Our Ref: 29N.

PA0043
P.A.Reg.Ref:
Your Ref:

Brookfield Road Residents Association

C/0 Patrick Kerr
35 Brookkfield Road
Kilmainham
Dublin 8
8th October 201 S

Re: Health Infrastructure Development comprising National Paediatric

Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir,
An Bord Pleanilla has received your recent submission in relation to the above mentioned proposed development and will
take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed.
The Board will revert to you in due course with regard to the matter.
Please be advised that copies of all submissions I observations received in relation to the application will be made
available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County
Council and at the offices of An Bord Pleanala when they have been processed by the Board.
If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above
mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

Encis.

ADHOC/PA0043/0 1

SdiLI t.l:lnilhhriLic,
Baile Acha Clialh I

t,.j

Tcol CUI) K~K KIIMI Tel

Gl.u Aocuhl IK'IO 1 ~ 17~ LnC.oll
l'al, cO I ) K71 2hK~ ho.\
L.;iilhn:au Gn.'";~'im \\'\\ w pkanala tc \\ch
Rimnhphn'l hurd'" plcanala Jc [m;ul

(>I ~l ;ulhnmu~h

Strl'CI

l>uhlm I

Our Ref: 29N.PA0043

P.A.Reg.Ref:
Your Ref:

Paul O'Neill
National Paediatric Hospital Development Board
C/0 G.V.A. Planning & Regeneration
Floor 2, Seagrave House
19-20 Earlsfort Terrace
Dublin 2
5th October 2015
Re: Health Infrastructure Development comprising National Paediatric
Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir,
Enclosed for your information is a copy of submission(s) received by the Board in relation to the above mentioned
proposed development.
If you have any queries in relation to the matter please contact the undersigned officer of the Board.
Please quote the above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with
the Board.
Yours faithfully,

Encis.
PA08.LTR

TeoI !01. X5X KHMI Td

Gl.u Aililiil IK'IO ~7.~ 17~ LnC~II

Sr;iul Manilhhrik.
ll.ulc ,\lha Cli;>lh I

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L.ulhn::in Gn'a,;iin www.plcanala oc \\ell

Ruunhphn\1 hnnl0 rlcanal;o IC I llhlil

1>-1

~lmlhnmu~h

Sln:cl.

()ul>lon I

Our Ref: 29N.PA0043

P.A.Reg.Ref:

An Bord Pleamila

Your Ref:

Chief Executive Officer

Dublin City Council
Civic Offices
Wood Quay
Dublin 8
5th October 2015

Re: Health Infrastructure Development comprising National Paediatric

Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir/Madam,
Enclosed for your information are two copies of submissions received by the Board in relation to the above mentioned
proposed development.
Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.
If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the
above mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

Encis.
ADHOC/PA0043/02

Tell (01)l!~Hl!HMI ld
Gh> \nniil 11!110 ~ ~I ~ LnC:o I
(~

Sr;iltf 1\t:ouilhhritfc.
ll:oilc Ach:o Cliach 1

L:uthrc.an Grc:l'.illl "ww plcan:l):o ic \\ch

Hinmhpho'l hurdu plc;m:ol;a ac I m.ul

(>-1 .\larlhnmugh Scree!

Dublin I

An Bard Pleamila

Our Ref: 29N.PA0043

P.A.Reg.Ref:
Your Ref:

Chief Executive Officer

Fingal County Council
County Hall
Main Street
Swords
County Dublin
5th October 2015

Re: Health Infrastructure Development comprising National Paediatric

Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir/Madam,
Enclosed for your information are two copies of submissions received by the Board in relation to the above mentioned
proposed development.
Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.
If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the
above mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

Y ~~
ran Somers
lcutive officer
Direct Line:01-8737107

Encls.
ADHOC/PA0043/02

Gl.u> i.ttniol IK'Xl ~7~ IH LoC.tl

SrJt<l !ll.uilhhridc
ll:oi le A1ha Cliath I

(>-1

L:lidtrc"n Gn!;t,.nn '""" pk:m:tla oc \\d

Riumhphml hurd n ple:m:~la IC r m.ul

Matll~mu~h

S1rcc1 .
Duhhn I

Our Ref: 29N.PA0043

P.A.Reg.Ref:
Your Ref:

Chief Executive Officer

South Dublin County Council
County Hall
Tallaght
Dublin 24
5th October 2015

Re: Health Infrastructure Development comprising National Paediatric

Hospital, Innovation Centre and Family Accommodation Unit at St
James' Hospital Campus, Satellite Centres at Tallaght & Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
Dear Sir/Madam,
Enclosed for your information are two copies of submissions received by the Board in relation to the above mentioned
proposed development.
Please ensure that a copy of each submission is available for public inspection at the offices of the planning authority.
If you have any queries in relation to this matter please contact the undersigned officer of the Board. Please quote the
above mentioned An Bord Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,

ran Somers
cutive Officer
Direct Line:Ol-8737107
Encls.
ADHOC/PA0043/02

T~ol

WII X~X XICKl Tel

Gl:m \nniol IH'!O 11~ 17.~ LuC.1ll

(>-1 Sr.ild t.hunlhhrid~.
B:~ilc Atha Cli:~lh I

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Rimnhph<hl lmrd "plcanal;o ic I nwl

IH

~larlll<>nm~h

Slrccl,

l>ublin I

021h October 2015

An Bord Pleanala
64 Marlborough St
Dublin 1

Re: The National Paediatric Hospital planning application at St.

James's Hospital
Case reference: PL29N.PA0043

u I.

Submission from:
Brookfield Road Residents' Association

LTRDATEO

L~, I

FROM

Pl

Fee enclosed:

50

Contact for correspondence:

Patrick Kerr
35 Brookfield Road
Kilmainham
Dublin 8

As Brookfield Road Residents' Association, we represent the following

residents
No. 1
No. 7
No.8
No. 14
No. 17
No. 19
No. 20
No. 28
No. 29
No. 35
No. 37
No. 43
No. 45

Orla Ryan
Pedro lnnecco
John Reynor
Dermot and Ann Morris
Elizabeth 0 Gorman and Keith Me Guinness
Ruth Cassidy
Paul Lynch
Kim and Sheena Me Carty
David and Laura Beausang
Patrick Kerr
AN BORD PLEANALA
Ivan Magee and Anita Magee
Received: o2-f.J
, "h
I s=
Daisy Cummins
Fee: $C.~ ~
Teresa Lawless
Receipt No: 13131 2.1 5""

lf\

Brookfield Road Residents' Association

Review of
Direct Application to An Bord PleanAia Under Section 37e
For Pennisslon For A Period Of 10 No. Years For The Development Of The Proposed New
National Paediatric Hospital, Which Is An Integrated Health Infrastructure Development
Comprising 6 No. Principal Elements And Ancillary Development: (I) A 473 No. Bed New
Children's Hospital (Up To 118,113 Sq.M. Gross Floor Area) At The St. James's Hospital
Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (II) A 53 No. Bed
Family Accommodation Unit (Up To 4,354 Sq.M. Gross Floor Area) At The St. James's Hospital
Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (Ill) A Children's
Research And Innovation Centre (Up To 2,971 Sq.M. Gross Floor Area) At The St. James's
Hospital Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (lv) A
Construction Compound At The Fonner Unilever Site At Davitt Road, Drimnagh, Dublin 12; (V)
A Children's Hospital Satellite Centre At The Adelaide & Meath Hospital Dublin (Tallaght
Hospital), Belgard Square North, Tallaght, Dublin 24 (Up To 4,466. Sq.M. Gross Floor Area); And
(VI) A Children's Hospital Satellite Centre At Connolly Hospital Campus In Blanchardstown,
Dublin 15 (Up To 5,093 Sq.M. Gross Floor Area).

An Bord Pleanala Reg Ref 29N.PA0043

Prepared on behalf of:
Residents of Brookfield Road
Kilman ham
Dublin 8

Prepared By
Patrick Kerr and Ruth Cassidy with use of a report commissioned from
Sheridan Woods, Architects + Urban Planners,
10 Adelaide Road, Dublin 2
September 31, 2015

Date of receipt of application by An Bord Pleanala:

Final date for submissions:
An Bord Pleanala Register Reference:

10 August 2015
2 October 2015
29N.PA0043

Issue 002_30 September 2015

AN BORO PLEANALA
TIME

BY _ _ ____,

02 OCT 20\5
LTRDATED
2.

PL

FIWM _ _~

Brookfield Road Residents' Association

Contents
1.0 Introduction
2.0 Context
3.0 Proposed New Children's Hospital and Children's and Family Accommodation Unit
4.0 Key Planning Issues
4.1 Land Use Zoning and Transitional Zones
4.2 Development in Excess of Development Plan Standards
4.2.1
Plot Ratio
4.2.2 Site Coverage
4.2.3 Building Height
Impact on Adjoining Residential Amenity
4.3
4.3.1 Overshadowing
4.3.2 Overlooking
4.4
Impact on Streetscape
Capacity of St. James's Campus
4.5
4.6
Traffic and Transportation (Initial Draft Review)
4.7
Parking
5.0 Cost
6.0 Concluding Comment

AN BORD PLEANALA
TIME

-----t
D2 OCT 2015

LTRDATIO

BY

FROM

----~

Brookfield Road Residents' Association

1.0

Introduction
This review has been prepared on behalf of residents of the Brookfield Road Kilmanham,
Dublin 8. It is an overview of the overall development of the proposed National Children's
Hospital, with particular attention to the potential planning impacts of the development on the
western end of the south circular Road, Brookfield Road, and Cameron Square.

2.0

Context
The site for the proposed new children's hospital and associated Family Accommodation Unit
relates to the western section of the existing St. James's Hospital Campus contiguous to the
Brookfield Road

Brookfield Road comprises of varied house types along the street, principally two storey
dwellings, the dwellings to the west of the street are two storey with the entrance and front
garden up a number steps above the street. while the dwellings to the east are two storey and
entered at street level, also with front gardens enclosed by railings. The dwellings to the
eastern side of the road back onto the hospital grounds. There are two single storey cottages
along the street at the entrance to Cameron Square.
Sl James Campus presents a two storey high rendered boundary walls to the South Circular
Road, with an entrance to the Campus from Brook Field Road, and further high walls and red
brick hospital buildings facing Brookfield Road. This boundary is characterised by trees, some
of which are mature specimens, they are located both along sections of the hospital boundary
and internally which are visible from the South Circular Road and Brookfield Road.
3.0

Proposed New Children's Hospital and Children's and Family Accommodation Unit
The proposed New Children's Hospital is proposed as a rectangular block facing St. James
Walk to the south, the South Circular Road, and Brookfield Road to the west, and the northern
and eastern facades are internal to the campus. It includes the replacement of the existing
boundary with a new boundary, a 'moat' separating the building from the street along the
'south fingers', a set back building line for the proposed podium structure, that further steps
back to an upper level Pavilion ward blocks. The building line steps in along the western
facade to create an entrance to the New Children's Hospital at Brookfield Road.

The proposed Family Accommodation unit will include the replacement of the ~51ir.tQ-
boundary wall to Brookfield Road, and the development thetlieW'Duircflng)i!t\elstr~~-~dge.
The proposed building form returns into the campus, forming the'h~vreritrancejQ~St. James
Campus. The Family Accommodation Unit extends to the r; ar ofelds.ting..dwellings-on-- - Brookfield Road and Cameron Square.
~
02
J
Key Planning Issues
..
HO
The relevant guiding planning document is the current Dubli ai\.C,~el(lpment.P'Ian 2"-&t...,.t"'="2017. We have reviewed the proposed development in the ~xt of the Devetopmem Plan.
Based on this review it is considered that the proposed deve

ason of its
inappropriate scale, bulk, mass and layout materially contravenes the Development Plan, and
as a result is likely to seriously and adversely detract from the residential amenities of the
South Circular Road, Brookfield Road and Cameron Square. A summary of our review is as
follows:

ocT .....- -

4.0

4.1

Land Use Zoning and Transitional Zones

The subject site is zoned Z15 in the Development Plan, the objective of which is "To protect and
provide for institutional and community uses and to ensure that existing amenities are
protected. nUnder this zoning "buildings for the health, safety and welfare of the public and
Medical and related consultantsn are permitted in principle, with "car park ancillary to main use"
open for consideration. "Education" and "Residential Institution" are also both permitted in
principle. Accordingly, the principle of development is acceptable.

The development plan notes that while the zoning objectives and development management
standards indicate the different uses permitted in each zone, it is important to avoid abrupt
transitions in scale and use zones. The development plan indicates that 'In dealing with
4-

Brookfield Road Residents' Association

development proposals in these contiguous transitional zone areas, it is necessary to avoid
developments which would be detrimental to the amenities of the more environmentally
sensitive zone. '(Para 19.1 pg 192)

Particular reference is made to zones abutting residential areas or abutting residential

development within predominately mixed-use zones and notes that particular attention must be
paid to the use, scale, density and design of development proposals and to landscaping and
screening proposals in order to protect the amenities of residential properties.
The Brookfield I South Circular Road and Cameron Square land are zoned as follows: Zone 1
To protect, provide and improve residential amenity and Zone 2 To protect and I or improve the
amenities of residential conservation areas which are more environmentally sensitive zones.
The scale and form of development as proposed has a detrimental impact on the amenity of
these areas and is contrary to the development plan guidance, which is further outlined below.
4.2

Development in Excess of Development Plan Standards

The quantitative measures to assess the scale of development include Plot Ratio, Site
Coverage, Building Height and distances achieved between new and existing residential areas.

4.2.1

Plot Ratio
The indicative plot ratio of Z151and is 0.5-2.5 in the Dublin City Development Plan. Plot ratio
is a tool to help control the bulk and mass of buildings. It expresses the amount of floor space
in relation (proportionally) to the site area.

The NCH Planning Report indicates that:

'The new children 's hospital building, including the family accommodation unit (excluding the
Children's Research and Innovation Centre), measures 92,031sq.m. (above ground) on a site
of 48,350 sqm., which results in a plot ratio of 1.90'
We contend that the plot ratio expressed for the proposed development is not an accurate
representation of the extent of development proposed.
For the purposes of calculating plot ratio, it is conventional, and appropriate to calculate the
site area to include only such land as lies within the curtilage of the related buildings. It is
inappropriate to include the lands outside the site boundary or building line. Including these
lands gives a distorted view of the distribution of the bulk of the building forms on the sites.
The red line boundary indicated in the proposed development drawing extends to the centre of
the road to the west, and it incorporates the linear park to the south. Furthermore the
cumulative site area includes the roads that separate the distinctive development areas within
the overall development. Appropriate site boundaries are illustrated in Figure 1 below.
In this regard we submit that the plot ratio should be calculated for the distinctive development
parcels independently including the Family Accommodation, and the New Children's Hospital.
To illustrate this we have indicated the configuration of these parcels which comprise the
Family Accommodation site, and the new Children's Hospital site and calculated the site areas
and consequent plot ratios as follows:

r...... "' . . . . . . ._...__.a.-.

.

--~

AN BOP.D P-LE.RNAt..A

TIME

------- BY

-------~

02 OCT 2015
LTR-OATED
PL

- 5.

FROM
-

--f

Brookfield Road Residents' Association

'

;..,

,.

.., ..
iJ :::

1....;

.....

'

---L.o..,.;.'~tn"

..,. _u

ll)'

I ......
_.,./
/

~~

Red line ~ry lndudellnlemal

ro.~ta, and exlendl beyond 111e curU

Blue line lndoc:ales applCI)IIale slle boundatlea

for lhe purposes of c:alcl.olatinO plol ratio and
olte coverage lor elldl M118rtle land parcel

'

\..
~ ~~~=-'

.I

. ~.---...., ~-~--~.. ~ ~ ~ ~
.~

NewCIIIIdtens HospeSlle Curtotage

Slla Area 37,656sqm

-~

t
't

. to!""ii:A~i.A\

Fa11111y Accommod41oon Unit

Site CL.011lage
Slle Area 23A8aqm

LTROAT!O-.....-

FROM _ _.,.

Figure 1 Illustrates appropriate site boundaries for the purposes of calculating

coverage
Source: Extract From New Children's Hospital Planning App6catlon Drawing BOP O'Connell Mahon
Architects Level 00; Annotated by Sheridan Woods, 2015
New Children's Hospital - As Proposed
Sile area within the curtilage of the site New Children's Hospital Site

37,556

sqm

Total area development proposed above ground NCH

Plot Ratio

87,6n
2.3

sqm

87,677
20,000

sqm
sqm

107,677
2.9

sqm

Site area within the curt~age of Family Accommodation Site

2348

sqm

Total area development proposed above ground Family

Accommodation
Plot Ratio

4024

sqm

New Children's Hospital -With Extensions within the New

Children's Hospital Site
Total area of development proposed above ground
Total area of extensions above ground (Children's Meadow site and
over the emergency site only)
Total Area
Plot Ratio

Family Accommodation

1.7

Based on this calculation, the actual plot ratio for the New Children's Hospital is the upper level
of the 'indicative plot ratio' indicated in the development plan. This is inappropriate in the
context of a 'transitional zone', and together with the proposed extension to the hospital, the
eventual plot ratio will exceed the development plan standard.
4.2.2

Site Coverage
The development plan indicates that 'Site coverage is a control for the purpose of preventing
the adverse effects of over development, thereby safeguarding sunlight and daylight within or
adjoining a proposed layout of buildings. Site coverage is the percentage of the site covered by
building structures, excluding the public roads and footpaths. '
-6-

Brookfield Road Residents' Association

The development plan standard for Z15 land use zoning is 50% of the site. On the basis that
the site coverage excludes public roads and footpaths, the site areas as calculated in the plot
ratio assessment above apply {Appropriate site boundaries as illustrated in Figure 1 above) In
this regard the site coverage standards achieved are as follows:

New Chlldren's Hospital As Proposed

Site area within the curtilage of the site New Children's Hospital Site

37,556

sqm

Total ground floor of the NCH

18,381

sqm

..at.

Site Coverage

New Children's Hospital- With Extensions within the New

Children's Hospital Site
Total ground cover floor of the NCH

sqm

Total area of ground cover of extensions (incl. Under Croft) (Children's

Meadow site and over the emergency site only)
(15,000 In buildings ranging from 4 to 6 floor (pg 29 draft capacity
study) say average 5 floors @ 3000sqm ground floor
(5,000 sqm 3-storey building from Level 02 upwards@ 1666sqm

sqm
3000

sqm

1666
Total Area

23047

Site Coverage

sqm

61%

Family AccommodaUon
Site area within the curtilage of Family Accommodation Site

2348

sqm

Total ground cover of Family Accommodation

1388
59%

sqm

Site Coverage

Based on this calculation, the actual site coverage for the New Children's Hospital is the upper
level of the 'indicative site coverage' indicated in the development plan and together with the
proposed extension to the hospital, the eventual site coverage will significantly exceed the
development plan standard. Furthermore, the site coverage for the Family Accommodation ..tf
also exceeds the Development Plan standard. In the context of the location oftf\e proposed
development in a 'transitional zone' this scale of development is contrary to the development
plan standards.

4.2.3

t\

Building Height

0 2 OC1

,._.l
OM

The development plan indicates that the maximum height standards ~'R&Jtl&f"ct!sm ll ~R _ __,
shall have precedence over the indicative Site Coverage. Notwithst . ~~g, the ctrltentio ,
the proposed development conforms with the Development Plan Site\Cov
the development proposals, building heights will take precedence. Dublin City Development
plan is prescriptive in terms of permissible building heights. The development plan defines the
permitted height for various areas in the Dublin context which is as follows - unless otherwise
approved in a local area plan: The St. James Campus is located within the area defined as the
inner city. This area is categorized as 'low- rise (relates to the prevailing local height and
context)'. The permitted height is 'Below 28m' for commercial development.
The development plan indicates that 'For the sake of clarity, plant rooms are included in the
height definition. ' Also that: 'No height greater than that specified for the inner city category will
apply until a LAP is adopted. '
The development comprises a parapet building height of 12.6m, to 14.1m including the
proposed balustrade above ground level facing the South Circular Road, stepping up to a roof
1

Brookfield Road Residents' Association

height of 34.95m and 37.95m to chimney height. Accordingly, the roof height exceeds the
permitted development plan height of 28m by 6.95m, and if permitted would materially
contravene the Development Plan.
The planning report relies on previous planning permissions as precedence, in particular the
Mercer's Institute for Successful Ageing (MISA) (3607112), and the Co-Located Private
Hospital (Dublin City Council2751109 ABP Ref PL29S.236070). We have illustrated the
building alignment and form of the previously permitted Co-Located Hospital in Figure 2 below.
The MISA building height to the top of the roof permitted is 28 metres, the proposed height in
metres to parapet is 29.1 metres and for a small section of the stair access core is 30.85
metres. This development generally conforms with the current development plan standards,
and given its context opposite existing 6 I 7 buildings at Herberton, it is more contextual with its
immediate environs. This development is lower in building height than the proposed National
Children's Hospital.

_j

Alignment of previously permoned

Co-located Private Hospotal indicated

lnred
{

;.

'--------~-----------i----J~e.... OCT
Figure Zlllustrates alignment and position of previously permitted Co-located Hospi I,
Including tower block and podium block
LlR-OAlED_ __

l\.llJ

FROM_

Source: Extract From New Children's Hospital Planning Application Drawing BOP O'Connel[~
~o~n;:;;;::::;;;;:=:;:::::;::::;:;;
Architects Level 00; Annotated by Sheridan Woods, 2015

The permitted Co-Located Private Hospital located on part of the site of the proposed New
Children's Hospital comprised an eight storey block with roof level at52.96 AOO Malin Head I
32.85m over ground level. The top of the proposed parapet is set at54.4 AOD or 34.29m over
ground. The eight storey block however, was set back from the South Circular Road by 40.5m.
Also the foot print of the podium block was 60m in length along the South Circular Road, with a
set back, and further 13.5m length totalling 74.5m length. While the roof height of the current
proposed development is generally consistent with the previously proposed private hospital,
there are notable differences. The taller element of the previously permitted private hospital
comprised a significantly smaller footprint of 95m length, and 20m width presenting a slender
building form that was substantially set back from the South Circular Road.
It is also notable that the previously grant of permission for the private hospital development
has expired (Permission granted in June 2010). The application was determined before the
adoption of the current development plan where height restrictions are more prescriptive.
There was no application to extend the duration of the permission, and we submit that it is
unlikely that the development would have been granted an extension of duration of permission,
on the basis that it would materially contravene the development plan in terms of building
height.

-8-

Brookfield Road Residents' Association

Accordingly the overall height of the proposed national Children's Hospital exceeds the
development plan. It is not reasonable or appropriate to rely on the precedence of the
previously permitted developments on the basis that the setting of the MlSA contrasts with the
setting of the proposed national Children's hospital and is accordingly not comparable, and
also on the basis that the overall configuration of the previous co-located hospital contrasts
significantly with the current proposals in footprint, and building set backs and is also not
comparable.
4.3

Impact on Adjoining Residential Amenity

The cumulative impact of the higher range of plot ratio, excessive site coverage and building
height suggests overdevelopment of the site. The consequence of overdevelopment
generates adverse overshadowing and overlooking of adjoining residential areas.

4.3.1

Overshadowing
The overshadowing analysis carried out in Chapter 13 of the EIS demonstrates that the
proposed development will cause overshadowing along the South Circular Road and
Brookfield Road in the moming from early morning to mid morning. We note that the
assessment of the previously permitted co-located private hospital did not generate
overshadowing primarily due to the separation between residential properties and the upper
elements of the development, and the orientation thereof. (As noted in the Inspectors Report
Pl29S.236070).

Given the separation distances and the proposed heights, the proposed development will result
in generating adverse overshadowing to the South Circular Road and Brookfield Road in
particular. The extent of overshadowing will result in the loss of sunlight on the street, and
consequently the overall appearance, ambiance and amenity of the streets, and a reduction in
the sunlight currently enjoyed by the residents of the South Circular Road and Brookfield Road
in particular.
Already, certain parts of current hospital cause green mildew to grow on adjoining footpaths
due to the persistent shade, a slipping hazard for many elderly residents. This situation will be
made significantly worse with the new development, with not so much one side of the street
being in shade, but huge sections of the road being subsumed by persistent shadow.
4.3.2

Overlooking
The distances proposed between the proposed development and the existing resi~efti(}L i
development are set out in the table here
'\
"'""

LocatJon

Distance

Opposing Use

r'\A"f1: n

Previo~ ~ly pennittea-

Setbaci fRIIn exitlnn

build in

Ia.

(12.5m lrom boundary to plinth,

and ~ lnlm bculdary to
toweretemem)

South Circular Road I

JunctJon with
Mountshannon

to 'South Fingers'

32.5m
Setback from front
wan of dwellings to
plinth level
(20m to site boundary,
with 12.5m setback)
60.5m set back from
front wall of dwelling to
tower
(20m to site boundary,
40.5 m setback)
25m (for 3 floors)

to Floating Garden

Outpatient (Gnd)
Wards (Level 1)
Day care (Level 2)
Therapies (Level 3)

to Pavilion Ward

Wards

62m (for 3 floors)

25m to garden
45m to accommodation

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FIWM

Brookfield Road Residents' Association

South Circular Road I

Junction with
Brookfield Road
to South Fingers

to Floating Garden
to edge of Floating
Garden
to Pavilion Ward

NIA

Outpatient (Gnd)
Wards (Level1)
Day care (Level 2)
Corporate Services I
offices
Open Space

21.9m (for 3 floors)

38m
21.9m
49.4m
'

Brookfield Road
to Family
Accommodation

Rear of Brookfteld Road

to Family
Accommodation

Board Room (Gnd)

Bedrooms & Communal
Kitchen (Level1 &2)
Oblique bedrooms &
Stair (Level 3)
Bedrooms I Communal
kitchen I Stairwell
(Level1)
Bedrooms & Stairwell
(level2)

14.1m (Street width

Including front gardens)

33.5m

Cameron Square

to gable of Family
Accommodation

NIA

Bf

Ground Floor

18.6m

First Floor

22m ( to main wall of

house)
27.6m

LTRDATED

25.7m

PL

Second Floor
to 'North Fingers

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F"OM

The development plan requires a separation of 22m between 2 storey dwellings in order to
protect their amenity_ This standard is applicable in this context. This standard is not met
along the South Circular Road in relation to the New Children's Hospital, it is not met on
Brookfield Road in relation to the Family Accommodation Unit, and it is not met in relation to
the rear of Cameron Square. Furthermore, this distance is a minimum distance, and greater
distances should be provided where buildings exceed two storey in height
The previously permitted co-located hospital development on part of the New Children's
Hospital site was positioned 12.5m from the St. James Boundary, which allowed for 32.5m
distances between opposing structures on the South Circular Road. The proposed
development is a significantly closer than the previously permitted development.
The proximity of three storey with a roof garden, stepping to four story, and a further three
storey structure facing the existing two storey structures will cause adverse overlooking that
will significantly detract from the amenity of the existing dwellings on the South Circular Road,
Brookfield Road, and Cameron Square. The proposed development is below and just within
the minimum distances required in the development plan for the lower level structures where
overlooking is likely. Furthermore, given the height of the opposing structures at the lower and
upper levels, there will be a significant altered perception of overlooking generated and
resultant loss of residential amenity of the existing dwellings on the South Circular Road,
Brookfield Road and Cameron Square that will be visually obtrusive and have an overbearing
impact on the amenity of the residents. .
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Brookfield Road Residents' Association

4.4 Impact on Streetscape of Brookfield Road

In addition to the impact of the proposed development on the residential amenity of

surrounding properties, the scale, massing and design of the proposed development would
have a considerable negative impact on the immediate streetscape and character of Brookfield
Road.
The Brookfield Road, benefits from a strong sense of place and identity. The streetscape is of
uniform red brick terraced houses comprising of two complimentary variations on the
Edwardian style has already been materially damaged by the building of the Brookfield Clinic.
The visual impact of our street will be further undermined by:

The main concourse is being repositioned further north onto Brookfield Road, rather
than remaining at its current location, causing additional traffic flow problems with this
change of use, incorporating hospital activity into the street, detracting from existing
residential living.
The concourse being hugely expanded from a simple rear hospital exit (with no
through traffic from Brookfield Road) to the main entrance to the new hospital will
create additional traffic congestion and substantial noise pollution
As Sl James's Hospital is a non smoking campus, the smokers will have no choice but
to congregate on Brookfield Road, further adding to litter (cigarette butts), which is
already a problem on the road.

0 i. UCl .. IJ.J
LTR-OATED

FROM _ _"'

PL

On approaching Brookfield Road, the four storey family residential unit (The Ronald
Macdonald house) will now dominate the entrance to the street. It will tower over the
current properties, being over twice the height. As this building is to the east of the
road, sunlight during morning hours will be greatly diminished, making the street a
colder shadier place.

View of proposed approach to Brookfield Road

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Brookfield Road Residents' Association

Felling of mature trees will hugely diminish the attractiveness of the street. Currently
they create a significant barrier between the hospital and the street. With the proposed
changes, the householders on the street will be directly overlooking a four story
hospital building.

It should be noted that there has been no attempt by the designers to create a building that will
blend with the current aesthetics of the street. Bright colours on the facades of the buildings
are a poor attempt to hide the fact the street will be in shadow due to the new developments.
Nor does the style of the building reflect the ethos of Edwardian Dublin. It seems ironic that in
one part of Dublin, just off Merion Square planners are doing everything possible to recreate
portions of lost Edwardian architecture, while little or no thought is being given to the damage
of the exact same architectural style on Brookfield Road.
Paragraph 16.1.8 of the Development Plan gives guidance on urban form and architecture, and
indicates that urban blocks should be designed to promote permeability and walkability,
thereby integrating with the existing urban fabric. It is reasonable that the hospital campus
should conform to this aspiration. The development plan indicates that urban block lengths
greater than 1OOm should be avoided. Developments should relate to the local context of
building patterns or typologies.
The photomontage views of the proposed development however illustrate the visual impact of
the proposal on the neighbouring streets and demonstrate the vast scale of the proposal
relative to the existing local context. The proposed building 'moat' separating the street edge
and the building, the proposed setback at third floor with intensive planted roof garden level is
incongruous, and the curved three storey form is discordant.

Photo taken from presentation boards at F2 meetings. Brookfield Road is highlighted in red.

[.

02 OCT ~lis~
LTRDATiD

- 12.

FftOM

----~

Brookfield Road Residents' Association

Photo taken from presentation boards at F2 meetings

This is a photomontage is looking east down Brookfield Street.
with end of terrace of Brookfield Road in the distance, with proposed the family
accommodation unit.

r... Elevation 8oultl

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Photo taken from presentation boards at F2 meetings

This drawing illustrates the scale of the proposed family accommodation unit on Brookfield
Road. The small house on the left is the first house of the terrace, with the Brookfield Clinic
with the apexes towards the road.

0 2 OCl

---

LTR-OA~D

Pl.
- 13 -

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FI'OM _ _""'

Brookfield Road Residents' Association

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02 OCT

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,...._ _ Ncmonol Pced10trlc Hospital Project local Regeneration Opportunities ---1-~::..:.:..::.:..:::._:=::::::~

Figure 3 Extract From Urban Initiatives Study

Source: Appendix 5:2 of the EIS "National Paediatric Hospital-local Regeneration Opportunities

Furthermore, the continuous length of the urban block measuring over 100m facing James
Walk, and greater than 200m along the South Circular Road, and Brookfield Road presents an
building scale that is contrary to the local and city building block. This is notably illustrated in
Appendix 5:2 of the EIS "National Paediatric Hospital- Local Regeneration Opportunities
where the existing context is illustrated, the regeneration opportunities indicatively illustrated in
careful urban blocks and the proposed Children's Hospital representing the single largest
urban block (Extract included above for illustration purposes). As a consequence the overall
development will overwhelm, detract from and result in the loss of the existing local character.
It should be noted, there have been no 30 models created, illustrating the impact of the
proposed development on Brookfield Road.
Traffic Flow
Brookfield Road becomes a one way street where it slopes down towards Old Kilmainham Road
(vehicles cannot access the street from the Old Kilmainham Road). Because of this, the only
access to Brookfield Road is by South Circular Road. Currently, around the St. James's Hospital
entrance, most weekday morning's traffic on the South Circular Road is little more than a jam
that consumes the whole road, going around the Rialto Roundabout, up Herberton Road,
regularly back as far as the canal.

With the proposed development, this situation would be exacerbated, meaning residents of
Brookfield Road would find their houses nearly inaccessible (without extremely long waits)
during the busiest times of the day when access is most needed.
4.5

Capacity of St. James's Campus

The Capacity Study accompanying the application presents an indicative layout illustrating how
it may accommodate the extent of development required for the three hospitals within the St.
James campus. This indicates that further 6 and 7 storey buildings with basement levels will
be required. The study relies on plot ratio assessment only, indicating that the campus is only
just capable of achieving the quantitative extent of development required within the standards
of the development plan with little room for further expansion or enhanced public realm (The
plot ratio expressed is 2.2). There is no indication of site coverage and no three dimensional
analysis.
14.

Brookfield Road Residents' Association

It is reasonable to assume that it is likely that in order for the campus to accommodate the
development of three hospitals that the remained of the site will be as intensively developed as
the proposed children's hospital portion of the site. If this is the case, this would potentially
lead to the development of an urban quarter that is so intensively developed that it does not
meet Dublin City Councils ambition for the built environment of Dublin to deliver quality urban
environments.
The capacity study highlights the shortcoming of the St. James Campus, that there is
insufficient site capacity to accommodate all three hospitals while achieving overall quality of
development and physical environment. The study clarifies why the site apportioned to the
children's hospital is so constrained, and why it has been necessary to develop the hospital
with 3 basement levels, and 8 floors above ground, which results in over development of the
children's hospital site, and which will set a precedence for the further over development of the
remainder of the site in order to meet the strategic health needs. We submit that this does not
represent proper planning and sustainable development.

---- , ... L

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Figure 4 Extract from Draft Site Capacity Study

Source: extract from StJames's Campus Site Capacity Study, BOP O'Connell Mahon Architects 2015

4.6

Traffic and Transportation

The planning report acknowledges that the biggest impact during construction will be as a
result of the export of material from site during basement excavations, over an approximate 18
month period, and the importation of materials for the construction process. This is significant,
and will seriously impinge on the amenity of residents in the area for an extended period during
construction period.
The traffic analysis during the operation of the development does not include sufficient stress
tests, including assessments during wet weather etc, and the proposed development relies on
a modal shift from car usage among staff and enhanced public transport provision for staff and
patients. The existing area already experiences traffic congestion and as acknowledged in the
planning report, 'that the surrounding street network will continue to experience traffic queuing
and delays at some periods through a typical week day. The mitigation proposals included as
part of the Transport Strategy for the St. James's Hospital campus and the new children's
hospital ensures that the increase in traffic levels and associated impact during these periods
are kept to a minimum.'

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Brookfield Road Residents' Association

It is submitted that this is not sufficient to ensure that the impact of the traffic proposals will not
exacerbate the existing traffic and transport context. The marginal manner in which traffic is
managed to ensure that increased levels in traffic and associated impacts are kept to a
minimum suggests that the site and adjoining road network does not have the capacity to
accommodate the proposed development, in accordance with proper planning and
development.
4.7

Parking
It is recognised that the proposed transport strategy which limits car parking provision within the
St. James's Hospital Campus, will almost certainly increase car parking demands on
neighbouring roads and streets. As the proposed concourse opens onto Brookfield Road, it
seems clear that this demand for parking will be focused primarily on this street.
In the planning application (EIS report ref 6.80) under the heading "Extend the on-street
controlled disk parking", it is proposed that this situation can be resolved by changing the
current disk parking system on streets adjacent to the hospital.
However, even if the current system on the street becomes twenty-four-hour paid parking, this
will only deter drivers who need to park their cars for extended amounts of time (like patients or
staff). The majority of visitors will not be deterred from parking on Brookfield Road if they only
have to pay a couple of Euros while they visit sick relatives, friends or children. The times that
these visitors will need parking spaces will be during visiting hours (usually 6-8pm)- the exact
hours the residents of Brookfield Road will be returning home from work and in need "to park
their cars.
5.0

o2 oct

Concluding Comment

t U\)

Notwithstanding the Strategic Infrastructure Development status o

and its importance to the future development of the City and the S~~--;;;;;::
development of the New Children's Hospital does not confonn with t e proper planning and
sustainable development of the area and should be refused pennission.

Having regard to the provisions of Dublin City Development Plan 2011-2017 in

relation to 'Taller Buildings as Part of the Urban Form and Spatial Structure of Dublin'
and in particular to Policy SC17 which seeks to 'protect and enhance the intrinsic
quality of Dublin as a predominantly lo-rise city and to provide for taller buildings in the
designated limited locations, it is considered that the proposed development would
exceed the defined height identified for Inner City locations, and would contravene
Dublin City Policy in this regard.
Having regard to the transitional zone area, to the height and scale of the proposed
development, its sitting in close proximity to the residential properties adjoining the
allocation to the west, by reason of overbearing aspect, excessive overlooking, and
visual intrusion, the development is an abrupt transition between the Z15 and
residential use zoning (zone 1 and Zone 2) and does not accord with the policies and
objectives of the Dublin City Development Plan.
Having regard to the height, scale, massing of the development it would be visually
intrusive in relation to the existing character and scale of the immediate local
streetscape along the South Circular Road, and Brookfield Road. The development
would seriously injure the amenities of the area and would therefore be contrary to the
proper planning and development of the area.
The capacity of St. James's Hospital to accommodate the children hospital and future
hospitals is marginal, and requires further 6 and 7 storey structures over basement
levels, without any notable enhancement of the public realm, which would suggest that
the site does not have sufficient capacity to accommodate the children's hospital or
future development of two additional hospitals.
The operational and construction impact of the development on traffic in the area will
seriously impact on the existing road network, and does not confonn with proper
planning and development of the area.
-16-

Brookfield Road Residents' Association

Simply put, Brookfield Road is a quiet residential road. With the current designs for the hospital
(as outlined above) the street will simply be an extension of a hospital entrance, a conduit for
hospital vehicles, with cars clogging the access points, hospital visitors taking resident's
parking spaces, smokers loitering outside the hospital gates, while the buildings themselves
casting huge shadows over many of the properties. Simply put, the planners are sacrificing
Brookfield Road and the comfort of all its homeowners for their own convenience.
The Brookfield Road Residents' Association would welcome the opportunity to present their
concerns to the board, if it is intended to hold an oral hearing in respect of the proposed
development, and requests an opportunity to do so.
We trust An Bard Pleanala will take our submission into account.

Patrick Kerr on behalf of the Brookfield Road Residents' Association

02 OCT

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LTRD~T~ ,-----PL

17 .