 and that

subsequently worked against the Mater site at planning stage have not been

substantially mitigated by the addition of the 1861 building complex, which will add site

area but not significant capacity. It is not clear at this stage if there is capacity on the

site for the proposed maternity hospital, having regard to the scale of existing

development and the scale of the new children's hospital. If this proves to be the case,

76

consideration might be given to finding a site for the new Rotunda Hospital in the

vicinity of the Mater.

There also needs to be a clearer focus on addressing public perception that access to

the site is difficult, which we do not consider to be the case.

f) St. James's Hospital:

The planning risk arising from the height and mass of the proposed children's hospital

could be reduced if the site were to be enlarged. Alternatively, consideration might be

given to developing a new maternity hospital on the offered Coombe site, thus allowing

capacity at StJames's.

Construction access is likely to prove difficult, and would need to be discussed with

Dublin City Council at an early stage if the site is chosen.

Finally, overall levels of staff parking on the campus would need to be reduced to

minimise traffic impacts.

g) Tallaght Hospital:

It would be helpful if the local road network to the north of the site could be upgraded

at an early date, to facilitate re-alignment of the existing hospital entrance road and to

provide for construction access to the site.

It is also suggested that the expansion area for the children's hospital should not be

used for surface car parking, as removing such parking at a later stage could create

delays. -AN BORD PLEANALA -

TIME_ BY

- ' ocr 2Dt5 -

LTR·DATED -J PL_ FROM _ __ __,

77

Chapter 13 Conclusions and recommendations

The decision about the location of the new children's hospital is not a simple one. The

original decision to build the hospital was made in 2006. Since then, through a number of

reviews and reports, there has been a consistency of opinion regarding its need not only for

Dublin but nationally and for its co-location with an adult hospital. Where it should be

located and what type of adult hospital it should co-locate with have been the subject of

debate for as many years. It not only replaces the three existing children's hospitals in

Dublin but, because of its size and pivotal role, will be the centre for determining the

national standards of care with which we treat our children in the future.

We received many offers and suggestions of sites, the majority of which were greenfield.

Should the Minister and the Government decide to choose a greenfield site, we believe that

it will need to include an adult teaching hospital, requiring very substantial investment ~f

human and capital resources to develop over time into an adult tertiary hospital with critical

mass supported by leading-edge research facilities, and may havf!T.~trremM1;:Jii~B;;;Jr,LA~l zoning, planning, procurement and time. TIME ___ BY ___ "'1

We are of the view that co-location is essential and tri-location o timal. It iS Jls9Glp,PtWnt

to note that 70% of the patients attending the hospital will come [91l.'tJA.VE~reater ~jR -- -t Area. Therefore, we considered only those site proposals which lfc supported by a Dub 10

Academic Teaching Hospital (OATH). Within that group of hospit

of sub-specialties and academic research. In 2006 the Joint Task Group shortlisted three

hospitals, namely St. James's, the Mater and Beaumont, because of their higher levels of

clinical complexity. These hospitals are still at that higher level, with StJames's Hospital now

having the widest range of specialties. However, all three have restricted sites to varying

degrees, which they have addressed in their proposals.

This is not a standalone decision; in making it a balance must be struck between the clinical

and research synergies that the adult hospital can bring versus the restrictions that an

established site will impose. Our assessment of the comparative strengths and weaknesses

of the six potential co-location sites for the new children's hospital has shown that, while

there is no single perfect solution, some locations are more advantageous than others.

Therefore the decision must be based on key parameters including optimal clinical and

research synergies, site suitability and planning risk, together with cost and time benefits.

Hospitals' proposals

We considered the proposals from the hospitals which made submissions to the Group. In

their indicative costs, some proposals have presented significant cost savings and have

included the maternity hospital within the overall budget.

78

AN BOAO PlEANALA TIME BY

- t ocr 201s The proposal for the Mater site has been significantly rewor J-d~iR-?J~efiflWvbf its

----f

height. It also includes the offer of the 1861 building (a prot.~~:!:!:~~::!~~~~=:l such as research and education. This will add space but not significantly impact on site

capacity. Whether the site is sufficiently large to accommodate a high quality maternity

hospital as well as the children's hospital remains a concern.

Should the Government choose not to go ahead with the revised Mater proposal, we

strongly recommend that they take into account in their deliberations the internationally

recognised clinical and research platforms that the existing adult hospitals offer and the

design and planning restrictions of each site, details of which are outlined in Chapter 10.

From a clinical and academic perspective, we identified StJames's Hospital as the existing

OATH that best meets the criteria to be the adult partner in co-location because It has the

broadest range of national specialties and excellent research and education infrastructure.

However, the proposed St. James's Hospital plan offers the smallest site for construction of

the new children's hospital, albeit with greater site capacity overall (see Table 1 on page 48),

has some drawbacks in terms of site suitability and is not without planning risk.

The site adjacent to the Coombe is large enough to accommodate the new children's

hospital and to allow design flexibility. Furthermore, corridor-linked co-location of the new

children's hospital to the existing Coombe maternity hospital (or a new maternity hospital at

StJames's Hospital) can establish the maternity co-location conditions for a level4 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 StJames's and Coombe proposals, given their proximity to each other, if they

presented a joint plan.

From a design and planning perspective, the sites adjoining Connolly and the Coombe

hospital offer the best potential for future expansion and a landscaped setting.

In our view, the 36 hectare site on the National Sports Campus lands proposed by Connolly

Hospital offers an attractive parkland setting and practically limitless scope for future

expansion. Access by car is excellent, and existing bus services could be upgraded to meet

demand.

However, Connolly Hospital would need very substantial investment of human and capital

resources to develop over time into an adult tertiary hospital with critical mass supported

by leading-edge research facilities, and even if such resources could be made available it

could take several decades to achieve such high standards of clinical and research

79

excellence. The proposed integration with Beaumont and RCSI, and the Universities, would

have to be accelerated.

The site at Beaumont is located in a low-rise housing area, and may face difficulty in gaining

approval for a large building up to ten storeys high, and in any event construction of the

children's hospital cannot start until the existing multi-storey public car park and other

buildings are rebuilt elsewhere on the campus.

The design and layout of the new hospital on the Tallaght site would be significantly

constrained by the proximity of an existing apartment complex.

Our terms of reference require us to make recommendations 'n th<> ... "::. !.<:'!"':."

by the Minister and the Government. Once the decision on the site'-\Nsf%~f?a~M;&~ALA recommend that the following needs to be urgently addressed TIME BY ____ -t

- 1 OCT 2015 Ambulatory and Urgent Care Centre

LTR·OATED __ FROM __ --t

The plan for the Ambulatory and Urgent Care Centre must also J;tlfe~~~r~· =t::·~~:±'dM:Dd=:lta=:::::t decision about location of the new children's hospital. The number and location of urgent

care centres in the Dublin area can only be determined once the site for the hospital is

selected. We also advise that care must be taken in defining the clinical objectives of these

urgent care centres, which should not be so large as to undermine the effective working of

the new children's hospital instead.

Vision and governance

The creation of a new children's hospital is a major statement by our nation for our children.

Since the decision was made, a great deal of energy and thought has gone on the type of

building we should have. We believe that in tandem with the building development there

should be an integrated national paediatric plan that brings the existing children's hospitals

together as a single entity as matter of urgency. Our new hospital will be at the centre of

care that will cascade from it to regional centres. In our view, these centres would become

part of the new children's hospital rather than paediatric departments in regional hospitals.

To achieve this, we recommend that the Minister considers establishing a Board to run the

new hospital and to start working now towards integrating the existing children's hospital

services including the Neonatal Intensive Care Units, transport services, regional paediatric

units and, ultimately, coordinate all paediatric services in the country under a single budget

holding paediatric directorate. As stated earlier this will also require a significant investment

in ICT.

80

In our view these processes should be undertaken promptly as it will be the governance

structures and the people who work in this hospital that will ensure its excellence.

-1 ANa

TIME ORO PLEANALA , - BY -- _____ ,

- 1 ocr 201s -L.TR·DATEO PL ~ FROM

~ ·- - -----· j

81

~ ·T • '

~- ;

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