abp, subm mary k.and joe r.501 scr.oct 2015.pdf

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Joe Ruane & Mary Kearney, 501 South Circular Road,

Kilmainham, Dublin 8.

The Secretary,

An Bord Pleanala,

64 Marlborough Street,

Dublin 1.

28 September 2015

Re: Planning Application Reference PL29N.PA0043, St James Hospital,

Dublin 8.

Dear Sir / Madam,

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

we have about the proposed development. Our family home at No. 501 South

Circular Road is a minimum of 21.9m to the west of the proposed development

site and accordingly we have a particular interest in any proposals which may

represent a threat to our established residential amenities.

We would like to firstly state that we have no objection to the fact that the area

immediately bounding our property is a hospital. As this has been mine and my

children’s family home all of our lives, and for a significant amount of time for

my parents, we have always welcomed the proximity of St. James’ Adult

hospital and have always expected that there would be developments to

complement our neighbourhood, as was previously done by St. James’s

Hospital. The most recent buildings developed on this western side of the site,

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the St James’s Private Clinic and the buildings that now house the Speech and

Language departments, are of a low height and are in red brick complementary

to our neighbourhood and our adjoining residential homes.

However, the development currently proposed does not complement this

historic neighbourhood. We have asked Sheridan Woods to review elements of

this on our behalf.

Our objections to the proposed development are on the following grounds: -

1. Breaches of Planning Guidelines

o Impact on our home in terms of light

o Impact on our home in terms of overlooking

o The proximity to our home and the abrupt transition to Z2

o Height & Scale of Development in an area not zoned for High

Buildings

o Lack of sympathy with Zone 2 Residential Area

2. Impact of traffic caused by this proposed development

o Construction phase

o Operational phase

o Impact on Parking

3. Health & Safety Issues

o Aspergillus/Legionnaires Disease

o Sewage

o Vermin Control

o Helicopter landings

4. Other matters of concern

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o Misrepresentation of photomontages at South Circular Road

o Duration of the Planning Application

o Inability of the local area to deal with the size of the construction

task

As a result of the above we ask that permission for this development be refused

on this site. We would suggest as an alternative that the site behind The

Coombe Women & Infant’s University Hospital would be more appropriate as

the location for the National Children’s Hospital.

1. Breaches of Planning Guidelines

Impact in terms of Light.

Section 15.10.14 – Land Use Zoning Objective for Z15 lands states

“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, and in section 15.9 in relation

to the avoidance of abrupt transitions of scale between zonings”.

The main windows to our kitchen face eastwards towards the planned

development site. There are no windows facing southwards. Access to the

early morning sunlight is very important in terms of our enjoyment of that

particular living space. See Fig 1 below. The development of this 12.6m

building due east of these windows of our home will inevitably affect the access

of early morning sunlight throughout the year. Due to the height of the

proposed development and its proximity to the site border, the consequent

overshadowing will cause serious injury, in particular to the amenities of our

kitchen area.

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Fig 1: View from kitchen 01/10/2015 07:58

In addition, we enjoy morning sun to the front bedroom and sitting room in our

house due to the presence of the Bay Window, See Fig 2 this will be completely

blocked due to the 34.95m building to our east.

Fig 2: Sun coming in bedroom window 10/8/2015 07:41

We do not agree with the view portrayed in the EIS that the impact of the

proposed development will not significantly alter the profile of the existing

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sunlight on our property. This view is confirmed by Sheridan Woods in the

adjoining submission. We request that a proper all-year round Independent

Light Survey to review of the shadow castings be undertaken to show the full

impact on our home and that of our neighbours.

Impact in terms of Overlooking.

The lodged drawings indicate that it is proposed to locate balconies and glass

fronted corridors immediately across from home to a height of 12.6m above the

level of our house. The proposed development will therefore result in serious

overlooking of our garden and of the windows of our kitchen, and indeed due to

its proximity, will provide direct views into our kitchen. This will cause serious

injury to the amenities and utility value of these areas of our home.

Section 17.6.3 of the Dublin City Development Plan - Assessment Criteria for

High Buildings sets out the assessment criteria that mid-rise and high buildings

must have regard to. I refer to the section on Social Criteria which states that

the buildings must “Minimise overshadowing and overlooking of surrounding

properties and adverse impacts on established or emerging residential

communities.” `

We contend that the planned development does not adhere to this criteria as it

overshadows and overlooks an established residential community and thence

should be refused.

The proximity to our home and abrupt transition to a Zone Z2

Recognising the reality of adjacent zoning issues, (we are Zone Z2, while the

grounds of St. James’ Hospital are Zone Z15), Section 15.19 of the Dublin City

Development Plan states the following strategy “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

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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.”

This proposed development does not achieve this objective as there is no break

at all between our period red-brick houses and the planned 12.6 metre high

section of this proposed building immediately to the boundary of the site. The

building, as proposed, comes to the extreme western end of the St. James’

Hospital site and as such it offers no transition at all to our home, being at a

distance of only 21.9m away, with no space for any landscaping or screening

between the proposed building and the western boundary of the site as currently

exists – See Figs 3 & 4 below. Our home is zoned Z2 – Residential

Neighbourhood, Conservation Area and has the stated objective of “To protect

and/or improve the amenities of residential conservation areas”. This

development does not meet this objective.

Fig 3: Daytime view from kitchen

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Fig 4: Early morning view from kitchen

Height & Scale of the Development

Section 17.6.2 of the Development Plan 'Definition of a High Building”

provides a definition of height for the St James’ Hospital grounds and

surrounding areas as below 19m residential / 28m office. The height of the

main body of this proposed hospital is 34.95m. This is significantly in excess of

the Dublin City Development plan, which has a maximum height of 28m for

this neighbourhood (including the Z15 area). We contend that the proposed

hospital building fails the planning principles in that regard by reason of its

visual incongruity arising from its excessive height in the context that it is not

an area approved for High buildings and due to the proximity to the adjacent

Residential Neighbourhood, Conservation Area Zone. We also contend that this

proposed development does nothing to protect the amenities of the residential

homes opposite and is in breach of Dublin City Council’s guidelines. As can be

seen from the photographs of the model – Fig 5 and 6 below it is significantly

higher than the local residential neighbourhood.

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Fig 5: Photograph of Model showing impact on Brookfield and South Circular Roads

Fig 6: Photograph of Model showing impact from Mount Shannon Road.

Section 17.6 of the Dublin City Development Plan states “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 also states “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”. The height of this proposed development,

immediately east of our home, rises to a height of 55.95m datum level. This

would leave it as one of the highest points in Dublin and with a length of

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251.3m for the building overall and 178.7m for the oval. It means that the

proposed building will be the largest visible structure on the skyline of Dublin.

We believe that this does not comply with the policy of Dublin City Council.

The proposed development is also in breach of Dublin City Council’s Strategic

Policy – SC18 To protect and enhance the skyline of the inner city, and to

ensure that all proposals for mid-rise and taller buildings make a positive

contribution to the urban character of the city, having regard to the criteria and

site principles set out in the Development Standards Section (see Chapter 17).

In particular all new proposals must demonstrate sensitivity to the historic city

centre, the river Liffey and quays, Trinity College, The cathedrals, Dublin

Castle, the historic squares and the city canals, and to established residential

areas, open recreation areas and civic spaces of local and citywide

importance” This proposed development does not demonstrate any sensitivity

to this historic residential area.

We also object that this development encroaches onto the Z9 Linear Park,

thereby reducing the access to the northern end of this park for residents of this

area for at least the years of the proposed development (Up to 10 years

permission being sought for the Davitt Road Compound).

Section 16.1.4 of the Dublin City Plan states that “The height of buildings

relative to the width of a space is an important consideration affecting

sunlighting and also the sense of being in a traditional street. For large

developments (e.g. occupying more than 20m of street frontage) the height of

buildings and how they positively relate to the scale of other buildings along the

whole length and on both sides of the street must be demonstrated.”

We believe that this proposed development does not meet this criteria.

Proposed Finishes

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The proposed finish of the National Children’s hospital – The prevailing

material proposed is stone with the favourite in terms of colour and grain being

a mottled grey granite – is totally unsympathetic to the materials and finishes

which characterise development in the adjacent residential area. Indeed, to date

St James’ Hospital has been very considerate of this neighbourhood in that all

the existing buildings on this western boundary are finished in red brick to

blend in with this existing historic area.

2. Impact of traffic caused by this proposed development

This is a residential area with many young families and children living close to

the entrance to the hospital. The significantly increased volume of traffic that

this development will generate will indeed negatively impact on our daily lives

and make our living situation worse. We are concerned with additional strains

that access to the proposed hospital will cause in our neighbourhood. This

traffic will not only be at peak hours when employees enter and leave the

complex, which we currently contend with. We understand, but do not know

how it will work in practice, that no more than 728 of the approximate 6,000

staff in the combined St James’s Adult and National Children’s hospitals will be

expected/allowed to drive (728 parking spaces available for staff). That level of

parking that will be provided is considerably less than the existing levels

provided in St. James’s Hospital and in each of the three Children’s Hospitals.

However, overall it amounts to a reduction of a mere 244 staff parking spaces

that is meant to mitigate the additional traffic generated by the 350,000 patients

that will be treated in the proposed hospital. That means approx. 1,900 sick

children coming into the site per day, and we do not expect the majority of them

to use Public Transport.

As all residents, commuters and hospital visitors and staff know, this area is at

maximum capacity during the rush hour periods at present (also recognised in

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Page 6-150 of the EIS Section 6). This development is proposing rush hour

conditions in the area during most of the day for all working days. We are

concerned of the impact that this level of traffic will have on urgent cases and

emergency vehicles trying to get to St James’ Adult Hospital as well as the

proposed National Children’s Hospital on the site.

Construction Phase Traffic

Per Section 6 of the EIS there are estimates for the lorry movements that will

pass our house to travel to the junction of SCR/Bulfin Road/Suir Road during

each of the 3 phases of construction. Our home is very close to the traffic lights

for the entrance to the hospital, and due to this we are very concerned with the

noise and vibration that will be caused by waiting trucks at the junction. Per the

information provided, for each of the phases the volume of traffic generated will

average in the region of the following:

Phase 1

Average 357 per day for the first 4 months (including removal of demolished

buildings), giving an estimated total of 48,654 traffic movements.

Average 322 per day for the next 2 months – total 19,504 total movements

Phase 2

483 per day for the next 18 months – total movements of 199,672

Phase 3

513 per day for the next 21 months (minimum) – total movements of 247,420

We object to this level of development on the site. Well in excess of 490,000

HGVs or LGVs will pass our home and due to the proximity to the junction will

have to wait outside our house awaiting clearance through the lights. It is worth

noting, that based on the estimates provided over 111,000 of those are to

remove the earth and rock from the site to dig the very substantial basement that

will be required for this proposed development. We consider this to be an

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indication that the proposed buildings are much too large for this constrained

site. The level of traffic on the South Circular Road is due to the inability of

these trucks to leave the proposed new entrance at Mount Brown for onward

exit via the Con Colbert Road.

Operational Traffic

Section 6 of the EIS – Page 132 states that the expected level of additional

hospital traffic will be in the region of 300 – 400 traffic movements per hour.

The majority of these will be via the SCR & Brookfield Road entrance. This is

a very significant number of additional vehicles on the road – in the region of

1800 to 2400 per day. We contend that the road network in this neighbourhood

cannot sustain this level of additional traffic and will lead to all day congestion

and will seriously hinder the access to the National Children’s Hospital and St.

James’s Adult Hospital A&E Department for emergency vehicles.

Proposed Bicycle Lane

We note the proposed plan to put a bicycle lane on the portion of the SCR

between Rialto Bridge and the junction with Brookfield Road, to cross into the

middle of the road as it approaches the junction and to continue on into

Brookfield Road. This is not a suitable place for a bicycle lane, and would

indeed be dangerous for cyclists trying to cross this very busy junction. We

consider that the proposal for a bicycle lane on this very narrow stretch of road,

which was built in the late 19th Century, will have even further detrimental

impacts on traffic in the neighbourhood. As planned, the bicycle lane will

effectively reduce the existing two lanes, which allows traffic select its direction

before the bridge – to go straight on towards the hospital or to turn left to travel

towards the Suir Road/Bulfin Road junction, down to one lane. This will cause

even more difficult conditions for the ambulance service that use this road

constantly, and who regularly have to switch lanes, or cross to the other side of

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the road to get into the St James’s Adult hospital at the moment. The

additional traffic generated by the National Children’s Hospital, together with

the cycle lanes that are proposed on both sides of this road, will create an even

more dangerous junction than exists today.

Parking issues for the resident community

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

07:00 – 19:00, with free parking on Sundays and at present it can prove difficult

to obtain parking near one’s house. Currently, during Visiting Hours in St

James’s Hospital quite a number of people park on our streets. This problem

regarding the adequacy of parking is acknowledged by the NPHDB who

suggest in Page 22 of the Non-Technical Summary “The extension of the

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

community, where required”

They also suggest that the prices in our areas should be increased. This tacit

acceptance that they are not providing adequate parking is totally unacceptable

to the parents of the sickest children of our country. A development location

that does not provide adequate parking for the transport of sick children to

hospital just should not be considered. This fact, further reinforces our belief

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

should be refused planning permission.

3. Health & Safety Issues

Aspergillus/Legionnaires Disease

The planning application discusses the possible presence of Aspergillus spores

in the site. The application states that “While dust from construction activities

tends to be deposited within 200 m of a construction site, the majority of the

deposition occurs within the first 50 m (as shown in Table 12.11). There is no

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mention in the report as to how any potentially adverse impact is going to be

mitigated for properties outside of the boundaries of the site. We live

21.9metres from this site and this is a very worrying feature for us. This is

particularly of concern as the excavation works will be taking place over 18

months at a minimum.

Vermin Control

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

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

James’ 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. This is currently a major issue for the

residents close to the MISA building which is under construction on the St.

James’s Hospital site.

Sewage

We are concerned that the facility is going to add significant pressure on the

local sewage facilities. The cost of relocating the Drimnagh Sewer is not

covered in the budget for the National Children’s Hospital. We have concerns

that any disruption to this service will have serious impacts on our facilities.

We would request that Dublin City Council Drainage division and Irish Water

be requested to affirm the plans for the rerouting of the Drimnagh Sewer and

that the successful completion of this should be a condition of further work

being carried out on the site.

Flooding

We are also concerned about the area identified as the entrance to the Basement

Car-park and the fact that there are three underground levels at this site. The

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area identified as the entrance has flooded twice in the past 7 years and is an

area that is recognised as being subject to flooding. We do not see any

mitigation to future events of a similar nature in the plans for this building.

Water

In recent years, this area has been subject to water restrictions. We have

concerns that a development of this size will create serious adverse implications

for water supply in this part of our city and we believe that this also needs to be

taken into consideration and is a reason to decline such a significant project.

Helicopter Landings on proposed Helicopter Landing Pad

As part of this development it is proposed to locate a helipad on the 4th Floor

Level to the South East of our property. We have serious concerns about the

level of noise that landings on this helipad will cause so close to our residence.

We would like additional information regarding the flight paths for helicopters

and details of the noise impact on our home.

4. Other matters of concern

Misrepresentation of the proposed building size in the Photomontages.

We contend that the representation of the building as shown in the photo-

montages is very misleading. It is obvious that different photographic angle

views are utilised, and these lead to the impression that the impact on the view

from the South Circular Road is quite limited (See Photomontages37.1, 37.2

and 37.3). These photomontages do not provide the required information

regarding angles of vision or lens focal length. However, using the data

provided, the height of the existing house on the grounds of St. James’ Hospital

is in the region of 9m and the height of the hospital at 34.95m then the height

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differential should be in the region of 385% not 110% as portrayed in the

photomontage.

We consider this to be in breach of good practice and that it gives a misleading

view of the development which as designed will not look at all like the pictures

represent.

Duration of the Planning Application.

The timeframe for this development is well in excess of the normal grant of

Planning Permission. We suggest that any permission for a National Children’s

Hospital should be for a period of 5 years only as it should be possible to build

such an important building in this timeframe if the site were suitable for such a

building. This extended application request would indicate that this site is too

constrained and is unsuitable for a building of this scale and mass. It may also

be caused by the inaccessibility of this site from the perspective of the

movement of construction and demolition materials required to prepare the site

and to build the hospital A more suitable site would allow the development of

the required National Children’s Hospital take place and be fully operational in

a much shorter time-frame.

Site Capacity

We are very concerned with the plans as outlined in the St. James’ Hospital

Draft Site Capacity Plan that is submitted as part of this application for the

National Children’s Hospital. This amounts to a capacity in the region of

303,000m2 for the site (Table Page 32). According to the Non-Technical

Summary, the site of the National Children’s Hospital amounts to 8.7ha of the

total 19.48ha SJH site, this means that there is 10.78ha left for St. James’

Hospital. Given the scale of the increase required by St. James’ Hospital we do

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not consider that adequate space is left to meet the capacity guidelines set out by

Dublin City Council Development Plans.

Future Traffic

We are also very concerned with the traffic that will be generated by this

additional development. The situation as described above appears impossible

even before the Maternity Hospital and the expansion covered in the St. James’

Hospital Master plan are taken into consideration. When all these additional

movements in and out of this constrained site are taken into consideration, it

will not be possible for the two access roads, one of which was built in the

1700s and the other in the 1800s, to deal with the traffic required for the

transport of patients. Is not acceptable that the health of future generations of

Dubliners relying on St. James’s Hospital, our elderly who will attend the new

MISA building, our cancer patients who will attend the proposed Oncology

Unit, our sickest children and our expectant mothers are put at risk by the

granting of this planning permission on this site when other more suitable sites

are available in our city to disperse this total patient population more

appropriately.

As stated in the Non-Technical Summary Page 26 Section 7.2.2 “Following the

construction of the new children’s hospital, it is acknowledged that the

surrounding street network will continue to experience traffic queuing and

delays at some periods through a typical week day. The mitigation proposals

included as part of the Transport Strategy for the St James’s Hospital campus

and the new children’s hospital will ensure however that the increase in traffic

levels and associated impact during these periods are kept to a minimum”. We

do not see these mitigation proposals and again suggest that there is no way that

we can mitigate for the requirements of sick people to be brought to hospital by

either car or ambulance.

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Site Boundaries

We wish to question the site boundaries as set out for this proposed

development. The boundary, per the drawings, on the western side of the

development takes approx. 50% of the South Circular Road into the

Development Site. We object to this, as this is not the property of St. James

Hospital, or the HSE and we do not believe that it can be taken into the site by

the National Children’s Hospital. The same issue applies to the Southern

boundary, which has extended into the Linear Park. This we believe to be

zoned Z9, to preserve, provide and improve recreational amenity and open

space. We as the local community use this space regularly and we object to it

being removed from our use for the many years of this development

Size of the Excavation and support for underground carpark

We are concerned that the excavation that will be required for the foundations

of the new building and for a 2 storey underground carpark and a lower plant

room and attenuation tank will have a detrimental impact on the structures and

foundations on the residential houses on the South Circular Road adjacent to the

site. The impact of the excavation work should be clarified and adequate

measures requested to ensure the protection of the structural integrity of our

home and those of our neighbours.

Considerations requested should this development be allowed.

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

request that in the event of a grant of permission that the following conditions

be attached to its decision: -

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To mitigate against the shadow and light reduction impact:

In order to mitigate on the impact of the light and shadowing impact on our

home, we request that the development be moved back at least 12.5m from the

western boundary of the site. This would place the building at the same

distance from our houses as the Private Hospital that was once planned for this

area of the site, and which was substantially smaller in mass than this proposed

building.

As stated above, we also request a full light survey, covering all times of the

year as part of this development, as the impact of the proposed development has

not been carried out for all daylight times during all four seasons. We request

that a proper all-year review of the shadow castings be taken to show the impact

on our home and that of our neighbours

To mitigate against the issue of overlooking:

We would ask in the event of a grant of permission that access to the proposed

balconies be removed by way of condition. We would also ask for a condition

that glazed barriers be placed along the front and sides of these balconies, and

that the windows in the western elevation be glazed in obscured glass to a

height of 2m to prevent overlooking of our residence and those of our

neighbours. In addition, we would request that this building be set-back by a

minimum of 12.5 meters to mitigate this overlooking impact.

To mitigate against the abrupt transition.

There is a screen of mature trees behind the existing Hospital wall on the South

Circular Road which has been a constant feature/amenity in the area for the past

30 years at least. We would like to retain this feature because of their

importance as a feature of the area’s streetscape and because they will moderate

the visual impact of the development on our residence and act as a screen

between this proposed building and our existing house. Should permission be

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granted, we would request that the building be moved back an adequate distance

to retain these trees, or if this cannot be accommodated, we want trees of a

similar height and density to replace them (e.g. Silver Birch/ Willows). This

will provide a softening between the materials and height of the new building

and our existing red-brick houses in the Residential Neighbourhood,

Conservation Area Zone Z2. We request that the trees be kept especially during

the period of construction, when they will help to reduce the impact of the

construction activity on our amenities, and that adequate measures be

implemented to ensure their protection.

Proposed Finish

We also request that the proposed stone finish on this building be replaced with

Red Brick to blend in with this Z2 Residential Conservation Area. We believe

that the stark contrast between the two different zones are not in compliance

with the aims of the Dublin City Development plans.

Traffic Management Plan:

It is vital that Dublin City Council request submissions of a Construction Traffic

Management Plan prior to the commencement of any form of development, and

to explain how these roads will cope with the Construction traffic in conjunction

with the normal daily use of this major thoroughfare. We note the plans in

Section 3.5.3.2 of the engineering report to use Flagmen “Flag Men will be

deployed by the Main Contractor at access and egress points into the site to

assist in the safe egress of construction vehicles from the site and their

integration onto the road network. There will be a requirement for the Flag

Men to be provided on a permanent basis for the duration of the works

regardless of traffic volumes or traffic movements.” We request a review of the

planned operation of such disruption to the normal traffic on the route from the

Traffic Department of Dublin City Council. We request that the Head of Dublin

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City Council Traffic Department attend the oral hearing to explain how these

roads, built in the 18th and 19th Centuries will deal with this increased volume of

traffic, and this disruption to their planned flows. We also request the Head of

the National Ambulance Service to attend the oral hearing to explain how their

service will operate in practice during this development and in the future

operational phase.

If this development is allowed to go ahead, given the volume of construction

traffic that will be generated, we would ask that by order of special condition,

Dublin City Council be required to actively maintain the roads of this

neighbourhood for the duration of the construction. We know that pot-holes

can occur during times of such high heavy traffic and ask that the roads be

maintained at least every month.

To allow for Bicycle lanes and to comply with the Dublin City Development

Plan.

We would contend that the hospital should be moved back from Western

boundary to allow for the bicycle lane within the boundaries of the site, as set

out in the Dublin City Development Plan Section 15.10.14 referring to Zone 15

sites 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”. This would be much safer for cyclists than that

proposed by the NPHDB in their submission, and it would not further constrain

emergency traffic accessing the St. James’ Hospital campus. It would also

adhere to the Dublin City Development Plan’s objective.

Parking

As we know in this community, there is significant strain on the on-street

parking during visiting hours of St. James’s Adult Hospital. The total visitor

parking being considered on the site for the St. James’s Adult Hospital together

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with the National Children’s Hospital is 1,131. This is being provided for the

total population of patients that will be treated at the two hospitals. Based on

current numbers, that would be in the region of 3,400 patients per day. This

level is totally inadequate for what will probably be the two busiest hospitals in

the country. It is an unacceptable solution for the parents, relatives and friends

of sick children and should not be allowed. There is no additional on-street

parking available in this built-up residential area. Please advise how this issue

will be addressed.

Aspergillus/Legionnaires Disease

We would like to know what specific mitigation actions are planned for the

safety of local residents as well as hospital patients for the extended duration of

this excavation work.

Vermin Control

We request that the matter of vermin control be addressed by the developer with

a view to constant monitoring in the local area. Standards should be put in place

in conjunction with the Environmental Health Service, and these should be

agreed with the local community before excavation commences. In addition,

any sightings identified locally should be addressed by the developer. This

should be monitored by Dublin City Council for the duration of this

development to ensure no risk to public health in the neighbourhood.

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

the South Circular Road, Kilmainham on a weekly basis during the autumn as

there will be an increased risk of vermin infestation due to this disruption

Sewage, flooding and Water provision

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We request that the relevant departments of Dublin City Council and

representatives of Irish Water attend the Oral Hearing to advise on the

resolution of issues regarding the treatment of sewage and the moving of the

Drimnagh Sewer, the risk of flooding at the entrance to the basement and

adequate water provision for this neighbourhood.

Working Hours

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

request that in the event of a grant of permission that the following conditions

be attached to its decision: -

We do not want work to commence before 8.00a.m during the week and we

wish it to finish at 6:00pm. Ideally, there should be no work on Saturdays at the

site, however if there is then we do not want work to commence before 9.00a.m

on Saturday mornings and request that it finish at 1:00pm. No work at all

should be permitted on Sundays, public or bank holidays.

Request for Understanding of the support for underground carpark

We request an understanding of the supporting structures required for the

underground facilities. Will supporting structures be required under the South

Circular Road – as the plans bring the buildings and excavation site right to the

boundary of the site - therefore any supporting structures may be under the road.

Can Dublin City Council confirm that they are in support of this plan and

confirm who will be responsible for the maintenance of the road should any

subsidence occur as a result of this work. We would also like confirmation that

no supports will come under our property.

Noise and Dirt:

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We would request that Dublin City Council control the dirt and noise pollution

that will result from this construction and ensure that this is kept to an

acceptable level for the local residents. The regulation of these activities should

be incorporated in a Construction Management Plan. A key objective of any

such plan should be to minimise the impact of the construction project on the

amenities of the neighbouring residents through the imposition of controls on

noise/dust emissions etc.

The submission by the NPHDB recognised that dust will be an issue for local

residents, (Chapter 12.1.5.1 of EIS). Therefore we request that the developer

clean the windows of our property (@21.9m from the construction site) weekly

for the duration of the build.

We request additional information regarding the noise that will be caused by the

helicopter landing and request this to be reviewed by the Environmental

Protection Agency to ensure the safety of our family members.

Issues re the Draft Site Capacity:

We note that there is inadequate expansion capacity for this hospital, to allow it

to last for the next 100 years. The expansion space identified will use up the

only green space at ground level. We consider this to be inappropriate for the

National Children’s Hospital

We note the future development plans included in this document relating to the

development of St. James’s Hospital. We question the correctness of building

the National Children’s Hospital in a constrained site that will be a construction

site for many years to come. The size of the proposed development for St.

James’s Adult Hospital, identified as part of this submission is indeed

staggering. It will lead to several years of construction activity, and based on

the lorry movements planned for this phase, the level of construction traffic that

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will be generated and the resultant pollution around this site will be immense.

We do not consider this a suitable environment for sick children. As a result

planning permission for the National Children’s Hospital should not be granted

for this site.

Finally, we are very concerned that if the project as outlined goes ahead, that is

will not be achievable in the expected timeframes and that the costs of same will

overrun significantly. We are concerned that the costs as identified to date do

not represent good value for money – given the extent of the demolition and

excavation required. We request that the proposal be reviewed by the Oireachtas

Committee of Public Accounts to ensure that it does provide the best value for

taxpayer’s money. We need to ensure that we select the most appropriate

location for the welfare of future generations of Irish Children, including the

children of Northern Ireland who will be treated at the All Ireland Children’s

Heart Surgery Unit in the National Children’s Hospital, while at the same time

ensuring a best in class hospital for the treatment of Adults at the St James’s

Hospital Campus.

Yours sincerely,

Joe Ruane & Mary Kearney

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abp, subm mary k.and joe r.501 scr.oct 2015.pdf

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