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28 September 2015
Re:
Dublin 8.
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
childrens 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. Jamess
Hospital. The most recent buildings developed on this western side of the site,
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the St Jamess 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.
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 & Infants University Hospital would be more appropriate as
the location for the National Childrens Hospital.
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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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.
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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Fig 5: Photograph of Model showing impact on Brookfield and South Circular Roads
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.
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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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 Childrens Hospital on the site.
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 Childrens Hospital and St.
Jamess Adult Hospital A&E Department for emergency vehicles.
the road to get into the St Jamess Adult hospital at the moment. The
additional traffic generated by the National Childrens 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.
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.
Jamess 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 Childrens 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.
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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 Childrens 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 Childrens 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. Jamess 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.
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 Childrens 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
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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.
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 Plans objective.
Parking
As we know in this community, there is significant strain on the on-street
parking during visiting hours of St. Jamess Adult Hospital. The total visitor
parking being considered on the site for the St. Jamess Adult Hospital together
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with the National Childrens 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
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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.
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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.
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 Childrens 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
taxpayers 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 Childrens
Heart Surgery Unit in the National Childrens Hospital, while at the same time
ensuring a best in class hospital for the treatment of Adults at the St Jamess
Hospital Campus.
Yours sincerely,
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