pa0043 sub gordon smyth.pdf

7/24/2019 PA0043 Sub Gordon Smyth.pdf

1/16

Our Ref: 29N.PA0043

P.A.Reg.Ref:

Your

Ref: Gordon Smyth

Charlotte Sheridan

Sheridan Woods Architects.

10 Adelaide Road,

Dublin 2.

9th October 2015

Dear Madam,

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 Pleanala

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

cop

ies of all submissions observations received in relation to the application will be made

available for public inspection at the offices ofDublin City Council, Fingal County Council and South Dublin County

Council and at the offices ofAn Bord Pleanata when they have been processed by the Board.

f you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above

mentioned n Bord Pleamila reference number in any correspondence or telephone contact with the Board.

Yours faithfully,

Executive Officer

Direct Line:Ol-8737107

Encls.

ADHOC/P

A0043

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2/16

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,

Dubl in 15 (Up To 5,093 Sq.M. Gross Floor Area).

An Bord Pleanala Reg Ref 29N.PA0043

AN BORD PLEANALA

Received

:

o

z l

o/ 1?:

Fee: f so oo

Receipt No

:

6

I

l 2 o :1-

Prepared On Behalf Of

Mr.

Gordon

Smyth

49

Brookfield Road

Kilman ham

Dublin

8

Prepared By

AN BORD

P L E ~ L

TIME \

BY

- - - ~

0 2

OCT

2 15

LlRD TED FROM 1

PL

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

Issue

0028_01 October 2015

Chorlolle

II

RISH

PUNNING

INSTITUTE

10 August 2015

2 October 2015

29N.PA0043

Kevin Woods, SWAUP Architect

and

Ult>an OeslgnM, 0 pArch BArch Sc MSc: Urban Design MRI I

T/A ShDifdan Woods Atc:h lecb + Urban Planners Ltd Registered In

Ireland

Reg

Na.

3752.5.4 VAT


3/16

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 ncludes 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. Y

___

t

0 2

OCT

2 15

LTR

D TID FNOM

t

Issue 002B_October 1, 2015

2

. . .

ad, Oublin


4/16

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 o he 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 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 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

o 48,350

sqm

., which results in 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 - 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

e calculated for the distinctive development

parcels independently including the Family

Accom

s ospital.

To illustrate this we have indicated the configurati n of B Q f i t B e

Family Accommodation

site,

and the

new

Childre t ~ i t a l site ~

and

consequent plot

ratios as

follows:

Issue 0028_October 1, 2015

0 2 O T 2 15

LTR DAtf.D

P

Dublin 8


5/16

SHERIDAN WOODS

ROPLEANALA

NewCNidt1 ns Haspital

Sde Cullilage

TIME ev .,.

Blue

-lndlcaleiiiAlfQpriate baUnCierln

IQr

e purposes a1 calculating plot ratio and

. . . .

coo;erage

lor

Ndl eepnte land

pan:el

y

SiteAn a 37

556sqm

. FllmllyAo:arnmodlbanU *

S ~ e C u n u g e

bAn 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,

2 15

New Children's Hospital

As

Proposed

Site area within

the

curtilage or

the

site New Children's Hospital Site

37556 sqm

Total

area development

proposed above

ground

NCH

67677

sqm

Plot Ratio 2.3

New Children's

Hospital-

With Extensions within the New

Children's Hospital Site

Total area of

deveiO(l llent_RfopC)Sed

above ground 67677

SQm

Total

area of extensions

above

ground (Children's Meadow site and

2 000

sqm

over

the emeraencv

site onlvl

Total Area 1o1. n

_sqm

Plot Ratio

2.9


Site

area within the curtilage of Family Accommodation Site 2346

~

Total area development proposed

above ground Family 4024 sqm

Accommodation

Plot Ratio

1.7

2 O T

2 15

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 ofbuildings. Site coverage is the percentage of he site covered y

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:

b s u e 0 0 2 B _ ~ o b e r 1 2 0 1 5

4 49

Brookfield Road, OubHn 6


6/16

SHERIDAN WOODS

New Children s

H o ~ p i t a l

- sPro.stosed

Site area within the curtilage of the slte New Childrens Hospital Site

37 ,556 ~

-

otal ground floor of the NCH

Site

Coveraae

18,381 r:::.A .. ALA

~ onQt l P L ~

r

~ ~ i l l d . ~ 5 H l ~ ~ ~ ~ ~ m s . O M ~ ~ n ; ~

w - - - - - r - - -

1 r ~

-

~ ~

~

New

Children s Hospital- With Extensions

within the

New 1 \

M-.;t-

Children s Hospital

Site 1Q4C.

~ T = ~

~ l ~ g t r ~ o u ~ n ~ d ~ o ~ v ~ e r ~ n ~ o o ~ r ~ o ~ f t ~ h e

N ~ ~ H

~ - - - - - - - - - - - - - - - - - - ; - - -

~ ~

- - - -

~

~

\ l

Q C 1

L

'a

Total area

of

ground cover of extensions (incl Under Croft) (Childrens

Meadow site and over the emergency site only)

sqm f O'-'_____

D -

--. ,_.

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

Pl

Total Area

23047 ~

Site Coverage

61%

Family

Accommodation

Site area within the curtilage or Family Accommodation Site 2348

~

Total ground cover or Family Accommodation 1388

~

Site Coveraae

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


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 ind

i

cates

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 o

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 of28m 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

-


7/16

SHERIDAN WOODS

2

O T 2 t5

~ R O M

. .

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 o he proposed New

Children s Hospital comprised an eight storey block with roof level at 52 .96 AOD Malin Head

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 Impacton 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 o overdevelopment

generates adverse overshadowing, overtooking of adjoining residential

areas.

Issue

0028_October 1, 2015 49

Brookfield Road

,

Du

b

lin

8


8/16

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, ambi

ance and

amenity of the streets,

and

a reduction

in

the sunlight currently enjoyed by the residents

of

he

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

Opposi

ng

Use Distance Previously pennmed

Setback from existing

buHdlngs

1 2. mhan boundary to

p

linth.

and 40m han boundary

ID

elomenl l

South Circular

Road

32.

6m

Junction with Setback from front

wal

l

Mountshannon 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)

to 'South Fingers' Outpatient (Gnd)

25m

(for 3 noors)

Wards (leve l 1)

Davcare (Level 2l

to Floating Garden Therapies (level 3)

25m

to garden

45m

to accommodation

to

Pavilion Ward Wards

62m

(for 3 noors)

South Circular Road

NIA

Junction with

Brookfield Road

to South Fingers Outpatient (Gnd) 21 .

9m

(for 3 noors)

'

Wards (level

1)

AN BORD

aycare

(Level 21

~

...

L

~ L

to Floating Garden Corporate Services 38m

TIME

_

j

offiCes

to edge of Floating Open Space 21 .9m

0 2 01

.

T 2 15

arden

to Pavilion Ward 49.4m

D

na.Ta n

PROM

Brookfield Road

Pl

.

to Family

Board Room

(Gnd) 14.1m (Street width

-

Accommodation Bedrooms Communal Including front gardens)

Kitchen

(Level1 2)

Oblique bedrooms

Stalr(level

3)

Rear of Brookfield

Road

Bedrooms

Communal

33 .5m

to

Family kitchen Stairwell

Accommodation

Level

1)

Bedrooms Sta irwell

Level

2)

Issue 002B_October 1, 2015 7 49 Brookfield Road, Dublin 8


9/16

SHERIDAN WOODS

Cameron Square NIA

to gable of Family

Ground Floor .6m

Accommodation

First Floor

22m

( to main wall of

house

Second

Floor Z76m

to North Flnaers 25.

7m

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.

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lssue002B_October 1, 2015 8 49 Brooldleld Road, Dublin 8


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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 ~ d e 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

d

we

lling. Bedrooms are p

roposed

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

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

SHERIDAN

WOODS

.

.

: : \ I I I I I J I I . I O c l

:

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

TIME av t

02OCT

2 15

LTROAT D

PRO

__

Source:

ChUd

ren's Hospital Planning

Application Drawing BOP O'Connell Mahon Architects

Level

00; Cropped by Sheridan Woods,

20

15

Facades Facing The Rear of No.

49

Brookfield Road

49

Brookfield Road, Dublin 8


11/16

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.

' -

Source: Extract From

EIS

Chapter 13

Figures

13

Shadow Plans

show

the

Proposed

shadow

plans

for

eac:h

hour

on 21st March September

from

8 OOam

shadow

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.

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

r..,.

11

1

PciW

r .. Ro td .. ... ew11 twJng . . .

I CGIII

Ml llfDW

w nDUar

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

t - ~ J L ~ 7 ~ :

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tf 1UJ. ~ l l I I.- ]

J r - In1. . ~ ~ t : 1 C::u j.... c9

....... I

=

I ..::... I - =- I I := I

Source; Extract

From

EIS Chapter 13 Figure 13.17

Illustrating

Impact

of

Fam

ily Ac:c:ommodatlon Unit

On the sky component

AN BORD PLEANALA

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49 Brookfield Road, Dublin B


12/16

4 6

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

he

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 t 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:

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 he

area.

The existing South Circular Road Brookfield

Road

and Cameron Square

area

all benefit from

a strong sense of place

and

identity.

AN BORD

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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.

AN

~ O R D

P

TIME '

t SY

f c

LA

LTROATEO

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National Paediatric Hospital Project

local

e g ~ n e r a t i o n

Opponun

es

_ 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 he 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 his 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

00

2B_October 1,

2015

49 Brookfield Road, Dublin 8


14/16

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

he

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.

.....

Figure 4

Extract From

Draft SHe Capacity

Study

:

AN BORD PLEANALA

0 2

OCT 2 15

LTRDATEC FROM

PL

.

. 1-. ....

r

r

:

-:

.

. I

: :

.

.

.

.

.

.. ._

_

Source: Extract From St. James Campus Site Capacity Study BOP OConnell 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 he Transport strategy

for

the St amess 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

3

49 Brookfield Road , Dublin 8


15/16

=s

2

iJ >

rm

I)

< E

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

r

_

c..J

0

N

c::.

g

)

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.

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

I

-

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


16/16

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

U 1 A ~ t .)-ItA._ ~ V f i V \ . .

Charlotte Sheridan

Sheridan Woods

October 1 2015

Encl

An Bord Pleanala Fee

ESO OO

lssue002B_October 1 2015 15

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