CUNNANE STRATTON REYNOLDS

Submission
on behalf of

The Jack and Jill Foundation Ltd

In relation to

Proposed National Childrens Hospital at St

Jamess Hospital, Dublin 8

Prepared by Cunnane Stratton

for

2nd October 2015

Reynolds

Jack and Jill Foundation

CONTENTS

Executive Summary
1.0

Introduction

2.0

Who are the Jack and Jill Foundation?

3.0

What is their interest in this Planning Application?

4.0

The Proposed Development

5.0

Comments on the Application

6.0

Comments on the Site Location

7.0

Consideration of Alternatives Sites

8.0

Assessment Against Planning Policy

9.0

Traffic, Access and Transport

10.0

Water, Waste Water and Drainage

11.0

Flooding

12.0

Landscape and Visual Impact

13.0

Noise and Vibration

14.0

Air Quality

15.0

Future Expansion Capacity

16.0

Other Concerns

Appendices

Appendix 1:

Traffic, Access and Transport Report by Traffic Insights

Appendix 2:

Observations on Drainage, Water Supply, Flood Risk Proposals &

Outline Management Plan

Appendix 3:

Comment on the Landscape and Visual Impact Assessment and Related

Aspects of the Planning Application for the Proposed National
Childrens Hospital by Cunnane Stratton Reynolds

Appendix 4:

Review of the Assessment of Noise and Vibration relating to the

Proposed National Children's Hospital by ICAN Acoustics

Appendix 5:

Air Quality Impact Assessment by TMS Environment Ltd

Executive Summary

This submission has been prepared by Cunnane Stratton Reynolds on behalf of the Jack and Jill Foundation,
against the proposed development of a new childrens hospital at St Jamess Hospital. Our client firmly
believes that the proposed site is fundamentally the wrong location for a national childrens hospital. We also
believe there are significant and irredeemable flaws within the process followed by the applicant which has
resulted in an underestimation of the potential impacts of the proposed development.

We believe that:

The statutory notice is inaccurate and that the application should be invalidated.

The consideration of alternatives failed to give proper consideration to the planning and
environmental impacts of the alternative sites, and that the process lacks the transparency and clear
rationale one expects in the consideration of alternatives within the EIA process.

The proposal is contrary to the Dublin City Development Plan 2011 - 2017 in relation to height, plot
ratio, site coverage, the removal of traffic from the city centre and the provision of adequate parking;

The assessment of a number of the environmental impacts within the EIA use inappropriate
methodologies which are not in accordance with best practice, resulting in an underestimation of the
potential impacts of the proposed development.

We have considered the impacts of the proposed development in relation to:

Traffic, Access and Transport;

Water, Wastewater and Drainage;

Flood Risk;

Landscape and Visual Impact;

Noise and Vibration; and,

Air Quality.

Traffic, Access and Transport;

Serious deficiencies in relation to the supporting rationale and robustness of the transport assessment
undertaken have been identified. Amongst the most significant concerns are:

The user needs (hospital patients; visitors and staff) in relation to car parking.

Additional travel needs of staff will not be met by mobility management proposed.

The proposed scheme has an excessive dependency on future delivery of uncommitted public
transport schemes such as DART Underground and Lucan Luas line to accommodate staff travel.

Public transport is not a viable alternative for the various user groups.

The applicant has not demonstrated there is sufficient reserve capacity on the public transport
network (LUAS Red Line in particular) to cater for additional passengers.

Despite traffic congestion on the local road network and arising from the hospitals national function
the proposal is highly car dependant.

Demand for car parking is significantly underestimated.

Supplemental parking analysis/surveys undertaken by this third party and review of assumptions used
by the applicant indicate;
o

Patient/visitor car parking demand to exceed capacity for potentially up to 10 hours per day.

Elevated parking changes of up to 5.10 per hour are anticipated.

Significant overspill parking is envisaged (conservatively estimated at potentially up to 260

cars)

Parking control measures will have limited effectiveness is managing overspill patient/visitor
car parking demand.

Increased walking distances, and reduced use satisfaction levels for patients and visitors will
result.

The proposed car parking does not comply with parking requirements for hospitals set out in the
Dublin City Development Plan 2011 2017.

The feasibility of transferring 3,000 staff from the other hospitals has not been demonstrated.

The transport assessment undertaken by the applicants does not accord with best practice (the
NRAs Traffic and Transport Assessment Guidelines May 2014).

Key stages in the transport assessment (trip generation, modal spilt, assessment years, and time
periods, traffic distribution, and assignment and modelling for future traffic impacts) lack the required
level of robustness.

Impaired accessibility by car, bus and emergency service vehicles is anticipated. There is significant
levels of peak period queuing and delays experienced on the local road network.

The suitability of Mount Brown as a major access route to the proposed hospital by patients, visitors
and staff has not been demonstrated.

The Road Safety Audit considers only the site interface with the surrounding road network and not
internal operations.

Water, Wastewater and Drainage;

Our main concerns in relation to water, wastewater and drainage are:

There is insufficient drainage capacity in the realigned Drimnagh Sewer which will surcharge under a
1 in 2 year storm event;

Flow velocities within sections of the Drimnagh Sewer exceed 3m/s and will result in scouring of the
pipe;

There is no attenuation volume calculations included with this application.

Surface water run-off rate has been limited to 2 litres/second per hectare. However in recent years it
has been Dublin City Councils policy to limit run off to 2 litres/second regardless of site area. It is
unclear if this requirement has been met.

It is difficult to assess the impact of surface water flows to the Drimnagh Sewer as no information on
flows has been presented.

There is no allowance for future expansion in the surface water system design.

There is insufficient detail on water supply for the site, and no allowance for future expansion in the
water system design.

The Development Impact Assessment is contradictory as it is suggested that the proposed

development will not impact on existing drainage but yet increase in flood volumes and new flooding
are identified within the system.

The increased foul drainage load on the system (from the new hospital) has not been assessed.

The Outline Construction Management Plan is lacking in detail in a number of important aspects:
o

No detail on parking provision for construction operatives.

Image given of proposed demountable hoarding system does not represent a 4m high
hoarding, as purported.

No specific details on proposed Fire Watch Regime.

No specific details on wheel wash and road sweeper provisions.

No specific details on proposed ground dewatering.

Flood Risk;
We believe that one of the main entrances to the hospital (the Mount Brown entrance) will flood on a regular
occurrence.

The assessment undertaken by the applicant has also failed to take account of the increased flood risk to the
surrounding area if this development proceeds.

Landscape and Visual Impact;

Our main concerns in relation to the landscape and visual impact are:

The inaccurate descriptions of the height of the building as 34.95 metres to ridge level;

The proposed development at 34.95 metres (or greater) contravenes Dublin City Councils height
policy for the area;

The substantial massing and volume of the proposed development, as indicated by the plot ratio and
site coverage results in a visually intrusive development;

The plot ratio and site coverage have been artificially reduced due to the fact the application boundary
(red line of the application site) has been increased to include areas of the linear park along the Luas
line and parts of South Circular Road which in our view should not be included;

The development would result in a very abrupt and pronounced transition in building scale and design
between the site and the surrounding urban area contrary to planning policy;

The proposed development will have a negative visual impact on the surrounding area, which is not
offset by the modern, light architectural style.

The inclusion of the private hospital, the planning permission for which has now expired, within the
photomontages, is misleading and contrary to the recognised and industry accepted method for
conducting a Landscape and Visual Impact Assessment (LVIA). Incorporation of the private hospital
represents a wholly invalid alternative baseline to the existing environment and an irrelevant future
scenario to the proposed NCH;

Noise and Vibration;

Our main concerns in relation to noise and vibration are:

The methodology for consideration of the construction noise impacts are inappropriate for a long term
construction projection in a constricted space;

Selective adherence to BS5228, ignoring areas which would pose a problem to the development

Inadequate assessment of vibrations with no examples of calculated vibration provided. It is also

evident that a basic generic third party calculation method is being considered and one that does not
take account of the actual ground strata at the location.

Considering the proximity of the proposed ground works, 10m from residential properties and 7.5m
from clinical areas, we would have expected a more robust prediction method and a vibration risk
assessment.

Inadequate assessment of the impact of noise intrusion from external sources on the naturally
ventilated hospital rooms, which are inherently acoustically weak.

Impact of noise arising from the proposed helipad on both the patients and local residents has been
grossly underestimated, and the applicant has only assessed one type of aircraft (AW-139) rather
than a larger/louder Sikorsky S92.

There is a gross underestimation of the duration of an actual Medevac event.

Any use of the helipad will most likely give rise to sleep disturbance at night.

No attempt to establish if vibration thresholds can be met at vibration sensitive locations (such as
operating theatres or imaging locations).

The number of helicopter take offs and landings is underestimated for a national hospital given known
movements for UCHG in Galway.

Air Quality;
Our main concerns in relation to air quality are:

The assessment fails to comply with best practice through the use of out of date or inappropriate
baseline and metrological data, in particular failure to consider the impact of traffic on the air
quality of the area;

A simple set of baseline air quality data that is representative of the wider Dublin area (including St
Jamess Hospital, Tallaght and Blanchardstown) rather than the specific location where the
development is proposed has been used;

Baseline air quality is poorer in the proposed location than almost anywhere outside the city
centre. There is therefore limited assimilative capacity available in the receiving environment to

accommodate any significant developments and especially developments as significant as the

proposed childrens hospital and future maternity hospital.

Failure to consider the construction impacts, beyond traffic movements, on the nearby residential
properties and more importantly on the existing adult hospital;

There are significant risks associated with the emission of hazardous substances during
construction that are not recognised;

Inadequate management plan for controlling the spread of Aspergillosis, particularly in relation to
the adults hospital which is to remain fully operational;

Incomplete on site investigations which have prevented the preparation of complete management
plans for the construction stage;

The impact on air quality during construction of Heavy and Light Goods Vehicles (HGV and LGV)
has not been considered;

Inappropriate use of the NRA Guidelines for the Treatment of Air Quality During the Planning and
Construction of Major Road Schemes as the methodology for assessing the construction impacts
of the scheme;

The proposed development will have a significant impact on air quality in the area once operational
due to the dramatic increase in emissions from the energy centre. Emissions to atmosphere from
the Energy Centre could be significantly higher (potentially 300%) if the use of diesel oil as the
primary fuel rather than natural gas is required as highlighted, but not evaluated, in the EIS;

WHO Guidelines have not been formally considered in the EIS which is a major concern given the
National Childrens Hospital will cater for sick children with compromised immune systems and
limited ability to cope with additional stresses such as air pollution.

We have major concerns about the ability of the site to accommodate future expansion including the maternity
hospital, without future damage to the environment and assessments of the area.

1.0

Introduction

1.1

Cunnane Stratton Reynolds have been appointed by the Jack and Jill Foundation, of Johnstown
Manor, Johnstown, Naas, Co Kildare, to prepare a submission on the proposed development of a
National Childrens Hospital at St Jamess Hospital, Dublin 8.

1.2

This submission confines itself to the proposal for the main childrens hospital on the St Jamess site.
We have no comments to make in relation to the proposed satellite centres at Tallaght Hospital and
Connolly Hospital, beyond how they relate to the main hospital at St Jamess.

1.3

We would state at the outset that our client accepts entirely and fully supports the need for a new
national childrens hospital. There is no denying that the existing hospitals at Crumlin, Temple Street
and Tallaght are out of date and no longer fit for purpose in relation to the demands of modern
medical care for children.

1.4

Notwithstanding their support in principle for a new childrens hospital, our client is concerned about
the adequacy of this current proposal in terms of meeting the needs of children now and into the
future.

1.5

The new childrens hospital represents the largest investment by the State in paediatric medical care
since its foundation. It is a once in a generation opportunity to completely overhaul how we as a
country care for our sickest children now and well into the future. We all therefore have a moral and
social obligation to ensure that the proposed development is fit for purpose and that childrens needs
which are the primary concern, are best met by the proposed development.

1.6

The consideration of the application before the Board exists within an interface between planning,
technical requirements, and medical best practice. We recognise that it is not for the Board to
question the political decisions which have resulted in this application and therefore we will not be
discussing such issues. However we do intend to discuss in sufficient detail the planning and
technical concerns linked to what we perceive to be the deficiencies from a medical perspective.

2.0

Who are the Jack and Jill Foundation?

2.1

The Jack and Jill Foundation, is a registered childrens charity. It was founded in 1997 by Jonathan
Irwin and his wife, Senator Mary Ann OBrien based on their own experience caring for their son Jack
at home until he passed away in December 1997, aged 22 months.

2.2

Over the past 18 years, Jack & Jill has supported over 1,900 children (from birth to 4 years old) with
brain damage who suffer severe intellectual and physical trauma. The Foundation also provides end
of life care for all children who require it from birth to 4 years of age.

2.3

The Jack & Jill homecare plan is designed around the whole family, never forgetting the siblings.
There is no waiting list. The nurses provide out of hours service for the families that need it, 365 days
a year, in every community and every walk of life. The nationwide service includes home visits and
care, advice, information, lobbying and bereavement support.

2.4

The children cared for by the Jack and Jill Foundation represent some of Irelands sickest children.
These children and their families often spend much of their short lives either in hospital, or attending
regular appointments with specialists in the current national childrens hospitals at Temple Street or
Our Ladys Hospital, Crumlin. The Jack and Jill Foundation, is therefore uniquely positioned to
understand the needs and requirements of Irelands sickest children, and just as importantly their
families, in terms of any new proposed hospital. The Board of the Jack and Jill Foundation is made up
of a number of people with medical qualifications and experience such as Dr Fin Breatnach, former
Head of Oncology at Our Ladys Hospital, Crumlin.

2.5

Our client feels obliged to highlight their very genuine, and we believe well founded concerns, and if
the Board decides to refuse, grant or grant with modification this proposal, the Jack and Jill
Foundation will fully respect that decision.

3.0

What is their interest in this Planning Application?

3.1

The Jack and Jill Foundation, as one of the States leading childrens charity catering to Irelands
sickest children, wish to ensure that this once in a generation opportunity to provide a state of the art
childrens hospital, fully meets the needs of Irelands children.

3.2

Our client has grave concerns about the suitability of the site in terms of the location and access to
the main childrens hospital at St Jamess, its capacity for future expansion, and the absence of a
maternity hospital from the proposal. It is our belief that the St Jamess site is unsuitable for the
proposed use and that the new childrens hospital will fail to adequately meet the requirements of
Irelands sickest children.

3.3

Our clients primary concerns can be summarised as follows:

Inappropriate site location;

Inadequate consideration of alternative sites;

Fundamental flaws in the environmental assessment of the proposal across a number of

topics;

Absence of a maternity hospital;

Inadequate expansion space.

4.0

The Proposed Development

4.1

The National Paediatric Hospital Development Board is seeking permission for the development of:

473 no. bed childrens hospital (up to 118,113 sq.m) at St Jamess Hospital;

53 no. bed family accommodation unit (up to 4,354 sq.m) at St Jamess Hospital;

Childrens Research and Innovation Centre (up to 2,971 sq.m) at St Jamess Hospital;

Construction compound at Davitt Road, Drimnagh, Dublin 12;

Two satellite centres at Tallaght Hospital and Connolly Hospital providing rapid access urgent
care and outpatient services.

4.2

The new childrens hospital at St Jamess Hospital will include:

380 no. inpatient beds (of which 60 no. are critical care beds);

93 no. day beds;

Emergency department;

Operating theatres;

Family resource centre;

Outpatient departments;

Hospital school;

Education facilities;

Therapy areas;

Staff and visitor canteens;

Pharmacy;

Pathology Department;

1,000 no. parking spaces (28 no. surface and 972 no. basement)

A new ambulance area to serve both the new childrens A&E and the existing adult A&E at St
Jamess Hospital;

Helipad serving both the new childrens and existing adult hospital;

4.3

The new building is advertised as 7 storeys, with a stated height of 34.95m.

4.4

This submission is confined to the development at the St Jamess Campus. It is not intended to
discuss the construction compound at Davitt Road or the satellite centres at Tallaght Hospital or
Connolly Hospital, except as they relate to the development at St Jamess.

5.0

Comments on the Application

5.1

Before discussing the substance of our clients objection we would like to draw the Boards attention
to some concerns about the application itself and the statutory process followed.

Statutory Planning Notice

5.2

It is one of the most fundamental requirements of planning that the statutory notices adequately and
correctly describe the proposed development. We believe that the issued notice includes errors in
relation to the description of the height of the main hospital building.

5.3

The statutory notice states, in relation to the height of the building:

The proposed building will vary in height from three storeys with a recessed podium level
fronting onto South Circular Road and the internal access road (facing west / northwest
towards the rear of Cameron Square), to four storeys at the northern, eastern and southern
elevations. The proposed central oval-shaped ward pavilion rises a further three storeys
above the podium garden level with a plant area enclosed in the roof space above (giving a
total of seven storeys above ground level)

5.4

It is generally accepted within the Irish planning system that plant, even where enclosed in a roof
space, constitutes a floor or storey. The description of the building as seven storeys including plant is
therefore factually incorrect. In actual fact the building is eight storeys (i.e. seven storeys excluding
plant or eight storeys including plant).

5.5

The statutory notice then describes the height of the building in metres:
The overall height of the building to ridge level of the roof structure is up to 34.95m
(Ordnance Datum 55.95m) and up to 37.95m to the top of the flues on the roof (Ordnance
Datum 58.95m) above a revised ground level of Ordnance Datum 21m at the proposed
entrances.

5.6

We believe this statement to be entirely inaccurate. The notice caveats the height at being 34.95
above the revised ground level of 21m Ordnance Datum. The true maximum height of building from
the actual ground level appears to range between 34.95m excluding the flues, or 37.95 including the
flues, and 39.15m excluding the flues, or 42.15m including the flues. This is clearly evident from
elevations and cross sections submitted as part of the application.

5.7

While these may seem minor errors, an incorrect or misleading notice, can be grounds for invalidation
and legal challenge. In our experience applications have been invalidated in such circumstances.

10

Masterplan
5.8

There are references throughout the application to a masterplan for the St Jamess Campus to guide
development into the future and which has informed this planning application. We have reviewed all
the documentation submitted as part of the application and have been unable to locate any
masterplan within the bundle of documents submitted with the planning application. This document
should be included with the application pack if a full assessment of the proposed development, how
the proposal was generated, and its interaction with the future development of the St Jamess
Campus is to be undertaken.

5.9

It should be noted that the Dublin City Development Plan 2001 - 2017 in Section 15.10.14, in relation
to Z15 lands (such as this site) implies the inclusion of a masterplan for major developments. The
failure to include a masterplan clearly represents non-compliance with planning policy.

Prematurity of the Application

5.10

The application repeatedly states the commitment of the applicant and the government to tri-location
of an adult, childrens and maternity hospital on the site. Our client supports this in principle, in
particular the co-location of a childrens hospital and maternity hospital, as this will greatly improve the
outcomes for premature or seriously ill babies, for whom transport by ambulance between the
maternity hospitals and children hospitals can be life threatening.

5.11

However, given the apparent commitment by the government and the applicant to tri-location, our
client is concerned about the lack of detail on how a maternity hospital will or can be accommodated
on this site. The capacity study of the campus is only in draft, and it does not appear to provide any
definitive empirical basis for the figures selected for the capacity of the maternity hospital.

5.12

We believe that the failure of the application to include any definitive details on the scale of the
maternity hospital, its location within the site or a timeline for its development, renders this proposal
premature from a tri-location perspective. If the justification for locating at St Jamess is tri-location
then at least some empirical evidence must be produced on how this will be achieved and within a
realistic timeline i.e. not in another 20 years time. Not to do so will ensure that there is lingering doubt
to the achievability of one of the key requirements that the applicant set for themselves to deliver.
Such deliverability must seriously be questioned therefore.

11

6.0

Comments on the Site Location

6.1

Our clients overarching concern, and which forms a golden thread running through this submission
relates to the suitability of the St Jamess site in terms of location and access on a national basis.
They are of the firm belief that the St Jamess site is fundamentally inappropriate and clearly not fit for
purpose.

6.2

When considering where to locate such an important piece of strategic infrastructure, such as a new
childrens hospital, the key consideration is ensuring it is accessible and proximate to the vast majority
of the intended users as is possible. In this regard Dublin is the obvious choice, as the capital city is
easily accessible by road and public transport. Our client therefore supports the choice to locate the
new childrens hospital in Dublin. Their concern rather is the specific location within Dublin and the
suitability of an inner city site especially one where there is a substantial residential component along
numerous boundaries to the application site.

Figure 6.1: Strategic Location

6.3

Figure 6.1 above paints a clear picture of a site, in the heart of the city. St Jamess Campus is located
in the west inner city, approximately 7 Km from the M50. It is an inherently constrained site, due to the
presence of the existing low rise St Jamess Hospital, and the character of the surrounding area,
which is predominantly residential and in places dramatically variable in terms of ground levels.

6.4

Based on the 2011 Census, there are 1,092,872 children aged between 0 16 years within Ireland.
Children generally begin to transition out of the paediatric system into the adult system sometime
between 16 and 18, therefore we are only examining those under 16. Figure 6.2 below, based on the

12

2011 Census Data, illustrates the number of children within Dublin City, Dublin County, the Greater
Dublin Area (GDA), and the rest of Ireland.

Children (Aged 0-16) by Area

Dublin City
8%

Rest of Ireland
59%

Dublin County
17%

GDA
16%

Figure 6.2: Percentage of Children (aged 0-16) in the State by Area

6.5

Figure 6.2 above shows only 8% of all children in the State live within Dublin City. The majority of
children in Dublin live in the fast growing areas of Dublin County (Fingal, Dun Laoghaire Rathdown
and South Dublin) or the commuter belt in the GDA (Louth, Meath, Kildare and Wicklow). We estimate
that approximately 33% of children within the immediate catchment of the new hospital live not only
outside the city but outside the M50. This is hardly surprising, as the main areas for relatively recent
population growth have been outside of Dublin City where the majority of residential development for
the past 15 20 years has been concentrated.

6.6

The concentration of children outside of Dublin City, is important in light of the new hospitals role in
providing secondary care for all children within the GDA. The vast majority of children within the GDA
will have to travel from outside the M50 into Dublin City Centre for secondary care, particularly in
cases where they cannot be treated at the satellite centres.

6.7

The new hospital will also provide tertiary and quaternary care to children throughout Ireland. In
addition to the approximately 33% who live outside of Dublin City but within the GDA, a further
approximately 59% of children within the State live outside the GDA entirely. This figure does not
include the children who live in Northern Ireland and will also attend this hospital for certain
specialities not available in Belfast.

6.8

Allowing for the fact that there are no geographical factors influencing the prevalence of chronic or
serious illnesses in children, this means that 92% of children attending for tertiary and quaternary care
will be from outside the M50. Children attending for tertiary and quaternary care represent the sickest
children in Ireland. We know that cardiac, haematology and oncology departments alone, who would
be dealing with some of the sickest children, account for nearly 50% of day care admissions and more

13

than 1/3 of admissions at Our Ladys Hospital Crumlin. These three departments alone therefore will
account for a significant volume of the patients attending the hospital on a daily basis. The children
attending these services will be from all over the country and are among the children who spend the
longest periods in hospital. On this basis any demographic rationale for locating the National
Childrens Hospital in an inner city location in of itself must be seriously questioned.
6.9

On the basis of where the majority of the population it will serve are located, we must question the
logic of locating in such a central location within Dublin City as a matter of principle, with its
associated development constraints and access issues as will be discussed in Section 9.0 of this
report and within the enclosed Traffic, Access and Transport Assessment carried out by Travel
Insights on behalf of our client.

Figure 6.3: Character of the Surrounding Area

6.10

Figure 6.3 above highlights the general character of the area. The surrounding area is predominantly
residential in nature. The industrial area is connected with the Guinness Brewery and is not indicative
of a large amount of industrial or commercial development in the area. The other area marked as
healthcare is St Patricks Hospital which provides a range of mental health services for teenagers and
adults. There is a small area of mixed development opposite St Jamess. This long strip contains a
mix of residential development and the types of local commercial and retail uses which one would
expect within a residential area i.e. a local convenience shop, post office, medical centre, pub etc.

6.11

While St Jamess Hospital is an existing established facility, it could be viewed as a non-conforming

use within a predominantly residential area. We would question the appropriateness of intensifying

14

this non-conforming use as a matter of principle, given the potential for negative impacts on
residential amenity. We believe that local residents are expressing their own concerns in this regard.
6.12

In terms of the existing prevailing height of the surrounding area, it is predominantly 2 3 storey
residential. This is particularly true in the case of the surrounding streets of South Circular Road,
Brookfield Road, Mount Brown, James Walk and Ceannt Fort. The proposed development will have
an inevitable negative impact on the residential amenity of the surrounding area in terms of
overlooking, overshadowing, traffic congestion, noise and disturbance from the proposed over
development and unacceptable intensification of the existing hospital use on site.

6.13

We do not believe that the site location has been determined in accordance with the established
principles of proper planning and sustainable development at a strategic or national level. The
proposed development would increase trip lengths and is in an environmentally unsustainable
location. Additionally our client would contend that the needs of the children and their families it is
supposed to serve, have not been adequately considered. Chapter 4, Section 4.0 of the EIS explicitly
states that:
St James Hospital Campus has been chosen at Government level as the location for the
new childrens hospitalWhile it will be outlined below that environmental considerations
informed the Government decision, they were not the primary consideration in choosing St
Jamess Hospital Campus as the location of new childrens hospital.

6.14

It is our clients view that far from being the primary consideration, environmental assessment has
been wholly inadequate to demonstrate the clear acceptability of the proposed development in
environmental terms.

6.15

We would ask the Board when determining this application to fulfil its statutory obligations to consider
first and foremost the proper planning and sustainable development of this site for the proposed
development. To do so should result in a refusal of planning permission in this instance on the basis
of the facts presented on the planning merits.

6.16

We accept that it is not for the Board to question the political decision which resulted in the selection
of this site. We would however assert that the selection of this site is contrary to the proper planning
and sustainable development of the site, and area and that whatever justification there is for the
proposed use on the subject there is no planning justification nor have alternatives been adequately
considered in the EIS accompanying the planning application.

15

7.0

Consideration of Alternatives Sites

7.1

Under EU law the consideration of alternatives, both in terms of design and location, is an important
element of the EIA process. The consideration of alternatives is required to explain the reasoning
behind a selected site and design, taking into consideration the environmental effects. We note that
the Inspector during pre-application discussions with the first party, specifically instructed the
applicant to carefully consider and demonstrate the reasoning behind the site and design selection.

7.2

We are satisfied that the consideration of alternative designs has been carried out in accordance with
the requirements of the EIS process. However we are of the view that the proper consideration of
alternative sites has clearly not been carried out as requested by the Inspector as a key planning
requirement during the pre-application discussions. We believe that the assessment of alternative
sites was unduly influenced and restricted by factors outside of the planning or environmental
considerations, and therefore the planning process that is supposed to be followed and which has to
be assessed by the Board is inherently and irreparably flawed.

7.3

It is very clear from the opening section of Chapter 4 of the EIS (quoted above in section 6.13 of this
report) that when the Government, and later its EIS team, set out to consider alternative sites,
environmental considerations, which should be the overriding consideration from a planning
perspective, were never the primary deciding factor and most importantly, the alternatives were not
considered against potential environmental impacts. If assessment of environmental impacts was not
a key component in the consideration of alternatives then it means in our view that the environmental
assessment process in addition to the planning process identified in the preceding paragraph is
deeply flawed. This is contrary to EU law and best practice in relation to an EIA.

7.4

We will focus on the consideration of St Jamess Hospital, Connolly Hospital and the Coombe
Hospital in terms of the consideration of alternatives as these three sites appear in the governments
own reports (the Dolphin Report and Clear Martin Report) as the most suitable of those examined.
We accept the other sites proposed are not suitable for a variety of reasons.

7.5

Overall there appears to be a lack of transparency in the process followed in relation to the
consideration of the alternative sites. Sites are ruled out and reasons given, but there is no evidence
that a consistent process or assessment has been followed in assessing the merits or otherwise of
each site. This is contrary to the clear instructions of An Bord Pleanala.

7.6

The assessment also draws heavily on the Dolphin, and Clear Martin reports which were used by the
government in the site selection process. While we acknowledge these reports were prepared by
experts in their respective fields, they were not prepared in accordance with the rigour of the EIA
process. We do not believe that the planning or environmental case has been clearly demonstrated.

16

7.7

We are unable, based on the information provided, to identify any substantial difference between St
Jamess Hospital and the Coombe which would justify why St Jamess is considered more appropriate
from a planning, environmental and technical perspective. Both are described as inner city sites in low
rise residential areas. The potential for impacts on residential amenity is therefore broadly similar in
our opinion. We would contend in fact that the potential impacts could be greater at St Jamess, as we
understand the Coombe site was larger, thereby offering greater opportunity to reduce the impact in
terms of height and the related issues of overlooking, overshadowing and visual impact etc. and to
effectively internalise the various impacts within the site. However in the absence of any transparent
and consistent assessment between sites on planning and environmental considerations a fair and
reasonable comparison cannot be made.

7.8

From a medical perspective neither allows for immediate tri-location, only co-location is achievable. In
relation to the Coombe the EIS claims that the absence of the adult hospital would present unique
challenges in terms of transportation and mobility management. It is our view that exactly the same
point could justifiably be levelled at this proposal for St Jamess Hospital. It is our firm belief that from
a medical perspective, that where only co-location can be achieved in the short to medium term, then
co-location with a maternity hospital is far more critical than with an adult hospital, due to the risks
associated with transporting small, extremely ill infants to the childrens hospital versus a requirement
for doctors to travel a short distance from the adults hospital to the childrens hospital.

7.9

In terms of Connolly Hospital we note the concerns regarding the environmental sensitivity of the site.
It is claimed that issues such as the zoning of the site as High Amenity and the potential presence of
bats on the site or in the surrounding area render the site unsuitable. However on the basis that these
concerns appear to not have presented an issue to its development as a satellite centre, or indeed a
recent government decision to relocate the Rotunda Hospital to the site, it is reasonable to assume
that any concerns in that regard could similarly be set aside for the development of a full childrens
hospital on the site. At the very least the matter should have been explored in greater detail than is
evident within the EIA.

7.10

Overall the main deciding environmental factor between the three sites appears to be transport and
access, and a determination to rely heavily on public transport. There is certainly no denying that St
Jamess Hospital is the best served in terms of public transport due to the presence of the LUAS
through the site. However we are deeply sceptical of the benefits of this reliance on public transport
as demonstrated in our traffic and transport assessment.

7.11

In relation to potential impacts of the development at St Jamess, the consideration of alternatives

states that car parking on the site will need to be limited to 2,000 spaces due to the potential impact
on the surrounding road network. It goes on to state that;

17

the parking requirement associated with the new childrens hospital will have an unavoidable
impact on the surrounding road network.however.this [impact] is not considered to be
significant.
7.12

We strongly disagree with the assertion that it will not have a significant impact in terms of traffic.
Traffic Insights will demonstrate in their enclosed Traffic, Access and Transport Report, that car
parking on the site is wholly insufficient, and that the proposed development will have a significant
negative impact on the surrounding road network. Significantly, in our view the main reason for
eliminating the Coombe is transport, and it is acknowledged that access would present unique
challenges and could potentially have an impact on traffic in the area.

7.13

Connolly appears to have been eliminated due to the current limited availability of public transport.
We would question whether it would be any more difficult to enhance public transport to Connolly
Hospital than it would be to accommodate additional and overspill parking at St Jamess Hospital.
Equally while in general we support the principle of sustainable transport, and the encouragement of
use of public transport, we do not believe that in the unique case of a national childrens hospital,
reliance on public transport is achievable or appropriate given the needs of the users (sick children
and their families). This is expanded upon in the enclosed Traffic, Access and Transport Report.

7.14

Overall the consideration of alternatives fails to present a clear or convincing picture of why St
Jamess Hospital was selected from a planning, environmental and technical perspective over other
sites, which based on the information available, appear equally if not more suitable.

18

8.0

Assessment Against Planning Policy

8.1

There are a number of areas where we believe the proposed development deviates significantly from
planning policy. These are in relation to height, plot ratio, site coverage, the removal of traffic from the
city and compliance with the car parking standards.

8.2

The relevant development plan covering the St Jamess Campus is the Dublin City Development Plan
2011 2017. This plan is currently being reviewed with a draft plan shortly.

Height
8.3

Dublin City Council has a very clear policy in relation to height, as set out in Section 17.6.2 and Figure
21 of the City Development Plan 2011 - 2017. The site is an inner city site located in an area identified
for low rise development. The designated height in such areas is up to 6 storeys residential or 7
storeys commercial. This equates to a height below 19m for residential or 28 metres for commercial.

8.4

The proposed development is described as 7 storeys, though as discussed above is in fact 8 storeys
including plant, and ranges between 34.95 metres and 39.15m from ground level to ridge level. This
clearly substantially exceeds the Councils policy in relation to height.

8.5

The applicant has attempted to justify the height by relying on the approved private hospital (Reg. Ref
2751/09) which was granted permission in 2010 for 8 storeys or 32.85m and the MERCER building
(Reg. Ref: 3607/12) currently under construction which is 7 storeys or 28m approximately.

8.6

The private hospital cannot be considered to provide a precedence as it was granted under the
previous City Development Plan which had a far less stringent policy approach to tall buildings. The
planning permission granted for the private hospital has now lapsed and a new application would be
required and would therefore be subject to the current height restrictions of the current City Plan. We
do not believe that such an application would be successful under the current height regime.

8.7

The MERCER building, which is currently under construction, while also 7 storeys, is only 28 metres
and therefore complies with planning policy. It does not therefore provide a precedence for the
Childrens hospital which is at best 34.95m, and in reality substantially taller.
Plot Ratio and Site Coverage

8.8

The Dublin City Development Plan includes two tools to manage development and prevent the over
development of a site; plot ratio and site coverage.

8.9

The subject site is zoned Z15 (Institutional) and as such the permitted plot ratio is 0.5 2.5, and the
permitted site coverage is 50%.

19

8.10

The applicant in Table 8 of their submitted Planning Report claims the plot ratio to be 1.9 and the site
coverage to be 42%.

Figure 8.1: Site Coverage of Proposed Development within Application (Red Line) Boundary

8.11

Unfortunately we have been unable to definitively verify these figures, given the paucity of information
provided in the application, but a basic visual assessment of the buildings (highlighted in orange)
within the application boundary, which must include the Energy Centre (though we suspect it has
been excluded from the calculation), would suggest that they occupy more than 50% of the
application site. The plot ratio, on the basis that none of the proposed structures are single storey, is
therefore also likely to be exceeded.

8.12

We also suspect that the plot ratio and the site coverage standards for the St Jamess Campus as a
whole will be exceeded. The applicant has failed to provide any definitive figures on the floor space of
the St Jamess Hospital, thereby preventing anyone from providing proper analysis of plot ratio and
site coverage. However once again a basic visual assessment would suggest the plot ratio and site
coverage have been exceeded.

20

Figure 8.2: Site Coverage for the entire Campus

8.13

The areas occupied by the various built structures associated with the two hospitals (orange
Childrens Hospitals, blue St Jamess) would appear to easily exceed 50%. The plot ratio is also
likely to be exceeded, on the basis that few of the structures are single storey.

8.14

We believe that the site area has been artificially inflated through the inclusion of the linear park along
the LUAS line and parts of South Circular Road within the red line and therefore the site area
calculation. This would have had implications on the calculation of the plot ratio and site coverage,
resulting in artificially lower figures.

8.15

We suspect that the plot ratio and site coverage for both the application site and St Jamess Campus
as a whole will be exceeded if this development is permitted. This would result in the
overdevelopment of the site and would contravene the City Development Plan. On this basis we
would request the Board to verify from the applicant the plot ratio and site coverage figures so that the
necessary assessment can actually be carried out by An Bord Pleanala.

Removal of Traffic from the City

8.16

Section 5.13 of the City Development Plan 2011 2017, sets out the strategic approach of the City
Council in relation to traffic and transport states:

21

The approach is to restrict through traffic and calm traffic generally within the city centre and
to give increased levels of priority for pedestrians, cyclists and public transport.

8.17

This, combined with a commitment on the part of the Council to encourage sustainable transport and
modal shift from private cars to public transport, implies the Council are seeking over time to reduce
the amount of traffic coming into the city. The proposed development, which will generate significant
car borne traffic, within the city centre is therefore contrary to policy.

Car Parking Standards

8.18

The Dublin City Development Plan does not include any definitive standards for car parking at
hospitals. The only explicit standards are for outpatient facilities at a rate of 1 space per 150 sq.m for
inner city locations such as St Jamess Campus. The City Development Plan then states that:
In assessing car parking requirements for hospitals Dublin City Council will have regard to
the numbers of medical staff, administration staff, patients and visitors.

8.19

The proposed new childrens hospital will provide 1,000 on site spaces, which combined with the
existing car parking on site will result in 2,148 spaces in total within the St Jamess Campus. However
as a result of car parking lost through the development of the childrens hospital there will in fact only
be a net gain of 420 spaces within the Campus. It is our belief that this is far from sufficient, as will be
demonstrated in the enclosed Transport Report. We believe that the applicant in determining the
number of required spaces has failed to adequately assess the car parking requirements of both
hospitals for staff and patients. They have therefore failed to comply with planning policy.

22

9.0

Traffic, Access and Transport

9.1

A detailed review of the traffic, access, and carparking arrangements for the proposed hospital at St
Jamess has been undertaken by Transport Insights on behalf of the Jack and Jill Foundation as part
of this submission. Their full report is enclosed as Appendix 1 of this document. We intend to briefly
outline our clients main concerns in relation to traffic, access and transport.

9.2

We believe that the traffic, access and transport assessment undertaken for this application is
severely inadequate. Transport Insights seriously question some of the findings, assumptions made
and process followed by the applicant.

9.3

We believe that:

The approach of the submitted transport impact assessment does not accord with best
practice, as set out in the NRAs Traffic and Transport Assessment;

The modelling software used is inappropriate for a development of this scale and lacks
highway re-assignment capabilities, and as a result the capability to analyse the strategic
implications of the development proposal is unacceptable;

There is a substantial underestimation of the proposals traffic impacts;

A failure to consider user needs in relation to access and car parking, as it will take on
average an additional 20 minutes to reach the site by public transport from a variety of
locations around the country;

Public transport is not a viable alternative for various user groups;

The applicant has failed to demonstrate adequate reserve capacity on the public transport
network to accommodate the proposed development, particularly in relation to the LUAS.

There appears to be, on the part of the applicant, a misplaced confidence in the role of
mobility management;

Demand for car parking appears to have been significantly underestimated;

Supplemental parking analysis/surveys undertaken by this third party and review of

assumptions used by the applicant indicate;
o

Patient/visitor car parking demand to exceed capacity for potentially up to 10 hours

per day.

Elevated parking changes of up to 5.10 per hour are anticipated.

Significant overspill parking is envisaged (conservatively estimated at potentially up to

260 cars)

Parking control measures will have limited effectiveness is managing overspill

patient/visitor car parking demand.

Increased walking distances, and reduced use satisfaction levels for patients and
visitors will result.

23

The applicant is claiming they will achieve an unprecedented change in behaviour in terms of
transport and parking on the part of their staff, by increasing modal shift to what we believe to
be unachievable levels;

The proposed car parking does not comply with parking requirements for hospitals set out in
the Dublin City Development Plan 2011 2017;

The feasibility of transferring 3,000 staff from the other hospitals has not been demonstrated;

The new access at Mount Brown will result in queuing along the road;

No swept path analysis has been provided for the Mount Brown entrance to demonstrate the
entrance is suitable, efficient and safe.

A lack of clarity relating to taxi and car drop off facilities, and whether they shall meet
anticipated high levels of future patient, visitor and staff demand;

The Road Safety Audits limited scope, having considered only the sites interfaces with the
surrounding road network, and not internal operations. This could have implications for the
safe future internal operations of the site.

9.4

These are substantial and significant failings on the part of the applicant, and demonstrate the entirely
inadequate nature of the site for the proposed use. On this basis the Board would be entirely justified
in our opinion in refusing permission on traffic access or parking grounds for this proposal as
presented.

24

10.0

Water, Waste Water and Drainage

10.1

A detailed review of the water, waste water and drainage arrangements for the proposed hospital at
St Jamess has been undertaken by Merit Consulting on behalf of the Jack and Jill Foundation as part
of this submission. Their full report is enclosed as Appendix 2 of this document. We intend to briefly
outline our clients main concerns in relation to water, waste water and drainage arrangements.

10.2

We believe that:

The OCSC Engineering Services Report has a significant number of inconsistencies in terms
of figures for flow rates, capacity and usage. The methodology for assessing the requirements
of the proposed development in terms of water, waste water and drainage is therefore flawed
and potentially inaccurate;

The proposed rerouted Drimnagh sewer is inadequate and has insufficient capacity for the
current volume of wastewater which uses the system. It will surcharge under a 1 in 2 year
storm event;

Flow velocities within sections of the sewer pipe exceed 3m/s and will result in scouring of the
pipe;

The design for the rerouted Drimnagh sewer is not in accordance with the Greater Dublin
Strategic Drainage Document, with which all drainage proposals within Dublin are required to
comply with;

Surface water run-off rate has been limited to 2 litres/second/per hectare, however in recent
years it has been Dublin City Councils policy to limit run off to 2 litres/second regardless of
site area. It is unclear if this requirement has been met.

There is no allowance for future expansion in the surface water system design.

There is very little detail provided on the availability of water to serve the site. Irish Water has
only stated that there is generally good pressure and availability of water in the area;

Future expansion within the site does not appear to have been considered in the design of
these services.

The Construction Management Plan is lacking in detail in a number of important aspects:

o

No detail on parking provision for construction operatives.

Image given of proposed demountable hoarding system does not represent a 4m high
hoarding, as purported.

10.3

No specific details on proposed Fire Watch Regime.

No specific details on wheel wash and road sweeper provisions.

No specific details on proposed ground dewatering.

We believe that the case presented for water, waste water and drainage provision is inadequate for
an application of such significance.

25

11.0

Flooding

11.1

A detailed review of the flooding risk to the site and surrounding area has been undertaken by Merit
Consulting, as part of the general report on water, waste water and drainage provision for the
proposed development on behalf of the Jack and Jill Foundation. Their full report is enclosed as
Appendix 2 of this document. We intend to briefly outline our clients main concerns in relation to flood
risk.

11.2

A site specific flood risk assessment was carried out for the proposed hospital by OCSC, and found
the site to be low risk. However it seemed to confine itself to the site and ignore the flood risk to the
surrounding area which may at times render access to the hospital challenging.

11.3

Mount Brown, off which the main access to the childrens hospital car park and service area is
located, is according to the ECFRAMS Flood Extents map for the Camac River subject to flood events
(i.e.) one in 10 year flooding. We believe this would render part of the development partially
inaccessible on a relatively frequent basis.

11.4

Added to this is the fact that the Drimnagh Sewer, which is a combined sewer, will surcharge on a
frequent basis (1 in 2 year return period).

11.5

Overall there is a clear increased risk of flooding, a fact which is acknowledged by Atkins
Development Impact Assessment Report included with the application. It indicates an increased risk
of flooding at the 5 year, 30 year and 100 year return rates. OCSCs assessment does not properly
assess this risk in our opinion or propose how it would be managed.

11.6

This is an extremely sensitive use, to which access must be maintained at all times. We believe that
the extent of the flood risk to the development and the surrounding area is unacceptable and renders
the location unsuitable.

26

12.0

Assessment of the Landscape and Visual Impact

12.1

A detailed review of the landscape and visual impact of the proposed hospital at St Jamess has been
undertaken by Cunnane Stratton Reynolds (who are qualified and experience landscape architects)
on behalf of the Jack and Jill Foundation as part of this submission. Our full report on the landscape
and visual impact of the proposed development is enclosed as Appendix 3 of this document. We
intend to briefly outline our clients main concerns in this regard.

12.2

We believe that the landscape and visual impact assessment undertaken for this application is
inadequate and based on inaccurate information and a flawed process of assessment. We also
believe that the manner in which photomontages have been presented may mislead or confuse
people.

12.3

We believe that:

The description of the height as 34.95 metres to ridge level is inaccurate, for the reasons
discussed in Section 5.0 above;

Notwithstanding this, the proposed development at 34.95 metres (or greater) contravenes
Dublin City Councils height policy for the area;

The plot ratio and site coverage have been artificially reduced due to the fact the application
boundary (red line of the application site) has been increased to includes areas of the linear
park along the Luas line and parts of South Circular Road which in our view should not be
included;

The substantial mass and height of the building will have a significant negative impact on the
areas of residential conservation, such as South Circular Road, OReilly and Donnellan
Avenue, as well as the general residential areas in the surrounding area;

The development would result in a very abrupt and pronounced transition in building scale
and design between the site and the surrounding urban area. The impacts arising from this
would be most acutely experienced by visual receptors on the adjacent residential streets of
OReilly and Donnellan Avenue in Ceannt Fort, South Circular Road, Mountshannon Road,
Brookfield Road, Brookfield Street and Cameron Square, some of which are zoned
Residential Conservation Areas in the City Development Plan.

The inclusion of the private hospital, the planning permission for which has now expired,
within the photomontages, is misleading and contrary to the recognised and industry
accepted method for conducting a Landscape and Visual Impact Assessment (LVIA).
Incorporation of the private hospital represents a wholly invalid alternative baseline to the
existing environment and an irrelevant future scenario to the proposed NCH;

Overall in the LVIA the proposed development is assessed as having a significant and
positive impact. However for a small number of locations (nearby streets where the proposed
NCH would be a dominant presence in views from houses and their environs) the LVIA finds

27

that the development may initially be viewed as negative but in the medium term (seven
years) and beyond the impact will become moderate and positive. The reason for this finding
is that the author considers the architecture of the building to be modern, light and
appropriate and that, presumably, visual receptors will become used to and even
appreciative of its presence over time. We wholly disagree with this position.

It cannot be the case that policy on the protection of residential amenities and restriction of
building height do not apply to buildings that are considered to represent good or striking
architecture. Various viewpoint assessments in the LVIA including for Royal Hospital
Kilmainham, Donnellan Avenue and elsewhere suggest that the light and varied colouring
and curved roof of the building render the proposed NCH so attractive that it can/should be
considered an appropriate and positive intervention in the cityscape. This is not the case.
From certain viewpoints the proposed development would be a large, imposing intrusion in
views, screening or otherwise affecting the perception of valued elements of views (rooflines,
mountains, sky), diminishing the presence of existing buildings, radically changing the urban
character. From certain viewpoints, e.g. Donnellan Avenue and Cameron Square, the visible
elements of the building would not appear attractive or appropriate in the context.

The LVIA has commented only on the impacts that would be experienced in the public realm.
The impacts that would be experienced by the occupants of affected houses should also be
considered, for example the houses on OReilly Avenue which back onto the site. The
presence of the NCH in views from the rear windows, back gardens and on all approaches to
the houses would be overwhelming, and the impact on visual receptors profound, negative
and permanent. In addition to the visual intrusion there would be impacts of overlooking / loss
of privacy, overshadowing and loss of sunlight.

12.4

In summary we strongly disagree with the conclusion in the LVIA that the proposed development
would ultimately have a positive visual impact on its receiving environment. This is most definitely not
the case in our view.

28

13.0

Noise and Vibration

13.1

A detailed review of the noise and vibration assessment for the proposed hospital at St Jamess has
been undertaken by ICAN Acoustics on behalf of the Jack and Jill Foundation. Their full report on the
potential noise and vibration impact of the proposed development is enclosed as Appendix 4 of this
document. We intend to briefly outline our clients main concerns in this regard.

13.2

We believe there are significant flaws within the noise assessment which have resulted in a significant
underestimation of the noise impact of the proposed development.

13.3

We believe;

The methodology for consideration of the construction noise impacts are inappropriate for a
long term construction projection in a constricted space;

Selective adherence to BS5228, ignoring areas which would pose a problem to the
development

Inadequate assessment of vibrations with no examples of calculated vibration provided. It is

also evident that a basic generic third party calculation method is being considered and one
that does not take account of the actual ground strata at the location.

Considering the proximity of the proposed ground works, 10m from residential properties and
7.5m from clinical areas, we would have expected a more robust prediction method and a
vibration risk assessment.

Inadequate assessment of the impact of noise intrusion from external sources on the naturally
ventilated hospital rooms, which are inherently acoustically weak.

Impact of noise arising from the proposed helipad on both the patients and local residents has
been grossly underestimated, and only assessed one type of aircraft (AW-139) rather than a
larger/louder Sikorsky S92.

There is a gross underestimation of the duration of an actual Medevac event.

Any use of the helipad will most likely give rise to sleep disturbance at night.

No attempt to establish if vibration thresholds can be met at vibration sensitive locations (such
as operating theatres or imaging locations).

The number of helicopter take offs and landings is underestimated for a national hospital
given known movements for UCHG in Galway.

13.4

In conclusion, the degree of noise and vibration has not been adequately considered with regard to
the proposed NCH development and these omissions seriously compromise the proposed
development. An EIS should adequately consider the likely impact of noise and vibration on both the
occupants of the proposed facility and occupants of noise/vibration sensitive properties in the locality.
However, this has not been undertaken for the proposed NCH development. We believe that the clear

29

significant impact of the proposed development in terms of noise and vibration on a variety of
sensitive receptors represents sufficient grounds for refusal.

30

14.0

Air Quality

14.1

A detailed review of the air quality assessment for the proposed hospital at St Jamess has been
undertaken by TMS Environment Ltd on behalf of the Jack and Jill Foundation. Their full report on the
potential air quality impact of the proposed development is enclosed as Appendix 5 of this document.
We intend to briefly outline our clients main concerns in this regard.

14.2

We believe that the air quality assessment undertaken for this application is inadequate and has
utilised incorrect methodologies and baseline data. The findings of the air quality assessment are
subsequently flawed and inaccurate.

14.3

We believe:

The assessment fails to comply with best practice through the use of out of date or
inappropriate baseline and metrological data, in particular failure to consider the impact of
traffic on the air quality of the area;

A simple set of baseline air quality data that is representative of the wider Dublin area
(including St Jamess Hospital, Tallaght and Blanchardstown) rather than the specific location
where the development is proposed has been used;

Baseline air quality is poorer in the proposed location than almost anywhere outside the city
centre. There is therefore limited assimilative capacity available in the receiving environment
to accommodate any significant developments and especially developments as significant as
the proposed childrens hospital and future maternity hospital.

Failure to consider the construction impacts, beyond traffic movements, on the nearby
residential properties and more importantly on the existing adult hospital;

There are significant risks associated with the emission of hazardous substances during
construction that have not been recognised;

Inadequate management plan for controlling the spread of Aspergillosis, particularly in

relation to the adults hospital which is to remain fully operational;

Incomplete on site investigations which have prevented the preparation of complete

management plans for the construction stage;

The impact on air quality during construction of Heavy and Light Goods Vehicles (HGV and
LGV) have not been considered;

Inappropriate use of the NRA Guidelines for the Treatment of Air Quality During the Planning
and Construction of Major Road Schemes as the methodology for assessing the construction
impacts of the scheme;

The proposed development will have a significant impact on air quality in the area once
operational due to the dramatic increase in emissions from the energy centre. Emissions to
atmosphere from the Energy Centre could be even higher (potentially 300%) if the use of

31

diesel oil as the primary fuel rather than natural gas is required as highlighted, but not
evaluated, in the EIS;

WHO Guidelines have not been formally considered in the EIS which is a major concern
given the National Childrens Hospital will cater for sick children with compromised immune
systems and limited ability to cope with additional stresses such as air pollution.

14.4

We have prepared a very comprehensive dispersion model which led to significantly higher
predicated impacts than those presented in the EIS. Overall the modelling results suggest that there
is insufficient assimilative capacity in the proposed city centre location to ensure that air quality
standards are not exceeded as result of this proposed development.

32

15.0

Future Expansion Capacity

15.1

This proposed development is anticipated to serve as the National Childrens Hospital for the next 100
years. It is truly a once in a generation opportunity. It is therefore essential that the development is
capable of future expansion to meet the future needs of Irish children. During the pre-application
consultation An Bord Pleanala requested demonstration that the site has adequate capacity to
accommodate the future expansion of the Childrens Hospital, Adult Hospital and a Maternity Hospital
on the site. In this regard a draft capacity study was included with the application.

15.2

We are concerned about the fact that this capacity study is only in draft. We would question its status
and its reliability in assessing the capacity of the site as it is only a draft document.

15.3

Aside from the draft status of this document, we also note that the capacity study has only allowed for
a 20% increase in floorspace, the bare minimum they are required to provide according to the Dolphin
Report, across all three potential hospitals on site. We would question the basis for this quantum of
increase. It is our understanding, based on our clients knowledge, that a far greater expansion space
is generally required.

15.4

We are of the opinion that the constrained nature of the site mayprevent the site accommodating
more than the inadequate 20% floorspace. Additionally there appears to be no expansion space
within the surrounding area. The surrounding area is predominantly low rise, of no more than 4
storeys maximum, residential development. There are no adjacent brownfield sites or commercial
properties to which administrative or outpatient clinics can be decanted.

15.5

Linked to these concerns is a fear that the site will be unable to accommodate the maternity hospital
in the future, which is crucial to the operation of the childrens hospital, and essential to achieving trilocation. On this constrained inner city site it is proposed to accommodate the childrens hospital, the
adults hospital, additional adult services currently being transferred to the adults hospital, and a
maternity hospital. All of these uses will likely also require expansion space. Such a quantum of
development will only be achievable if the heights, plot ratio and site coverage for the campus
increases dramatically.

15.6

Our technical reports demonstrate very real concerns about the current proposal which would be
exacerbated with any expansion or additional uses. We have demonstrated in our Traffic, Access and
Transport Report, that the surrounding road network is at capacity and that the car parking proposed
(which we note the applicant states will not be increased even in the case of future development on
the site) is inadequate for the needs of the site. We also contend that the applicants reliance on
public transport is unachievable and unrealistic given the nature of the uses on site. It is clear
therefore that from an access and mobility management perspective the site will be unable to

33

satisfactorily or sustainably accommodate future development. Add to this the inadequate drainage
arrangements for the site, the upgrading of which will only become more onerous as more
development occurs on site, and it is clear that from a technical perspective there will be severe
limitations on future expansion on site.
15.7

These technical constraints have very real implications on both the childrens hospital and the adults
hospital. It would appear that from a technical perspective the site will be unable to accommodate
even the 20% additional space envisaged by the applicant. The implications for the maternity hospital
are more problematic, and stand to prevent the governments commitment to tri-location, which is a
significant justification for this site being selected.

15.8

We are aware that it is unusual to request the Board to consider the degree of future proofing of a
development, but in this instance, given this is strategic infrastructure, it be must a major
consideration. We would request that the applicant be required to justify the basis for 20% expansion
space, finalise the capacity report, and demonstrate that the site is capable of accommodating all the
intended uses within that 20% expansion space without causing substantial negative impact on the
surrounding area.

34

15.0

Other Concerns

Economic
16.1

The applicant has sought to demonstrate that the economic benefits of this proposed development
will be far reaching and, in the case of the St Jamess Campus will be the catalyst to achieving the
social and economic regeneration of the area.

16.2

We would question whether any apparent economic benefit in terms of regeneration will outweigh the
significant costs associated with the project.

16.3

Developing in the inner city is always expensive, and that is certainly the case with this site. There are
a number of areas where it is clear the applicant has found a solution to an issue, for example the
creation of a new access off Mount Brown to accommodate the traffic or relocating the Drimnagh
Sewer, however at significant cost. The viability of this scheme therefore must be seriously
questioned, and the cost/benefit of the scheme in terms of the economic cost to the State vs the
economic benefit to the local area.

Height of the Roof/Plant Structure

16.4

The height of the main building has been discussed in various places throughout this submission,
however we have one final concern in relation to height and that is the height of the roof space. Based
on the drawings submitted the height of the roof space which houses the plant is 5 metres. This
seems excessive considering it is only housing plant equipment. It appears to add an unnecessary
additional few metres to the building.

Design of Open Space:

16.5

The Dolphin Report (p.32) states that Child-friendly design International best practice including the
design of the new Alder Hey Childrens Hospital in Liverpool indicates that child patients place a
high value on an attractive, landscaped setting. There is some academic research which points to
better healthcare outcomes in such cases

16.6

We believe that this is unachievable on this site. The site is an inner city site and therefore, despite
the best efforts of the applicant, an attractive, landscaped setting is not achievable.

16.7

We also have concerns about the quality of the open space. We fear the inner courtyard within the
ward pavilion will be overly enclosed and should be examined further.

16.8

It clear that the open space does not accord with best practice.

35

Is the Proposed Development fit for purpose?

16.9

Our client has a number of concerns about the design of the main building. These do not relate to its
architectural merit but rather whether the building can be considered functional and fit for purpose.

16.10

The constraints of the site are clear in the layout of the new hospital. It is our understanding that key
medical staff at the existing childrens hospitals repeatedly advocated for the inclusion of an
unconscious floor i.e. a floor containing the operating theatres, intensive care departments and
radiology departments, which would have allowed children who have undergone major surgery to be
wheeled directly between areas as required. Instead these units have been stacked on top of each
other resulting in a dependence on elevators to move seriously ill patients between these areas. This
is contrary to best practice.

16.11

Prof Roger Ulrich, Professor of Architecture and Health Facilities Design, Department of Architecture
Texas A&M University, and generally considered the Father of evidence-based hospital design
published a paper in the Health Environments Research and Design Journal, Vol 1. No.1. Fall 2007
entitled Elevator-dependent vertical hospital layouts may increase susceptibility to transport delays
that worsen complications. In it Prof. Ulrich drew attention to concerns relating to high-rise hospital
layouts. He states that:
Difficulty in accessing elevators was reported as one reason for transport-related
complications in an Australian study. Another study identified elevator malfunction as a
reason for delays in transport that worsened complications. In addition, elevators are
especially vulnerable in emergency situations such as blackouts, fires, earthquakes. These
findings should be taken into account when making such key architectural choices as
between a high-rise building relying heavily on elevators and a low-rise horizontally dominant
structure. The finding that elevators may worsen complications has implications for choosing
between small infill sites within cities that require tall structures as compared to larger sites on
the periphery of cities that permit lower-rise hospitals.

16.12

The evidence would suggest that having to transport seriously ill patients by elevator to key areas for
tests or procedures, results in poorer outcomes for those patients. In existing hospitals stacking these
key areas may be unavoidable, but the proposed development is a new build. We believe as such an
opportunity has been missed to ensure the hospital accords with best practice in terms of medical
design.

16.13

It is our understanding that it is proposed for specialist outpatient services to hotdesk. We are
concerned about the impact this may have on children. A visit to hospital can be a daunting and
sometimes frightening experience for children. Children benefit from routine and the sense of security
offered by attending the same person in the same room during visits. A scenario where staff have to
book rooms, and arent guaranteed the same room each time may increase the distress for children.
The needs of children must be the overriding concern with this development.

36