Download - APB subm,SCR Kilmainham Res.Oct 2015.pdf

South Circular Road, Kilmainham

Residents Association

Chairperson Secretary Committee Members

Sean Cassidy Mary Kearney Tanya Kenny

Joe Ruane

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513 South Circular Road Kilmainham

Dublin 8

01 October 2015

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

Compound at Davitt Road, Dublin

Dear Sir / Madam,

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

we have about the proposed development of the National Children’s Hospital

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

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

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

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

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

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

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





Joe Ruane

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

so well into our neighbourhood.

We support the building of the National Children’s Hospital, but not on the

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

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

close to St James’ then the site behind the Coombe Women’s Hospital would

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

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

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

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

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

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

Lack of adherence to Dublin City Council Guidelines

Health and Safety for our residents

Lack of amenity for our residents.

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





Joe Ruane

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

Development Plan.

1.1 Size, scale and Impact on our area:

The zone attached to our neighbourhood is Residential Neighbourhoods

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

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

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

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

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

residential development shall have regard to the prevailing height of existing

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

natural lighting, sunlight, layout and private open space”.

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

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

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

generation and for the duration of the construction works.





Joe Ruane

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1.2 Abrupt Transition with Residential Zone

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

transition with a residential zone.

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

zoning objectives and control standards show the boundaries between zones.

While the zoning objectives and development management standards indicate

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

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

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

which would be detrimental to the amenities of the more environmentally

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

residential development within predominately mixed-use zones, particular

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

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

amenities of residential properties.”





Joe Ruane

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

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

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

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

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

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

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

28m from the boundary.

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

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

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

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

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





Joe Ruane

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

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

another reason why this proposed development is not appropriate.

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

areas.

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

vernacular architecture.

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

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

encouraging a distinctive response which complements the setting. A high

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

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

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

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

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

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





Joe Ruane

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

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

harmonise with and not clash with the city’s traditional pitched roof forms."

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

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

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

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

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

recognises and harmonises with the successful neighbourhoods, local character

and the remaining historic fabric of the city."

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

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

this historic Museum Quarter of Dublin City.





Joe Ruane

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1.5 Finish on the building as proposed.

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

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

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

National Children’s hospital (the material proposed is stone with the favourite

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

that of the contiguous residential area.

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

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

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

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

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

relationship with the vernacular architecture.





Joe Ruane

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1.6 Scale of the development on the city scape

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

City Development Plan.

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

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

predominantly remain so”.

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

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

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

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

We consider that the proposed National Children’s Hospital, on the St. James’s

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

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





Joe Ruane

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

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

areas.

2. Health and Safety for us as a community.

2.1 Duration of the Construction envisaged in this plan.

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

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

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

This is to facilitate the construction of the National Paediatric Hospital

development at St. James’s Hospital campus in order to accommodate a dry

storage and staging area during the construction phase.

The NCHDB envisage movement of construction materials between St. James’s

Hospital and the Davitt Road compound for this duration.





Joe Ruane

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

it will cause extensive disruption to this neighbourhood for an excessively

extended period of time.

2.2 Level of Construction Traffic through South Circular Road

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

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

required.

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

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

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

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

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

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

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

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

of those months having over 200 lorry movements a day.





Joe Ruane

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

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

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

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

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

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

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

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

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

journeys out of the neighbourhood.

Table 1: Lorry Movements on / off proposed NCH at St. James’s site

Source: EIS

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

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

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

duration of this work.





Joe Ruane

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

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

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

considered imperceptible.”

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

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

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

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

clearance through the junction.

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

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

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

together with attenuation tanks.

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

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





Joe Ruane

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2.3 Level of traffic that will be generated by the National Children’s Hospital,

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

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

Significant assumptions are made in the Environmental Impact Study on Traffic

regarding the existing volume of traffic and the projections.

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

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

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

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

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

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

Kilmainham Lane.

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

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

reduction in staff parking within St James’s Hospital Campus. They also state





Joe Ruane

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

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

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

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

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

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

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

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

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

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

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

predictable methodologically.

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

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





Joe Ruane

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

the James’s hospital site, as set out in master plan.

The total number of patients attending St. James’s hospital is 400,000 annually

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

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

double the current numbers all moving within a confined space.

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

Maternity Hospital and the significant increase in patient treatment proposed

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

James’s Hospital.

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

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

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

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





Joe Ruane

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These calculations must now take into account the announcement on 22

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

Dublin City Council’s own forecast, traffic will increase of 10% between 2020

and 2030 in Dublin City.

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

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

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

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

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

inappropriate traffic analysis at the outset.

The proposed New Children’s Hospital will increase traffic congestion on all

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

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

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

2.4 Way Finding Signs





Joe Ruane

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The Way Finding signs for the New Children’s Hospital are a good idea.

Nonetheless, there are some implications that have hitherto not been

considered.

The hospital traffic coming from the Southern Counties will come through

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

Brookfield Road is as follows:

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

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

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

Rd – (Entrance to The New Children’s Hospital).

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

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

the New Children’s Hospital and St James’s Hospital, except for buses and

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

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

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





Joe Ruane

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

South/South East (e g Harold’s Cross, Terenure, Sandymount, Donnybrook) will

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

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

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

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

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

Planner, the route would be: turn right down James’s St. and travel onto

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

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

2.5 Proposed Bicycle Lane.

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

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

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

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





Joe Ruane

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

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

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

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

network”.

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

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

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

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

Neighbourhood (Conservation Area).

2.6 Helicopter traffic

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

National Children’s Hospital, adjacent to the Linear Park and close to the South

Circular Road. This will presumably provide helicopter access for St James’s

Adult hospital, The National Children’s Hospital and the Maternity Hospital.

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





Joe Ruane

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

the health and safety of our local residents.

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

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

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

3. Impact on local amenity

3.1 Impact of additional parking requirements on the neighbourhood.

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

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

parking near one’s house. Currently there is a significant strain on parking in

the neighbourhood with overflow parking from James’s Hospital coming onto

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

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

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

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





Joe Ruane

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

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

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

the additional burden on local residents as follows:

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

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

James’s Hospital campus, has the potential to increase parking demand on

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

consultation meetings with resident groups in the vicinity of the St James’s

Hospital campus. 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. “





Joe Ruane

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

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

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

belief that this site is not the appropriate site for the National Children’s

Hospital.

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

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

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

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

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

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

expectation in the use of public transport.

4. Considerations requested should this development be allowed.

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

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

following conditions be attached to its decision:

4.1 Working Hours





Joe Ruane

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

and that it finish at 6:00pm.

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

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

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

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

4.2. Road cleaning and maintenance

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

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

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

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

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

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

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

to carry.





Joe Ruane

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4.3 Vermin Control

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

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

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

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

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

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

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

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

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

increased risk of vermin infestation due to this disruption.

4.4 Landscaping

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

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

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





Joe Ruane

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

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

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

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

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

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

adequate provision for greenways in accordance with routes illustrated and

relevant local area plan content.”

5. Alternative sites & possibilities

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

the New Children’s Hospital.

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

“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

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

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





Joe Ruane

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

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

report.

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

strengths of the St James’s and Coombe proposals, given their proximity to

each other, if they presented a joint plan.”

We believe the choice of St James’s Hospital as the potential site for the New

Children’s Hospital did not take on board the suggestions and conclusions of

this report.

St James’s Hospital is the country’s busiest hospital. It is the nature of

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

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

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





Joe Ruane

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

development and expansion requirements of a national children’s hospital.

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

for the New Children’s Hospital on the James’s Hospital site on the grounds

outlined in detail above.

Yours sincerely,

Sean Cassidy Mary Kearney

Chairman Secretary

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