pa0043 sub brookfield road residents association.pdf

7/24/2019 PA0043 SUB BROOKFIELD ROAD RESIDENTS ASSOCIATION.pdf

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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

Dear Sir,

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.

An

Bord Pleanilla has received your recent submission in relation to the above mentioned proposed development and will

take it into consideration in its determinationof 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 officesof 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

mentionedAn Bord Pleanala reference number in any correspondence or telephone contact with the Board.

Yours faithfully,

Encis.

ADHOC/PA0043/0 1

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ur

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

Dear Sir,

Re: Health Infrastructure Development comprising National Paediatric


James Hospital Campus, Satellite Centres at Tallaght

&

Connolly

Hospitals and Construction Compound at Davitt

Road,

Dublin.

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

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Our Ref: 29N.PA0043

P A Reg Ref:

Your Ref:

Chief

Executive Officer

Dublin City Council

Civic Offices

Wood Quay

Dublin 8

5th October 2015

Dear Sir/Madam,

Re: Health Infrastructure Development comprising National Paediatric


James Hospital Campus, Satellite Centres at Tallaght Connolly


An Bord Pleamila

Enclosed for your information

are

two copies of submissions received by the Board in relation to the above mentioned


Please ensure that a copy ofeach submission is available for public inspection at the officesof he 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 numberin any correspondence or telephone contactwith the Board.

Yours faithfully,

Encis.

ADHOC/PA0043/02

Sr;iltf

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ll:oilc Ach:o Cliach 1

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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

Dear Sir/Madam,

Re:



James' Hospital Campus, Satellite Centres at Tallaght Connolly

Hospitals and Construction Compound

at Davitt Road, Dublin.

An

Bard

Pleamila

Enclosed for your information are two copies of submissions received by the Board in relation to the above mentioned


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 correspondenceor telephone contact with the Board.

Yours faithfully,

an Somers

lcutive officer

Direct Line:01-8737107

Encls.

ADHOC/PA0043/ 2

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Our

Ref:

29N.PA0043

P.A.Reg.Ref:

Your Ref:

Chief

Executive Officer

South Dublin County Council

County Hall

Tallaght

Dublin

4

5th October 2015

Dear Sir/Madam,

Re:



James' Hospital Campus, Satellite Centres

at

Tallaght Connolly


Enclosed for your information are two copies

of

submissions received by the Board in relation to the above mentioned


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

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An Bord Pleanala

64 Marlborough St

Dublin 1

02

1

h October 2015

Re

The National Paediatric Hospital planning application

at

St.

James s Hospital

Case reference: PL29N.PA0043

Submission from:

u L ~ ,

I


LTR•DATEO FROM

lf\

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. 2

No. 28

No.

29

No. 35

No. 7

No.

4

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

Ivan Magee and Anita Magee

Daisy Cummins

Teresa Lawless

AN BORD

PLEANALA

Received: o2

f J

h

s

,

C

Receipt No:

13131

2 1

5



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,

1

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:

Issue

002_30 September 2015

• 2

1 0 August 2015

2 October 2015

29N.PA0043

AN

BORO PLEANALA

TIME BY

__,

0 2

OCT

2 \5

LTR·D TED

FIWM

PL




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

o

Development Plan Standards

4 2 1 Plot Ratio

4.2 2 Site Coverage

4.2.3 Building Height

4.3 Impact on Adjoining Residential Amenity

4.3.1 Overshadowing

4.3.2 Overlooking

4.4 Impact on Streetscape

4.5 Capacity

o

St James s Campus

4.6 Traffic and Transportation (Initial Draft Review)

4.7 Parking

5.0 Cost

6.0 Concluding Comment

AN BORD PLEANALA

TIME

BY

t

D OCT

2 15

LTR•D TIO FROM

~



Brookfield

Road

Residents' Associati

on

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 .

l

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

tr

ees

,

some

of which are mature specimens, they are located

both

along sections of the hospi

tal

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

4 0

4.1

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 replacementof he 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

~ 5 1 i r t Q

boundary

wall to Brookfield

Road

,

and the

development l i e W

u i r c f l n g ) i t \ e s t r ~ ~ ~ d g e

The

proposed

building

form

returns into the campus

formin

g

h e ' h ~ v r r i t r a n c e Q ~ S t .

James

Campus

. The

Family

Accommodation Unit extends

to the

r; ar ofelds.ting..dwellings-on-

Brookfield

Road

and Cameron Square. T

0 2 oc

J

Key Planning Issues . .

HO

¥

The relevant guiding planning document is the current Dubli a i \ ¥ . C , ~ e l ( l p m e n

2 -&t..,.

t '= -

2017

.

We

have reviewed

the proposed

development

in the of the Deve to

pmem

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 :

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 o he public and

Medical and related

consultantsn are permitted in

principle,

with

car park ancillary

to main

use

open for consideration. Education and Res idential 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 ind icate 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




development proposals in these contiguous transitional zone areas it is necessary to avoid

developments

which

would

be

detrimental

to

the amenities o he 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

o development proposals

and

to landscaping

and

screening

proposals

in

order

to

protect the amenities of residenti

al

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

o

these areas

and

is

contrary

to

the

development

plan

guidance,

which

is further outlined below.

4.2 Development in Excess o 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 .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 o

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

o 48,350 sqm.,

which

results

in a

plot ratio o

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

o the

distribution of the bulk of the buildi

ng

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 Accomm odation 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 I

TIME BY

-------

02O T 2 15

LTR

OATED

FROM

PL - f

5 .



Brookfield

Road

Residents Association

~

.

o " " i i : A ~ i . A \ t

t

.. . ..... -

\

;..

i :::

..

._u ~ ~ ~

- - - L . o . . , . ; . t · n

l l)

.I

· - • 1 ...

I

... . . . - - - ....- . ~ ~

~

_.,. • NewCIIIIdtens Hospe -

/

Slle Curtotage

Red

line r y lndudellnlemal Slla Area 37 ,656sqm

r o . ~ t a , and exlendl

beyond

111e

curU

Fa y

Accommod41oon

Unit

Blue line lndoc:ales applCI)IIale slle boundatlea Site

CL.011lage

for lhe purposes of

c:alcl olatinO plol ratio and Slle Area 23A8aqm

olte coverage lor elldlM118rtle

land parcel

LTR·OAT 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 87 6n sqm

Plot Ratio

2.3

New Children s Hospital

-With

Extensions within the New

Children s Hospital Site

Total area of development proposed above ground

8

,677 sqm

Total area of extensions above ground (Children s Meadow site

and

20,000 sqm

over the emergency site only)

Total Area 107,677

sqm

PlotRatio 2.9

Family Accommodation

Site area

within

the u r t ~ a g e of Family Accommodation Site

2348

sqm

Total

area

development proposed above ground Family 4024 sqm

Accommodation

Plot Ratio 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

overdevelopment thereby safeguarding sunlight and daylight

within

or

adjoining

a

proposed layout

of

buildings.

Site

coverage

is

the

percentage

of he

site covered by

building structures, excluding

the

public

roads

and footpaths.

-6 -



4.2.3

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

Site

Coverage

a•t

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

sqm

Meadow site and over the emergency site only)

(15,000 In buildings ranging from 4 to 6 floor (pg 29 draft capacity

3000

sqm

study) say average 5 floors @ 3000sqm ground floor

(5,000 sqm 3-storey building from Level 02 upwards@ 1666sqm

1666

Total Area

23047 sqm

Site Coverage

61

Family

AccommodaUon

Site area within the curtilage

of

Family Accommodation Site

2348

sqm

Total ground coverof Family Accommodation

1388

sqm

Site Coverage 59

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 oft f\e proposed

development in a 'transitional zone' this scale of development is contrary to the development

plan

standards. •

· 0 2

OC

._.l

Building Height t\

OM

The development plan indicates that the maximum height standards

~ ' R & J t l & f "

l

_

shall have precedence over the indicative Site Coverage. Notwithst . ~ the c

trlte

ntio ,

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 o clarity, plant

rooms

are included in

the

height definition. Also

that: 'No

height greater

th n

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

· ·



Brookfield

Road


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 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

i

ndicated

f

t

lnred

{

;

·.

- - - - -

J ~ e O T

l\ llJ

Figure Zlllustrates alignment and position

of

previously permitted Co-located Hospi I,

ROM_

Including tower block and podium block LlR OAlED

Source: Extract From New Children s Hospital Planning Application Drawing BOP O C o n n e l ; : ; ; ; : : : : ; ; ; ; : = : ; : : : : : ; : : : : ; : ; ;

Architects Level 00; Annotated y 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

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


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 impactof 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 r e s i ~ i } L ·i '- '

J

development are

set

out

in

the table here '

\

FIWM

' r'\A f1:n

LocatJon Opposing Use

Distance

r e v i o ~

~ l y ·pennittea-

Setbaci

f

RIIn

exi•tlnn

build n

Ia.

12. mlrom

boundary

to plinth,

and lnlm bculdary to

toweretemem)

South Circu lar Road

32.5m

JunctJonwith

Setback

from

front

Mountshannon

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)

to 'South Fingers' Outpatient

Gnd)

25m (for 3 floors)

Wards (Level 1)

Day care (Level 2)

to

Floating

Garden

Therapies (Level

3)

25m

to

garden

45m to accommodation

to Pavilion Ward Wards

62m

(for 3 floors)



Brookfield

Road


South Circu lar Road

I NIA

Junction with

Brookfield Road

to South Fingers Outpatient

Gnd)

21.9m (for 3 floors)

Wards (Level1)

Day care (Level 2)

to Floating Garden Corporate Services I 38m

offices

to

edge of Floating Open Space

21.9m

Garden

to Pavilion Ward 49 .4m

Brookfield Road

to Family Board Room Gnd)

14.1m (Street

width

Accommodation Bedrooms & Communal Including front gardens)

Kitchen

(Level1 &2)

Oblique bedrooms &

Stair (Level 3)

Rear of Brookfteld Road Bedrooms I Communal 33

.

5m

to Family kitchen

I

Stairwell

Accommodation (Level1)

Bedrooms & Sta irwell

level2)

Cameron Square

NIA

to gable of

Family Ground

Floor 18.6m

' ··

f

Accommodation

First Floor 22m (

to

main wall

of

U

Ul

1

'- ' .J

house)

Second Floor

27.6m

LTR·DATED

F OM

to 'North Fingers

25.7m

PL

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 .

·

10-



Brookfield Road


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

l

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.

UCl .. J

J

LTR OATED ROM

'

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 ofproposed

approach

to Brookfield

Road

• 11 -



Brookfield

Road


• 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 o 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 .

[

n•

2O T

~ l s ~

LTR·D TiD FftOM

~ ~

12



Brookfield

Road


Photo taken from presentation boards at F2 meetings

This is a photomontage is looking east down Brookfield Street.

with

end

of terrace o Brookfield

Road in

the distance, with proposed the family

accommodation unit

r Elevation

8oultl

\ D

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 .

1

,

.

0 2

O l

' Uil

L T R O A ~ D FI'OM '

---

l.

- 13 -



Brookfield

Road


. -.-

.......=

\

t

•

02

OCT

lR

·

D TEO

ROM

...

. . . . cmonol Pced10trlc Hospital Project ·local Regeneration Opportunities

= : : : : : :

Figure 3 Extract From Urban Initiatives Study

Source:

Appendix 5:2 of

the

EIS

National

Paediatric Hospi tal- loca l

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 impacto 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 o 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 o site coverage and no three dimensional

analysis.

• 14



Brookfield

Road


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 o 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.

~ ~

(

·····

_.

· · · · · · ~ ~ : ••

.•

•• J« t

Figure 4 Extract from Draft Site Capacity Study

, ... L -

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

o

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. he mitigation proposals included

as

part

of

he 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.

·



Brookfield

Road


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 Concluding Comment

2o t t U\

Notwithstanding the Strategic Infrastructure Development status o

and its importance to the future development of the City and the ; ; ; ; ;

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 Assoc iation

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

condu

it 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


would

welcome

the

opportunity to present their

concerns to the board, i t 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

2O T t.\ IJ

e,o

fRo

L T R · ~ T ~

P

pa0043 sub brookfield road residents association.pdf

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