Our Ref: 29N.PA0043 P.A.Reg.Ref: Your Ref: Maria Conway Charlotte Sheridan Sheridan Woods Architects. 10 Adelaide Road, Dublin 2. 8th October 2015 Dear Sir/Madam, Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin. An Bord Pleamila An Bord Pleanala has received your recent submission in relation to the above mentioned proposed development and will take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed. The Board will revert to you in due course with regard to the matter. Please be advised that copies of all submissions I observations received in relation to the application will be made available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County Council and at the offices of An Bord Pleamila when they have been processed by the Board. If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above mentioned An Bord Pleami.Ja reference number in any correspondence or telephone contact with the Board. Yours faithfully, En cis. ADHOC/PA0043/0 1 (..t Sr;iid Manilnhridc. Atlt.t Cliath I. Tctl !IH X5X KIIMI Tc. Gl.u>Anuul LnC.>.l L.iithrc.an \\\\\\ rrcom.ala \Vch Rimnhphu'l hunt • pk;mal• ic I m.>il l>l Street Duhhn I
Transcript
Our Ref: 29N.PA0043 P.A.Reg.Ref:
Your Ref: Maria Conway
Charlotte Sheridan Sheridan Woods Architects. 10 Adelaide Road, Dublin 2.
8th October 2015
Dear Sir/Madam,
Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.
An Bord Pleamila
An Bord Pleanala has received your recent submission in relation to the above mentioned proposed development and will take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed.
The Board will revert to you in due course with regard to the matter.
Please be advised that copies of all submissions I observations received in relation to the application will be made available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County Council and at the offices of An Bord Pleamila when they have been processed by the Board.
If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above mentioned An Bord Pleami.Ja reference number in any correspondence or telephone contact with the Board.
L.iithrc.an Grc.a,~un \\\\\\ rrcom.ala I~ \Vch Rimnhphu'l hunt • pk;mal• ic I m.>il
l>l Matlhmun~h Street Duhhn I
Our Ref: 29N.PA0043 P.A.Rcg.Ref:
Your Ref:
Paul O'Neill National Paediatric Hospital Development Board CIO G.V.A. Planning & Regeneration Floor 2, Seagrave House 19-20 Earlsfort Terrace Dublin 2
5th October 2015
Dt'ar Sir,
Rc: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.
Enclosed for your information is a copy of submission(s) received by the Board in relation to the above mentioned proposed development.
If you have any queries in relation to the matter please contact the undersigned officer of the Board.
Please quote the above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,
Encls.
PA08.LTR
(>4 Sr.i•d Mamlhhritlc ll.uk ,\liM ChJih I
Tcil 101) XSX K IIKt Tel Glao Aitiuil I K•!lt 115 175 LoC.tll
Luthrdn GO:a,,ion '"' w plc;mala k \\'ch R innlltJlh<"l hortl@ plc;utala.ic Email
-,;~ I
1>4 ,\larlhmllugh Slrccl.
Duhlin I
Our Ref: 29N.PA0043 P.A.Reg.Ref:
Your Ref:
Chief Executive Officer Dublin City Council Civic Offices Wood Quay Dublin 8
5th October 2015
Dear Sir/Madam,
Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.
An Bord Pleaml.la
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 Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,
En cis.
ADHOC/PA0043/02
(>-1 Sr;iid M.tuilhhri<l~. u~ik Arh~ Clioth I.
Tell ((II • H~H H lOCI 'ld Gl.u• .\,tiull 1!1'!0 2· ~ I'~ LnC:tll
l:tc\ (O()l!7211>l<~ !.1\
l...uthrc.m Grc.,,.un \\ ww.p c~lnaJa tc \\'ch
ll.iumhphU\1 ht>rll··· rk:tll'll:t ·~ l.m:tol
_..,_ 1.:1 :\l.ult.'ft ·'•" '>Unt ,
()1lt>hr I
Our Ref: 29N.PA0043 P.A.Reg.Ref:
Your Ref:
Chief Executive Officer Fingal County Council County Hall Main Street Swords County Dublin
5th October 2015
Dear Sir/Madam,
Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.
An Bord Pleamila
t
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 Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,
?tOO lfnSomers ~
x cutive Officer Direct Line:O 1-8737107
Encls.
ADHOC/PA0043/02
(~ Sraitl Mamlhhrit.lc. ll.ulc Ath;t Cliath I
Tctl (01)1!5M MHMI Tel
GhK> Aituiil IK'.I() 175 175 LnCtll
Liithrcdn Grca-.iin "" w rlc;m:ol.t tc \\ch IHnmhJll""' IK•nlli' t•lc:on:ola ic I mat I
M .\brll~>mugh .Street L>uhlin I
Our Ref: 29N.PA0043 P.A.Reg.Rcf:
Your Ref:
Chief Executive Officer South Dublin County Council County Hall Tallaght Dublin 24
5th October 2015
Dear Sir/Madam,
Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.
An Bord Pleamila
I I
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 Pleanala reference numberin any correspondence or telephone contact with the Board.
l'ac' CUI l xn ~I>X.t Fax L.uthrc:in Gn:a"iin "" w plcan;ola.ie \\ch
Rinmhpht"t hnnHi"• pkanal:uc Em;ul
J
~ I .,_. . -
l..t :\larlhnmugh ~t~d
Duhhn I
• SHERIDAN WOODS I architecture I urban design I planning
Submission To An Bord Pleanala
Third Party Submission
In respect of Direct Application To An Bord Pleanala Under Section 37e
For Permission For A Period Of 10 No. Years For The Development Of The Proposed New National Paediatric Hospital, Which Is An Integrated Health Infrastructure Development Comprising 6 No. Principal Elements And Ancillary Development: (I) A 473 No. Bed New Children's Hospital (Up To 118,113 Sq.M. Gross Floor Area) At The St. James's Hospital
Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (li) A 53 No. Bed Family Accommodation Unit (Up To 4,354 Sq.M. Gross Floor Area) At The St. James's Hospital
Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (Iii) A Children's Research And Innovation Centre (Up To 2,971 Sq.M. Gross Floor Area) At The St. James's Hospital Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (lv) A
Construction Compound At The Former Unilever Site At Davitt Road, Drimnagh, Dublin 12; (V) A Children's Hospital Satellite Centre At The Adelaide & Meath Hospital Dublin (Tallaght
Hospital), Belgard Square North, Tallaght, Dublin 24 (Up To 4,466. Sq.M. Gross Floor Area); And (Vi) A Children's Hospital Satellite Centre At Connolly Hospital Campus In Blanchardstown,
Dublin 15 (Up To 5,093 Sq.M. Gross Floor Area).
An Bord Pleanala Reg Ref 29N.PA0043
Prepared On Behalf Of .---A-N_B_O_R_D_P~L~E~A~~~-.r.ll.A-:--_p,
TIME \ .S : oo IV.....:;,-:;::~~ AN BORD PLEANALA Received: o 2-ft of I s-
1.0 Introduction This submission has been prepared by Sheridan Woods Architects + Urban Planners Ltd, on behalf of our client, Ms. Maria Conway of 47 Brookfield Road, Kilmainham, Dublin 8. Our client wishes to object to the proposed development and we request that the development is refused planning permission. We enclose here a cheque to the sum of €50.00 being the appropriate fee. We set out here an over view of the overall development of the proposed National Children's Hospital, and Family Accommodation Unit and set out grounds for refusal in relation to the overall development, and with particular attention to the potential planning impacts of the development on our clients property, No. 47 Brookfield Road.
2.0 Context The site for the proposed new children's hospital and associated Family Accommodation Unit relates to the western section of the existing St. James's Hospital Campus contiguous to the South Circular Road, Brookfield Road and Cameron Square.
The South Circular Road is characterised by two storey dwellings, set back from the pavement with front gardens enclosed by railings. The South Circular is lined with mature deciduous trees and presents a formal appearance. Brookfield Road comprises more varied house types along the street, principally two storey dwellings, the dwellings to the west of the street are two storey with the entrance and front garden up a number steps above the street, while the dwellings to the east are two storey and entered at street level, also with front gardens enclosed by railings. The dwellings to the eastern side of the road back onto the hospital grounds. There are two single storey cottages along the street at the entrance to Cameron Square. Cameron Square is accessed off Brookfield Road and comprises two storey dwellings formally arrange in a square, with front gardens enclosed by railings. All three residential areas present their own distinctive character, and benefit from a strong sense of place.
St. James Campus presents a two storey high rendered boundary walls to the South Circular Road, with an entrance to the Campus from Brook Field Road, and further high walls and red brick hospital buildings facing Brookfield Road. This boundary is characterised by trees, some of which are mature specimens, they are located both along sections of the hospital boundary and internally which are visible from the South Circular Road and Brookfield Road.
3.0 Proposed New Children's Hospital and Children's and Family Accommodation Unit The proposed New Children's Hospital is proposed as a rectangular block facing St. James Walk to the south, the South Circular Road, and Brookfield Road to the west, and the northern and eastern facades are internal to the campus. It includes the replacement of the existing boundary with a new boundary, a 'moat' separating the building from the street along the 'south fingers', a set back building line for the proposed podium structure, that further steps back to an upper level Pavilion ward blocks. The building line steps in along the western facade to create an entrance to the New Children's Hospital at Brookfield Road.
The proposed Family Accommodation unit will include the replacement of the existing boundary wall to Brookfield Road, and the development the new building to the street edge. The proposed building form returns into the campus, forming the new entrance to St. James Campus. The Family Accommodation Unit extends to the rear of existing dwellings on Brookfield Road and Cameron Square.
4.0 Key Planning Issues The relevant guiding planning document is the current Dublin City Development Plan 2011 -2017. We have reviewed the proposed development in the context of the Development Plan. Based on this review it is considered that the proposed development by reason of its inappropriate scale, bulk, mass and layout materially contravenes the Development Plan, and as a result is likely to seriously and adversely detract from the residential amenities of the South Circular Road, Brookfield Road and Cameron Square. A summary of our review is as follows:
-· ··~\ ·
0 2 OCT '015 LTR·OATID FltOM---1
SHERIDAN WOODS
4.1 Land Use Zoning and Transitional Zones The subject site is zoned Z15 in the Development Plan. the objective of which is "To protect and provide for institutional and community uses and to ensure that existing amenities are protected." Under this zoning "buildings for the health, safety and welfare of the public and Medical and related consultants" are permitted in principle, with "car pari< ancillary to main use" open for consideration. uEducation" and "Residential Institution" are also both permitted in principle. Accordingly, the principle of development is acceptable.
The development plan notes that while the zoning objectives and development management standards indicate the different uses permitted in each zone, it is important to avoid abrupt transitions in scale and use zones. The development plan indicates that 'In dealing with development proposals in these contiguous transitional zone areas, it is necessary to avoid developments which would be detrimental to the amenities of the more environmentally sensitive zone.' (Para 19.1 pg 192)
Particular reference is made to zones abutting residential areas or abutting residential development within predominately mixed-use zones and notes that particular attention must be paid to the use, scale, density and design of development proposals and to landscaping and screening proposals in order to protect the amenities of residential properties.
The Brookfield I South Circular Road and Cameron Square land are zoned as follows: Zone 1 To protect, provide and improve residential amenity and Zone 2 To protect and I or improve the amenities of residential conservation areas which are more environmentally sensitive zones. The scale and fonn of development as proposed has a detrimental impact on the amenity of these areas and is contrary to the development plan guidance, which is further outlined below.
4.2 Development in Excess of Development Plan Standards The quantitative measures to assess the scale of development include Plot Ratio, Site Coverage, Building Height and distances achieved between new and existing residential areas.
4.2.1 Plot Ratio The indicative plot ratio of Z151and is 0.5-2.5 in the Dublin City Development Plan. Plot ratio is a tool to help control the bulk and mass of buildings. It expresses the amount of floor space in relation (proportionally) to the site area.
The NCH Planning Report indicates that: 'The new children's hospital building, including the family accommodation unit (excluding the Children's Research and Innovation Centre), measures 92,031sq.m. (above ground) on a site of 48,350 sqm., which results in a plot ratio of 1.90'
We contend that the plot ratio expressed for the proposed development is not an accurate representation of the extent of development proposed.
For the purposes of calculating plot ratio. it is conventional, and appropriate to calculate the site area to include only such land as lies within the t artilage of the related buildings. It is inappropriate to include the lands outside the site boundary or building line. Including these lands gives a distorted view of the distribution of the bulk of the building fonns on the sites. The red line boundary indicated in the proposed development drawing extends to the centre of the road to the west, and it incorporates the linear park to the south. Furthennore the cumulative site area includes the roads that separate the distinctive development areas within the overall development. Appropriate site boundaries are illustrated in Figure 1 below.
In this regard we submit that the plot ratio should be calculated for the distinctive development parcels independently including the Family Accommodation, and the New Children's Hospital. To illustrate this we have indicated the configuration of these parcels whic · Family Accommodation site, and the new Children's Hasp· and consequent plot ratios as follows:
Issue 002C_October 1, 2015
o 1. OCl 20i5 l.TR..OAlEO 47 Brookfi~:~~~·~~I.WW!i~
PL
... ., ..• ... ....... ... , .. -a-
New Children's Hospital - As Proposed Site area within the t artllage of the site New Children's Hospital Site
Total area development proposed above ground NCH Plot Ratio
New Children's Hospital - Wrth E~ttensions within the New Children's Hospital Site Total area of development proposed above around Total area of extensions above ground (Children's Meadow site and over the emergency site only) Total Area Plot Ratio
Family Accommodation Site area within the a artilaae of FamilY Accommodation Site
Total area development proposed above ground Family Accommodation Plot Ratio
SHERIDAN WOODS
RD PLEANALA TtME B¥ ___ _, ,- -+---
37,556 sqm
87677 sqm 2.3
s7sn sqm 20,000 sqm
101.sn sqm 2.9
2348 sqm
4024 sqm
1.7
Based on this calculation, the actual plot ratio for the New Children's Hospital is the upper level of the 'indicative plot ratio' indicated in the development plan. This is inappropriate in the context of a 'transitional zone', and together with the proposed extension to the hospital, the eventual plot ratio will exceed the development plan standard.
4.2.2 Site Coverage The development plan indicates that 'Site coverage is a control for the purpose of preventing the adverse effects of over development, thereby safeguarding sunlight and daylight within or adjoining a proposed layout of buildings. Site coverage is the percentage of the site covered by building structures, excluding the public roads and footpaths. '
The development plan standard for Z15 land use zoning is 50% of the site. On the basis that the site coverage excludes public roads and footpaths, the site areas as calculated in the plot ratio assessment above apply (Appropriate site boundaries as illustrated in Figure 1 above) In this regard the site coverage standards achieved are as follows:
lssue002C_October 1, 2015 -4- 47 Brookfield Road, Dublin B
SHERIDAN WOODS
New Children's Hospital- As Proposed ---Site area within the curtilage of the site New Children's Hospital Site 37,556 .sqm= 1RD PLEAr-4ALA A 1\ f'l.l R 1 Total ground floor of the NCH 18.JJ 1 ~in BY Site Coveraqe ~ %.I l_M_E -- -
~ 2 OCl 20\5 New Children's Hospital -With Extensions within the New Children's Hospital Site
FROM Total ground cover floor of the NCH ~IRATI 0 Total area of ground cover of extensions (lncl Under Croft) (ChUdren's · ·~m --Meadow site and over the emergency site only) ~l (15,000 In buildings ranging from 4 to 6 floor (pg 29 draft capacity 300 t study) say average 5 floors G! 3000sqm ground floor (5,000 sqm 3-storey building from Level 02 upwards @ 1666sqm
1666 Total Area 23047 sqm Site Coverage 61%
Family Accommodation Site area within the curtilage of Family_ Accommodation Slle 2348 __§gm
Total ground cover of Family Accommodation 1388 sqm Site Coverage 59%
Based on this calculation, the actual site coverage for the New Children's Hospital is the upper level of the 'indicative site coverage' indicated in the development plan and together with the proposed extension to the hospital, the eventual site coverage will significantly exceed the development plan standard. Furthermore, the site coverage for the Family Accommodation also exceeds the Development Plan standard. In the context of the location of the proposed development in a 'transitional zone' this scale of development is contrary to the development plan standards.
4.2.3 Building Height The development plan indicates that the maximum height standards set out at section 17.6 shall have precedence over the indicative Site Coverage. Notwithstanding, the contention that the proposed development conforms with the Development Plan Site Coverage standards in the development proposals, building heights will take precedence. Dublin City Development plan is prescriptive in terms of permissible building heights. The development plan defines the permitted height for various areas in the Dublin context which is as follows- unless otherwise approved in a local area plan: The St. James Campus is located within the area defined as the inner city. This area is categorized as 'Low- rise (relates to the prevailing local height and context)'. The permitted height is 'Below 28m' for commerdal development.
The development plan indicates that 'For the sake of clarity, plant rooms are included in the height definition.' Also that: 'No height greater than that specified for the inner city category will apply until a LAP is adopted. '
The development comprises a parapet building height of 12.6m, to 14.1m including the proposed balustrade above ground level facing the South Circular Road, stepping up to a roof height of 34.95m and 37 .95m to chimney height. Accordingly, the roof height exceeds the permitted development plan height of 28m by 6.95m, and if permitted would materially contravene the Development Plan.
The planning report relies on previous planning permissions as precedence, in particular the Mercer's Institute for Successful Ageing (MISA) (3607/12), and the Co-Located Private Hospital (Dublin City Council 2751/09 ABP Ref Pl29S.236070). We have illustrated the building alignment and form of the previously permitted Co-Located Hospital in Figure 2 below.
The MISA building height to the top of the roof permitted is 28 metres, the proposed height in metres to parapet is 29.1 metres and for a small section of the stair access core is 30.85 metres. This development generally conforms with the current development plan standards, and given its context opposite existing 6 I 7 buildings at Herberton, it is more contextual with its immediate environs. This development is lower in building height than the proposed National Children's Hospital.
Figure 2 Illustrates alignment and position of previously permitted Co-Located Hospital, Including tower block and podium block Source: Extract From New Children's Hospital Planning Application Drawing BOP O'Connell Mahon Architects Level 00; Annotated by Sheridan Woods, 2015
The pennitted Co-Located Private Hospital located on part of the site of the proposed New Children's Hospital comprised an eight storey block with roof level at 52.96 AOD Malin Head 1 32.85m over ground level. The top of the proposed parapet is set at 54.4 AOD or 34.29m over ground. The eight storey block however, was set back from the South Circular Road by 40.5m. Also the foot print of the podium block was 60m in length along the South Circular Road, with a set back, and further 13.5m length totaling 74.5m length. While the roof height of the current proposed development is generally consistent with the previously proposed private hospital, there are notable differences. The taller element of the previously pennitted private hospital comprised a significantly smaller footprint of 95m length, and 20m width presenting a slender building fonn that was substantially set back from the South Circular Road.
It is also notable that the previously grant of pennission for the private hospital development has expired (Pennission granted in June 2010). The application was determined before the adoption of the current development plan where height restrictions are more prescriptive. There was no application to extend the duration of the permission, and we submit that it is unlikely that the development would have been granted an extension of duration of permission, on the basis that it would materially contravene the development plan in terms of building height.
Accordingly the overall height of the proposed national Children's Hospital exceeds the development plan. It is not reasonable or appropriate to rely on the precedence of the previously permitted developments on the basis that the setting of the MISA contrasts with the setting of the proposed national Children's hospital and is accordingly not comparable, and also on the basis that the overall configuration of the previous co-located hospital contrasts significantly with the current proposals in footprint, and building set backs and is also not comparable.
4.4 Impact on Adjoining Residential Amenity - Overall Context The cumulative impact of the higher range of plot ratio, excessive site coverage and building height suggests overdevelopment of the site. The consequence of overdevelopment generates adverse overshadowing, overlooking of adjoining residential areas.
4.4.1 Overshadowing The overshadowing analysis carried out in Chapter 13 of the EIS demonstrates that the proposed development will cause overshadowing along the South Circular Road, and Brookfield Road in the morning from early morning to mid morning. We note that the assessment of the previously permitted co-located private hospital did not generate overshadowing primarily due to the separation between residential properties and the upper elements of the development, and the orientation thereof. (As noted in the Inspectors Report PL29S.236070).
Given the separation distances and the proposed heights, the proposed development will result in generating adverse overshadowing to the South Circular Road and Brookfield Road in particular. The extent of overshadowing will result in the loss of sunlight on the street, and consequently the overall appearance, ambiance and amenity of the streets, and a reduction in the sunlight currently enjoyed by the residents of the South Circular Road and Brookfield Road in particular.
4.4.2 Overlooking The distances proposed between the proposed development and the existing residential development are set out in the table here.
Location Opposing Use Distance Previously permitted Setback from existing buildings (12.5m tram boond•ry 10 plinth, and 40m tram boond•ry to towerelementl
South Circular Road I 32.5m Junction with Setback from front wall Mountshannon or dwellings to plinth
level (20m to sile boundary, with 12.5m setback) 60.&m set back rrom front wall of dwelling to tower (20m to site boundary, -40.5""
to gable of Family Ground Floor 18.6m Accommodation
First Floor 22m ( to main wall of house)
Second Floor 27.6m to 'North Flpgers 25.7m
The development plan requires a separation of 22m between 2 storey dwellings in order to protect their amenity. This standard is applicable in this context. This standard is not met along the South Circular Road in relation to the New Children's Hospital, it is not met on Brookfield Road in relation to the Family Accommodation Unit, and it is not met in relation to the rear of Cameron Square. Furthermore, this distance is a minimum distance, and greater distances should be provided where buildings exceed two storey in height.
The previously permitted co.located hospital development on part of the New Children's Hospital site was positioned 12.5m from the St. James Boundary, which allowed for 32.5m distances between opposing structures on the South Circular Road. The proposed development is a significantly closer than the previously permitted development.
The proximity of three storey with a roof garden, stepping to four story. and a further three storey structure facing the existing two storey structures will cause adverse overlooking that will significantly detract from the amenity of the existing dwellings on the South Circular Road, Brookfield Road, and Cameron Square. The proposed development is below and just within the minimum distances required in the development plan for the lower level structures where over1ooking is likely. Furthermore, given the height of the opposing structures at the lower and upper levels, there will be a significant altered perception of overlooking generated and resultant loss of residential amenity of the existing dwellings on the South Circular Road, Brookfield Road and Cameron Square that will be visually obtrusive and have an overbearing impact on the amenity of the residents . .
4.5 Impact On Amenity Of No. 47 Brookfield Road We have carried an assessment of the impad of the proposed development on our client's property. This includes a review of the existing amenity, a description of the location of the proposed development relevant to No. 47, and an assessment of the impad of the development with regard to visual impact, over1ooking and overshadowing.
p
Location No. 47 is located to the north western side of Brookfield Road. The dwelling currently front onto an existing concrete boundary wall to the hospital, with set back two storey brick structures.
Existing Amenity The front of the dwelling enjoys early morning eastern sunlight from sunrise to mid morning.
The dwelling faces an existing concrete blockwork wall and a two storey structure that fonns part of the hospital.
The street is characterised by two storey structures. Proposed Development The proposed Family Accommodation Unit is located to the east of the dwelling. The FAU presents an 11.95m high facade that steps up to a 15m high structure facing the dwelling. The separation distance between the new structure and the existing dwelling is 14.16m A conference room is proposed at ground floor level that is obliquely position opposite the dwelling. The ground floor level is consistent with the ground floor level of the dwelling. Bedrooms are proposed at the upper two floors. The main entrance to the New Children's Hospital is located south east, in a position closer than the existing entrance to the hospital to an large open piazza. Landscaping proposals to the front of the block suggest the inclusion of street trees.
4.5.1 Impact Of Proposed Development
Visual Intrusion Given the close position, height and scale of the proposed Family Accommodation Unit it will visually dominate the views from the front of the dwelling at ground and first floor level. As a result of this it will be both visually intrusive and have an over bearing Impact on the residents of No. 47 Brookfield Road. The views southwards from the front window will be further enclosed by the AFU building stepping up to four floors to the new entrance plaza. The overall impact is an oppressive enclosing effect on the dwelling, that detracts from its residential amenity.
SHERIDAN WOODS
View Of Dwelling
.. a • •
::1'· 5:·~ :! ,. - 1-. • I l::olvlt ~ ~a ~ : ·, "
Extract From New Children's Hospital Planning Application Drawing BOP O'Connell Mahon Architects level 00; Annotated by Sheridan Woods, 2015
Source: Extract New Children's Hospital Phon,nlnn
Application Drawing BOP O'Connell Mahon Architects level 00; Cropped by Sheridan Woods, 2015 Facades Facing The Rear of No. 49 Brookfield Road
The EIS assesses the impact of the development on adjoining property, No. 49 Brookfield Road and specifically calculates the Vertical Sky Component, and the access to sunlight. A reduction in both in noted for both dwellings and the proposed Family Accommodation Unit is the primary contributor to this reduction.
While the existing sky component and access to sunlight from the front of the property is low for both dwellings, the combination of the proximity of the AFU and the reduction in the sky component and access to sunlight will represent a serious depreciation in the enjoyment of our client's property. This significantly detracts from the amenity of our clients property.
Source: Extract From EIS Chapter 13 Figures 13 Shadow Plans show the Proposed shadow plans for each hour on 21st March I September from 8:00am shadow plan illustrated - Location of No. 47 Brookfield Road Highlighted -Annotated by Sheridan Woods 2015
Overlooking The separation distance between the Family Accommodation Unit and the front fac;ade of No. 41 is just 14.16m. The proposed ground floor conference room will obliquely face the living window of our clients property, and bedrooms at first floor.
The separation distance is well below the development plan separation distances. The proximity and nature of use of the proposal will generate overtooking of our dients property and will result in a significant loss of privacy to our clients property.
Landscaping The landscaping plan suggests the provision of street trees adjoining the proposed family Accommodation opposite our client's property.
There is insufficient space along the foot path to accommodate the trees and to ensure their successful rowth.
Issue 002C_October 1, 2015 -10-
Source: Extract From EIS Chapter 13 Figure 13.17 illustrating Impact of Family Accommodation Unit On the sky component For No. 49 Brookfield Road (Property Adjoining no. 47)
AN BORO PLEANA
TIME BV----+--1
0 2 OCT 2015 I TR-DATED FROM ~ ------ ~---1 Pl
47 Brookfield Road, Dublin 8
4.6
SHERIDAN WOODS
Based on the above analysis and previous findings we submit the following to An Bord Pleanala:
• The close proximity of the family Accommodation Unit opposite the front facade of our clients property will be visually intrusive and have an overbearing impact on the amenity of our clients property.
• The proposed development will result in the loss of sunlight to the property in particular in the morning at sun rise to mid morning,
• The proposed development will result in the loss of vertical sky component as a consequent of the proximity and height of the proposed development, and will have a closing effect on the dwelling.
• The proposed development will generate adverse over1ooking as a consequence of proximity and separation distance between the proposal and our clients dwelling, and will result in the loss of privacy enjoyed by our client.
• The change in scale of development along the street is incongruous and detracts from the integrity of the two storey architectural character of the street of the street.
• The provision of the new entrance to the hospital northwards to Brookfield Road will result in a significant change of use along the street, giving a sense of being part of the hospital activity and will detract from the existing residential amenity. This will have a particular impact on our clients property.
• The scale of new development along the street, together with the intensified hospital use on the street will significantly erode the existing sense of place currently enjoyed by the Brookfield Road community.
• The increased traffic will significantly alter the character, noise levels, and environmental quality of the street.
• There is insufficient space along the proposed footpath to accommodate the proposed street trees to the front of the proposed Family Accommodation Unit.
It is requested that the proposed development is refused permission on these grounds.
Mitigation Measures: If it is intended to permit the proposed development, we request that the Family Accommodation Unit is redesigned to take account of the negative impact that the structure has on the amenity of our client property and the provision of additional landscaping. in this regard we request the following:
•
•
•
•
That the building is set back further to increase the street width, that the overall height of the structure is reduced to limit the enclosing and overbearing impact. We request that the street pavement is designed to allow for the successful planting of new street trees opposite our clients property adjoining the proposed Family Accommodation Unit. That the extent of tree planting is increased to the front of the Family Accommodation Unit to further lessen the immediate impact to our clients. That landscaping, such as the provision of a line of trees is positioned to the edge of the proposed plaza, to create a separation between the proposed entrance to th~ hospital, and Brookfield Road. The purpose of this is to limitthe ~t:me - c:; ANALA residents on Brookfield Road to the activity of the Hospital, an~~~~Q..Pdfme· main entrance from Brookfield Road in order to maintain the · ntity_ of Brookfield B~ L ----, distinct neighbourhood, and not part of the overall hospital ca ii~E---
Impact On Streetscape 01 OCl 20\S In addition to the impact of the proposed development on the residentia amen~y .. oJ"" fR~ _ -surrounding properties, the scale, massing and design of the proposed U1b~
have a considerable negative impact on the immediate streetscape and lthliJ~(a~ct~e;r~o~f~i#l~f:::;::::::::;; The existing South Circular Road, Brookfield Road, and Cameron Squart rom a strong sense of place and identity. Paragraph 16.1.8 of the Development Plan gives guidance on urban form and architecture, and indicates that urban blocks should be designed to promote permeability and walkabllity, thereby integrating with the existing urban fabric. It is reasonable that the hospital campus should conform to this aspiration. The development plan indicates that urban block lengths greater than 1OOm should be avoided. Developments should relate to the local context of building patterns or typologies.
The photomontage views of the proposed development however illustrate the visual impact of the proposal on the neighboring streets and demonstrate the vast scale of the proposal relative to the existing local context. The proposed building 'moat' separating the street edge and the building, the proposed setback at third floor with intensive planted roof garden level is incongruous, and the curved three storey form is discordant.
Furthermore, the continuous length of the urban block measuring over 1OOm facing James Walk, and greater than 200m along the South Circular Road, and Brookfield Road presents an building scale that is contrary to the local and city building block. This is notably illustrated in Appendix 5:2 of the EIS "National Paediatric Hospital- Local Regeneration Opportunitiesft where the existing context is illustrated, the regeneration opportunities indicatively illustrated in careful urban blocks and the proposed Children's Hospital representing the single largest urban block (Extract included above for illustration purposes). As a consequence the overall development will overwhelm, detract from and result in the Joss of the existing local character.
4.7 Capacity of St. James Campus The Capacity Study accompanying the application presents an indicative layout illustrating how it may accommodate the extent of development required for the three hospitals within the St. James campus. This indicates that further 6 and 7 storey buildings with basement levels will be required. The study relies on plot ratio assessment only, indicating that the campus is only just capable of achieving the quantitative extent of development required within the standards of the development plan with little room for further expansion or enhanced public realm (The plot ratio expressed is 2.2). There is no indication of site coverage and no three dimensional analysis.
It is reasonable to assume that it is likely that in order for the campus to accommodate the development of three hospitals that the remained of the site will be as intensively developed as the proposed children's hospital portion of the site. If this is the case, this would potentially lead to the development of an urban quarter that is so intensively developed that it does not meet Dublin City Councils ambition for the built environment of Dublin to deliver quality urban environments.
The capacity study highlights the shortcoming of the St. James Campus, that there is insufficient site capacity to accommodate all three hospitals while achieving overall quality of development and physical environment The study clarifies why the site apportioned to the children's hospital is so constrained, and why it has been necessary to develop the hospital with 3 basement levels, and 8 floors above ground, which results in over development of the
children's hospital site, and which will set a precedence for the further over development of the remainder of the site in order to meet the strategic health needs. We submit that this does not represent proper planning and sustainable development.
- ) ......
• ~ - t.l!IDooJ
• .,_,
Figure 4 Extract From Draft Site Capacity Study
--~- --
I
-l
. . . .. . , ... :·~ .
0 2 OCT l.u 5
Source: Extract From St. James Campus Site Capacity Study BOP O'Connell M(h~YJl~A=rc=hit~ect;:s;20;1:5:::;;::;;;:::==;::J
4.8 Traffic And Transportation
The planning report acknowledges that the biggest 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 importation of materials for the construction process. This is significant, and will seriously impinge on the amenity of residents in the area for an extended period during construction period.
The traffic analysis during the operation of the development does not include sufficient stress tests, including assessments during wet weather etc, and the proposed development relies on a modal shift from car usage among staff and enhanced public transport provision for staff and patients. The existing area already experiences traffic congestion and as acknowledged in the planning report, 'that the surrounding street network will continue to experience traffic queuing and delays at some periods through a typical week day. The mitigation proposals included as part ofthe Transport Strategy for the StJames's Hospital campus and the new children's hospital ensures that the increase in traffic levels and associated impact during these periods are kept to a minimum.' It is submitted that there is over reliance on the mitigation measures to ensure that the impact of the traffic proposals will not exacerbate the existing traffic and transport context. The marginal manner in which traffic is managed to ensure that increased levels in traffic and associated impacts are kept to a minimum suggests that the site and adjoining road network does not have the capacity to accommodate the proposed development in accordance with proper planning and development.
In relation to car parking, there is currently significant pressure on car parking in the locality. The reliance on the modal shift from car use to public transport while commendable is ambitious. Furthermore, the development has the potential to result in the loss of existing car parking spaces at Brookfield Road in particular. It is submitted that there will be inadequate parking available for residents in the area who rely on on-street parking, as a consequence of the development during the construction period, and the following operation of the development.
Furthennore. there is no assessment of the capacity of the existing Infrastructure to support the potential traffic generated if the extent of development proposed in the master plan is implemented, and no assessment of the impact on car parking in the area.
The proposed helipad and construction traffic are also likely to generate significant noise, which will detract from the amenity of the area.
We submit that the proposed development should be refused permission on traffic and transportation grounds and associated noise and environmental deterioration reasons.
5.0 Concluding Comment Notwithstanding the Strategic Infrastructure Development status of the proposed development and its importance to the future development of the City and the State, the proposed development of the New Children's Hospital does not conform with the proper planning and sustainable development of the area and should be refused pennission.
• Having regard to the provisions of Dublin City Development Plan 2011 - 2017 in relation to 'Taller Buildings as Part of the Urban Form and Spatial Structure of Dublin' and in particular to Polley SC17 which seeks to 'protect and enhance the intrinsic quality of Dublin as a predominantly low-rise city and to provide for taller buildings in the designated limited locations, it is considered that the proposed development would exceed the defined height identified for Inner City locations, and would contravene Dublin City Policy in this regard.
• Having regard to the transitional zone area, to the height and scale of the proposed development, its location in close proximity to residential properties adjoining the site to the west, and by reason of overbearing aspect, excessive over1ooking, and visual intrusion and that the development is an abrupt transition between the Z15 and residential land use zoning (zone 1 and Zone 2, the development does not accord with the policies and objectives of the Dublin City Development Plan).
• Having regard to the height, scale, massing of the development it would be visually intrusive in relation to the existing character and scale of the immediate local streetscape along the South Circular Road, and Brookfield Road. The development would seriously injure the amenities of the area and would therefore be contrary to the proper planning and development of the area.
• The proposed development will seriously injure the amenity of our client's property, No. 47 Brookfield Road in particular through visual intrusion, over1ooking and overshadowing as a consequence of the location, height, and uses proposed within the Family Accommodation Unit opposite our clients dwelling.
• The capacity of St. James Hospital to accommodate the children hospital and future hospitals is marginal, and requires further 6 and 7 storey structures over basement levels, without any notable enhancement of the public realm, which would suggest that the site does not have sufficient capacity to accommodate the children's hospital or future development of two additional hospitals.
• The operational and construction impact of the development on traffic in the area will seriously Impact on the existing road network and car parking in the area, noise and deterioration of the environment quality of the area and does not conform with proper planning and development of the area.
In the event that An Bord Pleanala intend to grant permission, we request that the mitigation measures presented in this submission are included in a condition attaching to the grant of permission in order to protect the amenity of our clients property.
Our client would welcome an opportunity to present their concerns to the Board, in the event it is intended to hold an oral hearing in respect of the proposed devetopment; cmcn:eqo~ an opportunity to do so. ~ • • .. , '· · • •j
Issue 002C_October 1, 2015 - 14.
II
0 2 OCT 201~
. ,.
LTR·DATEO FJtOM __ --t
PL
47 Brookfield Road, Dublin 8
SHERIDAN WOODS
We trust An Bord Pleanala will take our submission into account.
Yours sincerely
[JvwJ\otCc ~M/ Charlotte Sheridan Sheridan Woods October 1 , 2015
