Our Ref: 29N.

PA0043

An Bord Pleanala

P.A.Reg.Ref:
Your Ref: Gordon Smyth

Charlotte Sheridan
Sheridan Woods Architects.
10 Adelaide Road,
Dublin 2.
9th 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 Madam,

An Bord Pleana.Ia has received your recent submission in relation to the above mentioned proposed development and will
take it into consideration in its determinationofthe 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 Pleanata 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 Pleamila reference number in any correspondence or telephone contact with the Board.

Yours faithfully,

Executive Officer
Direct Line:Ol-8737107
Encls.
ADHOC/PA0043/0l

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SHERIDAN WOODS I architecture I urban design I planning

Submission To An Bord Pleanala

Third Party Submission

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

An Bord Pleanala Reg Ref 29N.PA0043

Prepared On Behalf Of

AN BORD PLEANALA
Received:

Mr. Gordon Smyth

49 Brookfield Road
Kilman ham
Dublin 8

oz/l o/ 1?:
I

~
Receipt No: 6 I ~ l 2..o "':1-

Fee:

f so.oo

AN BORD PLEA~AL.A11
TIME \ s ~ oo BY "---~

0 2 OCT 2015
LlRDATED

PL
Prepared By

Sheridan Woods, Architects+ Urban Planners,

10 Adelaide Road, Dublin 2
October 1 , 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 0028_01 October 2015

II

IRISH PUNNING

INSTITUTE

Chorlolle
Kevin Woods, SWAUP
Architect and Ult>an OeslgnM, 0 pArch BArch Sc: MSc: Urban Design MRIAI
T/A ShDifdan Woods Atc:h lecb + Urban Planners Ltd Registered In Ireland Reg Na. 3752.5.4 VAT

FROM _ _-1

SHERIDAN WOODS

1.0

Introduction
This submission has been prepared by Sheridan Woods Architects + Urban Planners Ud, on
behalf of our client, Mr. Gordon Smyth of 49 Brookfield Road, Kifmainham, Dublin 8. Our client
wishes to object to the proposed development and we request that the development is refused
planning permission. We enclose here a cheque to the sum of 50.00 being the appropriate
fee. We set out here an over view of the overall development of the proposed National
Children's Hospital, and Family Accommodation Unit and set out grounds for refusal in relation
to the overall development, and with particular attention to the potential planning impacts of the
development on our clients property, No. 49 Brookfield Road.

2.0

Context
The site for the proposed new children's hospital and associated Family Accommodation Unit
relates to the western section of the existing st. James's Hospital Campus contiguous to the
South Circular Road, Brookfield Road and Cameron Square.
The South Circular Road is characterised by two storey dwellings, set back from the pavement
with front gardens enclosed by railings. The South Circular is lined with mature deciduous
trees and presents a formal appearance. Brookfield Road comprises more varied house types
along the street, principally two storey dwellings, the dwellings to the west of the street are two
storey with the entrance and front garden up a number steps above the street, while the
dwellings to the east are two storey and entered at street level, also with front gardens
enclosed by railings. The dwellings to the eastern side of the road back onto the hospital
grounds. There are two single storey cottages along the street at the entrance to Cameron
Square. Cameron Square is accessed off Brookfield Road and comprises two storey dwellings
formally arrange in a square, with front gardens enclosed by railings. All three residential
areas present their own distinctive character, and benefit from a strong sense of place.
St. James Campus presents a two storey high rendered boundary walls to the South Circular
Road, with an entrance to the Campus from Brook Field Road, and further high walls and red
brick hospital buildings facing Brookfield Road. This boundary is characterised by trees, some
of which are mature specimens, they are located both along sections of the hospital boundary
and internally which are visible from the South Circular Road and Brookfield Road.

3.0

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

4.0

Key Planning Issues

The relevant guiding planning document is the current Dublin City Development Plan 2011 2017. We have reviewed the proposed development in the context of the Development Plan.
Based on this review it is considered that the proposed development by reason of its
inappropriate scale, bulk, mass and layout materially contravenes the Development Plan, and
as a result is likely to seriously and adversely detract from the residential amenities of the
South Circular Road, Brookfield Road and Came
w is as
follows:
AN BORD PLEANALA

TIME._ _ _ _ BY _ _ _- - t

0 2 OCT 2015
LTRDATID

------------------------------------~
PL .Issue 002B_October 1, 2015
-2

FNOM- - - t
-

.. . . . . .ad, Oublin8
~

SHERIDAN WOODS

4.1

Land Use Zoning and Transitional Zones

The subject site is zoned Z15 in the Development Plan, the objective of which is "To protect
and provide for institutional and community uses and to ensure that existing amenities are
protected." Under this zoning "buildings for the health, safety and welfare of the public and
Medical and related consultants" are permitted in principle, with "car 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
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 '- artilage of the related buildings. It is
inappropriate to include the lands outside the site boundary or building line. Including these
lands gives a distorted view of the distribution of the bulk of the building 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

s ospital.
parcels independently including the Family Accom
To illustrate this we have indicated the configurati n ofMf~SBQ)fitBI~
e
Family Accommodation site, and the new Childre -t1~ital site an~;lc;::
; ul:=:,
at~
e--T
and consequent plot ratios as follows:

0 2 OCT 2015
LTRDAtf.D
Issue 0028_October 1, 2015

PL

Dublin 8

SHERIDAN WOODS

ROPLEANALA
TIME

y
Blue -lndlcaleiiiAlfQpriate a~e baUnCierln
IQr 111e purposes a1 calculating plot ratio and
.... coo;erage lor Ndl eepnte land pan:el

.7

New CNidt1!ns Haspital

Sde Cullilage
Site An!a 37,556sqm

ev___..,.

2 OCT 2015

Fllmlly Ao:arnmodlban U'*

S~eCunuge

Sb An!a 2348IIJII

Figure 1111tJstrates appropriate site boundaries for the purposes of calculating pi

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

37,556

sqm

Total area development proposed above ground NCH

Plot Ratio

67677
2.3

sqm

67677

SQm
sqm

New Children's Hospital- With Extensions within the New

Children's Hospital Site
Total area of deveiO(l!llent_RfopC)Sed above ground
Total area of extensions above ground (Children's Meadow site and
over the emeraencv site onlvl
Total Area
Plot Ratio

Family Accommodation
Site area within the curtilage of Family Accommodation Site
Total area development proposed above ground Family
Accommodation
Plot Ratio

20,000

1o1.6n _sqm
2.9

2346

~m

4024

sqm

1.7

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

Site Coverage
The development plan indicates that 'Site coverage is a control for the purpose of preventing

the adverse effects of over development, thereby safeguarding sunlight and daylight within or
adjoining a proposed layout of buildings. Site coverage is the percentage of the site covered by
building structures, excluding the public roads and footpaths.'
The development plan standard for Z15 land use zoning is 50% of the site. On the basis that
the site coverage excludes public roads and footpaths, the site areas as calculated in the plot
ratio assessment above apply (Appropriate site boundaries as illustrated in Figure 1 above) In
this regard the site coverage standards achieved are as follows:

bsue002B_~ober1,2015

-4-

49 Brookfield Road, OubHn 6

SHERIDAN WOODS

New Children's Ho~pital - As Pro.stosed

Site area within the curtilage of the slte New Children's Hospital Site
Total ground floor of the NCH
Site Coveraae

~m

37,556
18,381

~~.

'ALA

r:::.A ..

onQtl) PL~''

r~~illd.~5Hl~~~~~ms.O!M~~n;~w-----r---1rlffi~~~,~-~~~ev ____________~
New Children's Hospital- With Extensions within the New
Children's Hospital Site

1\M-.;t-

"1Q4C.

7a~l~gtr~ou~n~d~co~v~er~n~oo~r~o~ft~he~N~C~H~------------------;---~~--+-~T=~
~~~
\lrlQC1 L

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 G 1666sqm
Total Area
Site Coverage

Family Accommodation
Site area within the curtilage or Family Accommodation Site
Total ground cover or Family Accommodation
Site Coveraae

sqm

~ ~D;---.- - Pl
23047
61%

. ~m

2348

~m

1388

~m

'a

f"O'-' _____,
,_.

69%

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

4.2.3

Building Height
The development plan indicates that the maximum height standards set out at section 17.6
shall have precedence over the indicative Site Coverage. Notwithstanding, the contention that
the proposed development conforms with the Development Plan Site Coverage standards in
the development proposals, building heights will take precedence. Dublin City Development
plan is prescriptive in terms of permissible building heights. The development plan defines the
permitted height for various areas in the Dublin context which is as follows - unless otherwise
approved in a local area plan: The st. James Campus is located within the area defined as the
inner city. This area is categorized as 'Low- rise (relates to the prevailing local height and
context)'. The permitted height is 'Below 28m' for 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
height of 34.95m and 37.95m to chimney height. Accordingly, the roof height exceeds the
permitted development plan height of 28m by 6.95m, and if permitted would materially
contravene the Development Plan.
The planning report relies on previous planning permissions as precedence, in particular the
Mercer's Institute for Successful Ageing (MISA) (3607/12), and the Co-Located Private
Hospital (Dublin City Council 2751/09 ABP Ref Pl29S.236070). We have illustrated the
building alignment and form of the previously permitted Co-Located Hospital in Figure 2 below.
The MISA building height to the top of the roof permitted is 28 metres, the proposed height in
metres to parapet is 29.1 metres and for a small section of the stair access core is 30.85
metres. This development generally conforms with the current development plan standards,
and given its context opposite existing 6 /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.

lssue002B_October 1, 2015

-5-

49 Brookfield Road, Dublin 8

SHERIDAN WOODS

02 OCT 20t5
----~ROM _ _..,.

Including tower block and podium block

Source. Extract From New ChAdren's Hospital Planning Application Drawing BOP O'Connell Mahon
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 at 52.96 AOD Malin Head I
32.85m over ground level. The top of the proposed parapet is set at 54.4 AOD or 34.29m over
ground. The eight storey block however, was set back from the South Circular Road by
40.5m. Also the foot print of the podium block was 60m in length along the South Circular
Road, with a set back, and further 13.5m length totaling 74.5m length. While the roof height of
the current proposed development is generally consistent with the previously proposed private
hospital, there are notable differences. The taller element of the previously 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 201 0). The application was determined before the
adoption of the current development plan where height restrictions are more prescriptive.
There was no application to extend the duration of the permission, and we submit that it is
unlikely that the development would have been granted an extension of duration of permission,
on the basis that it would materially contravene the development plan in terms of building
height.
Accordingly the overall height of the proposed national Children's Hospital exceeds the
development plan. It is not reasonable or appropriate to rely on the precedence of the
previously permitted developments on the basis that the setting of the MISA contrasts with the
setting of the proposed national Children's hospital and is accordingly not comparable, and
also on the basis that the overall configuration of the previous co-located hospital contrasts
significantly with the current proposals in footprint, and building set backs and is also not
comparable.

4.4

Impact on Adjoining Residential Amenity - Overall Context

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

Issue 0028_October 1, 2015

-6-

49 Brookfield Road, Dublin 8

SHERIDAN WOODS

4.4.1

Overshadowing
The overshadowing analysis carried out in Chapter 13 of the EIS demonstrates that the
proposed development will cause overshadowing along the South Circular Road, and
Brookfield Road in the morning from early morning to mid morning. We note that the
assessment of the previously pennitted 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 Joss of sunlight on the street, and
consequently the overall appearance, ambiance and amenity of the streets, and a reduction in
the sunlight currently enjoyed by the residents of the South Circular Road and Brookfield Road
in particular.

4.4.2

Overlooking
The distances proposed between the proposed development and the existing residential
development are set out in the table here.
Location

Opposing Use

Distance

Previously pennmed
Setback from existing
buHdlngs
(1 2.5m han boundary to plinth.
and 40m han boundary ID

-elomenll

South Circular Road I

Junction with
Mountshannon

to 'South Fingers'

32.6m
Setback from front wall
of dwellings to plinth
level
(20m to site boundary,
with 12.5m setback)
80.6m set back from
front wall of dwelling to
tower
(20m to site boundary,
40.5 m setback)
25m (for 3 noors)

to Floating Garden

Outpatient (Gnd)
Wards (level 1)
Davcare (Level 2l
Therapies (level 3)

to Pavilion Ward

Wards

62m (for 3 noors)

South Circular Road I

Junction with
Brookfield Road
to South Fingers
to Floating Garden
to edge of Floating
Garden
to Pavilion Ward

25m to garden
45m to accommodation

NIA
Outpatient (Gnd)
Wards (level 1)
Oaycare (Level 21
Corporate Services I
offiCes
Open Space

21.9m (for 3 noors)

'

38m
21.9m

Rear of Brookfield Road

to Family
Accommodation

Issue 002B_October 1, 2015

AN BORD
TIME

....

...

-~

LEAI'l.,~LA

- r
0 2 01..T 2015

Board Room (Gnd)

Bedrooms & Communal
Kitchen (Level1&2)
Oblique bedrooms &
Stalr(level 3)
Bedrooms I Communal
kitchen I Stairwell
(Level 1)
Bedrooms & Stairwell
(Level 2)

-7-

14.1m (Street width

Including front gardens)

-PlD na.Ta n
-

PROM

33.5m

49 Brookfield Road, Dublin 8

-~

_ _j

49.4m

Brookfield Road
to Family
Accommodation

- .

SHERIDAN WOODS

Cameron Square
to gable of Family
Accommodation

NIA

Ground Floor

1B.6m

First Floor

22m ( to main wall of

house)
Z76m
25.7m

Second Floor
to 'North Flnaers

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. Furthennore, this distance is a minimum distance, and greater
distances should be provided where buildings exceed two storey in height.
The previously pennitted 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 pennitted 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 over1ooking that
will significantly detract from the amenity of the existing dwellings on the South Circular Road,
Brookfield Road, and Cameron Square. The proposed development is below and just within
the minimum distances required in the development plan for the lower level structures where
over1ooking is likely. Furthermore. given the height of the opposing structures at the lower and
upper levels, there will be a significant altered perception of overtooking generated and
resultant loss of residential amenity of the existing dwellings on the South Circular Road,
Brookfield Road and Cameron Square that will be visually obtrusive and have an overbearing
impact on the amenity of the residents ..
4.5

Impact On Amenity Of No. 49 Brookfield Road

We have carried an assessment of the impad of the proposed development on our client's
property. This includes a review of the existing amenity, a description of the location of the
proposed development relevant to No. 49, and an assessment of the impad of the
development with regard to visual impact, over1ooking and overshadowing.
Location
No. 49 is located to the north western side
of Brookfield Road. The dwelling currently
front onto an existing concrete boundary
wall to the hospital, with set back two storey
brick strudures.

TIME_, .

~-

. - ----4
t

02 OCT 2015
LTRDAlED._ _ _ FIItOM _ __..

lssue002B_October 1, 2015

------~--

-8-

49 Brooldleld Road, Dublin 8

SHERIDAN WOODS

Existing
The front of the dwelling enjoys early
morning eastern sunlight from sunrise to
mid morning.
The dwelling faces an existing concrete
blockwork wall and a two storey structure
that forms part of the hospital.
The street is characterised by two storey
structures.
The proposed Family Accommodation Unit
is located to the east of the dwelling. The
FAU
presents 11.95m high fa~de facing the
dwelling. The building steps down to the
meeting the adjoining terrace and steps up
to fonn the entrance to the New Hospital
Entrance Piazza. The separation distance
between the new structure and the existing
dwelling is 14.16m
A conference room is proposed at ground
floor level. The ground floor level is
consistent with the ground floor level of the
dwelling. Bedrooms are proposed at the
upper two floors.
The main entrance to the New Children's
Hospital is located south east, in a position
closer than the existing entrance to the
hospital to an large open plaza space.
Landscaping proposals to the front of the
block suggest the inclusion of street trees.

4.5.1

."

. ...
;

:!

. 1;

: .. ~:'"'\IIIIIJII.IOcl

:1~.'

: ~

~ *) ; .
Extract From New Children's Hospital Planning
Application Drawing BOP O'Connell Mahon Architects
Level 00; Annotated by Sheridan Woods, 2015

AN BORD PLEANALA

av___- t

TIME

02 OCT 2015
LTROAT!D

PROM _ _...

Impact Of Proposed Development

Impact Of Proposed Development
Visual Intrusion
Given the close position, height and scale of
the proposed Family Accommodation Unit it
will visually dominate the views from the front
of the dwelling at ground and first floor level.
As a result of this it will be both visually
intrusive and have an over bearing impact on
the residents of No. 49 Brookfield Road.
The views southwards from the front window
will be further enclosed by the AFU building
stepping up to four floors to the new
entrance plaza.
The overall impact is an oppressive
enclosing effect on the dwelling, that detracts
from its residential amenity.

Issue 002B_October t, 2015

.g.

Source:
ChUdren's Hospital Planning
Application Drawing BOP O'Connell Mahon Architects
Level 00; Cropped by Sheridan Woods, 2015
Facades Facing The Rear of No. 49 Brookfield Road

49 Brookfield Road, Dublin 8

SHERIDAN WOODS

Overshadowing
The EIS assesses the impact of the development on No. 49 and specifically calculates the
Vertical Sky Component, and the access to sunlight. A reduction in both in noted and the
proposed Family Accommodation Unit is the primary contributor to this reduction.
While the existing sky component and access to sunlight from the front of the property is low,
the combination of the proximity of the AFU and the reduction in the sky component and
access to sunlight will represent a serious depreciation in the enjoyment of our client's
property. This significantly detracts from the amenity of our clients property.

r..,.

11 '1 PciW

w.-....nDUar.-

r ..,

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lt 1 ' .:..7"f~~ ~r'1

t+-~JL~7~: 1~'
I

I
.._

.tf
J'

,.......
"'"-"
Source: Extract From EIS Chapter 13 Figures 13
Shadow Plans show the Proposed shadow plans for eac:h
hour on 21st March I September from 8 OOam shadow

f \\\ . I ';.I/ yJ"/1

~

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1...-1\'

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Source; Extract From EIS Chapter 13 Figure 13.17

Illustrating Impact of Family Ac:c:ommodatlon Unit
On the sky component

plan Jnustrated - Loc:atlon of No. 10 Brookfield Road

Highlighted - Annotated by Sheridan Woods 2015

Overlooking
The separation distance between the Family
Accommodation Unit and the front facade of
No. 49 is just 14.16m. The proposed ground
floor conference room will directly face the
living window of our clients property, and
bedrooms at first floor.
The separation distance is well below the
development plan separation distances. The
proximity and nature of use of the proposal
will generate over1ooking of our clients
property and will result in a significant toss of
privacy to our clients property.

AN BORD PLEANALA

----

TIME

BV _ _--i---1

0 2 OCT 2015

---

LTROATEO

PL

FROM_..,._-1

Landscaping
The landscaping plan suggests the provision
of street trees adjoining the proposed family
Accommodation opposite our client's
property.
There is insufficient space along the foot
path to accommodate the trees and to
ensure their success.

Issue 002B_October 1, 2015

-10-

49 Brookfield Road, Dublin B

SHERIDAN WOODS

Based on the above analysis and previous findings we submit the following to An Bord
Pleanala:

The close proximity of the Family Accommodation Unit opposite the front facade of our
clients property will be visually intrusive and have an overbearing impact on the
amenity of our clients property.
The proposed development will result in the loss of sunlight to the property in particular
in the morning at sun rise to mid morning,
The proposed development will result in the loss of vertical sky component as a
consequent of the proximity and height of the proposed development, and will have a
closing effect on the dwelling.
The proposed development will generate adverse overlooking as a consequence of
proximity and separation distance between the proposal and our clients dwelling, and
will result in the loss of privacy enjoyed by our client.
The change in scale of development along the street is incongruous and detracts from
the integrity of the two storey architectural character of the street.
The provision of the new entrance to the hospital northwards to Brookfield Road will
result in a significant change of use along the street, giving a sense of being part of the
hospital activity, will detract from the existing residential amenity. This will have a
particular impact on our clients property.
The scale of new development along the street, together with the intensified hospital
use on the street will significantly erode the existing sense of place currently enjoyed
by the Brookfield Road community.
The increased traffic will significantly alter the character, noise levels, and
environmental quality of the street.
There is insufficient space along the proposed footpath to accommodate the proposed
street trees to the front of the proposed Family Accommodation Unit.

It is requested that the proposed development is refused permission on these grounds.

Mitigation Measures:
If it is intended to permit the proposed development, we request that the Family
Accommodation Unit is redesigned to take account of the negative impact that the structure
has on the amenity of our client property and the provision of additional landscaping. In this
regard we request the following:

4.6

That the building is set back further to increase the street width, that the overall height
of the structure is reduced to limit the enclosing and overbearing impact.
We request that the street pavement is designed to allow for the successful planting of
new street trees opposite our clients property adjoining the proposed Family
Accommodation Unit.
That the extent of tree planting is increased to the front of the Family Accommodation
Unit to further lessen the immediate impact to our clients.
That landscaping, such as the provision of a line oftrees is positioned to the edge of
the proposed plaza, to create a separation between the proposed entrance to the
hospital, and Brookfield Road. The purpose of this is to limit the exposure of the
residents on Brookfield Road to the activity of the Hospital, and to block the view of the
main entrance from Brookfield Road in order to maintain the identity of Brookfield as a
distinct neighbourhood, and not part of the overall hospital campus.

Impact On Streetscape
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 the area.
The existing South Circular Road, Brookfield Road, and Cameron Square area all benefit from
a strong sense of place and identity.

AN BORD
TIME

PLEANA~A - ~

BY ____---\.

0 2 OCT 2015
Issue 0028 October 1, 2015

- tt

LI,..U~ICU

PL

IJI'

eld Road Dublin 8

SHERIDAN WOODS

Paragraph 16.1.8 of the Development Plan gives guidance on urban fonn and architecture,
and indicates that urban blocks should be designed to promote penneability and walkability,
thereby integrating with the existing urban fabric. It is reasonable that the hospital campus
should confonn to this aspiration. The development plan indicates that urban block lengths
greater than 100m should be avoided. Developments should relate to the local context of
building patterns ortypologies. The photomontage views of the proposed development
however illustrate the visual impact of the proposal on the neighboring streets and
demonstrate the vast scale of the proposal relative to the existing local context. The proposed
building 'moat' separating the street edge and the building, the proposed setback at third floor
with intensive planted roof garden level is incongruous, and the curved three storey fonn is
discordant.

LA
AN ~ O.RD P
TIME""""'
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---

LTROATEO
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~~~~~~--- National Paediatric Hospital Project- local Reg~neration Opponunrt1es _ _L;.:.;M;:::====~:;;==:I

Source: Appendix 5:2 or the EIS "National Paediatric Hospital- Local Regeneration Opportunities"

Furthennore. the continuous length of the urban block measuring over 1OOm facing James
Walk, and greater than 200m along the South Circular Road, and Brookfield Road presents an
building scale that is contrary to the local and city building block. This is notably Illustrated in
Appendix 5:2 of the EIS National Paediatric Hospital -Local Regeneration Opportunitiesw
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.
4.7

Capacity of St. James Campus

The Capacity study accompanying the application presents an indicative layout illustrating how
it may accommodate the extent of development required for the three hospitals within the St.
James campus. This indicates that further 6 and 7 storey buildings with basement levels will
be required. The study relies on plot ratio assessment only, indicating that the campus is only
just capable of achieving the quantitative extent of development required within the standards
of the development plan with little room for further expansion or enhanced public realm (The
plot ratio expressed is 2.2). There is no indication of site coverage and no three dimensional
analysis.
It is reasonable to assume that it is likely that in order for the campus to accommodate the
development of three hospitals that the remained of the site will be as intensively developed as
the proposed children's hospital portion of the site. If this is the case, this would potentially
lead to the development of an urban quarter that is so intensively developed that it does not
meet Dublin City Councils ambition for the built environment of Dublin to deliver quality urban
environments.

Issue 002B_October 1, 2015

49 Brookfield Road, Dublin 8

SHERIDAN WOODS

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.

AN BORD PLEANALA

02 OCT 2015
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Figure 4 Extract From Draft SHe Capacity Study

Source: Extract From St. James Campus Site Capacity Study BOP O'Connell Mahon Architects 2015

4.8

--

Traffic And Transportation

The planning report acknowledges that the biggest impact during construction will be as a
result of the export of material from site during basement excavations, over an approximate 18
month period, and the importation of materials for the construction process. This is significant,
and will seriously impinge on the amenity of residents in the area for an extended period during
construction period.
The traffic analysis during the operation of the development does not Include sufficient stress
tests, including assessments during wet weather etc. and the proposed development relies on
a modal shift from car usage among staff and enhanced public transport provision for staff and
patients. The existing area already experiences traffic congestion and as acknowledged In the
planning report, 'that the surrounding street network will continue to experience traffic queuing
and delays at some periods through a typical week day. The mitigation proposals included as
part of the Transport strategy for the StJames's Hospital campus and the new children's
hospital ensures that the increase in traffic levels and associated impact during these periods
are kept to a minimum.' It is submitted that there is over reliance on the mitigation measures
to ensure that the impact of the traffic proposals will not exacerbate the existing traffic and
transport context. The marginal manner in which traffic is managed to ensure that increased
levels in traffic and associated impacts are kept to a minimum suggests that the site and
adjoining road network does not have the capacity to accommodate the proposed
development in accordance with proper planning and development.

Issue 0028_October 1, 2015

-13-

49 Brookfield Road, Dublin 8

SHERIDAN WOODS

In relation to car parking, there is currently significant pressure on car parking in the locality.
The reliance on the modal shift from car use to public transport while commendable is
ambitious. Furthermore, the development has the potential to result in the loss of existing car
parking spaces at Brookfield Road in particular. It is submitted that there will be inadequate
parking available for residents in the area who rely on on-street parking, as a consequence of
the development during the construction period, and the following operation of the
development.
Furthermore, there is no assessment of the capacity of the existing infrastructure to support
the potential traffic generated if the extent of development proposed in the master plan is
implemented, and no assessment of the impact on car parking in the area.
The proposed helipad and construction traffic are also likely to generate significant noise,
which will detract from the amenity of the area.
We submit that the proposed development should be refused permission on traffic and
transportation grounds and associated noise and environmental deterioration reasons.
5.0

Concluding Comment
Notwithstanding the Strategic Infrastructure Development status of the proposed development
and its importance to the future development of the City and the State, the proposed
development of the New Children's Hospital does not conform with the proper planning and
sustainable development of the area and should be refused permission.

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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 low-rise city and to provide for taller buildings in
the designated limited locations, it is considered that the proposed development would
exceed the defined height identified for Inner City locations, and would contravene
Dublin City Policy in this regard.
Having regard to the transitional zone area, to the height and scale of the proposed
development, its location in close proximity to residential properties adjoining the site
to the west, and by reason of overbearing aspect, excessive over1ooking, and visual
intrusion and that the development is an abrupt transition between the Z15 and
residential land use zoning (zone 1 and Zone 2, the development does not accord with
the policies and objectives of the Dublin City Development Plan).
Having regard to the height, scale, massing of the development it would be visually
intrusive in relation to the existing character and scale of the immediate local
streetscape along the South Circular Road, and Brookfield Road. The development
would seriously injure the amenities of the area and would therefore be contrary to the
proper planning and development of the area.
The proposed development will seriously injure the amenity of our client's property,
No. 49 Brookfield Road in particular through visual intrusion, over1ooking and
overshadowing as a consequence of the location, height, and uses proposed within
the Family Accommodation Unit opposite our clients dwelling.
The capacity of St. James Hospital to accommodate the children hospital and future
hospitals is marginal, and requires further 6 and 7 storey structures over basement
levels, without any notable enhancement of the public realm. which would suggest that
the site does not have sufficient capacity to accommodate the children's hospital or
future development of two additional hospitals.
The operational and construction impact of the development on traffic in the area will
seriously impact on the existing road network and car parking in the area, noise and
deterioration of the environment quality of the area and does not conform with proper
planning and development of the area.

In the event that An Bard Pleanala intend to grant permission, we request that the mitigation
measures presented in this submission are included in a condition attaching to the grant of
permission in order to protect the amenity of our clients property.

Issue 0028_October 1, 2015

49 Brookfield Road, Dublin 8

SHERIDAN WOODS

Our client would welcome an opportunity to present their concerns to the Board, in the event it
is intended to hold an oral hearing in respect of the proposed development, and requests an
opportunity to do so.
We trust An Bard Pleanala will take our submission into account.
Yours sincerely

U1A~t (.)-ItA._ )~VfiV\..

Charlotte Sheridan
Sheridan Woods
October 1, 2015
Encl
An Bord Pleanala Fee ESO.OO

AN BORD PLEANALA
TIME

BY______~

0 2 OCT 2015
LTROATEO

FkOM

----1

PL.

lssue002B_October 1, 2015

-15-

49 Brookfield Road, Dublin 8