Our Ref: 29N.PA0043 P.A.Reg.Ref:

Your Ref:

Neil Donnellan and Caroline Leaden and Others 34 Mountshannon Road Kilmainbam Dublin 8

9th October 2015

Dear Sir/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 Pleam1ln

An Bord Pleanala has received your recent submission in relation to the above mentioned proposed development and will take it into consideration in its determination of the matter. A receipt for the fee lodged is enclosed.

The Board will revert to you in due course with regard to the matter.

Please be advised that copies of all submissions I observations received in relation to the application will be made available for public inspection at the offices of Dublin City Council, Fingal County Council and South Dublin County Council and at the offices of An Bord Pleanala when they have been processed by the Board.

If you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above mentioned An Bord Pleanala reference number in any correspondence or telephone contact with the Board.

Yours faithfully,

KJ ran Somers Executive Officer Direct Line:Ol-8737107

Encls.

ADHOC/PA0043/0l

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34 Mountshannon Road

The Secretary An Bord Pleanala 64 Marlborough Street Dublin 1

tst October 2015

·.

Kilmainham Dublin 8 Ireland

ANBORDPLEA TIME I ( ·, :>'b BY

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Re: Submission to An Bord Pleanala in opposition to an Application for Permission to construct a New Children's Hospital on St. James's Hospital Campus (An Bord Pleanala Reference Number: PL29N.PA0043)

Dear Sir/Madam,

We are opposed to the Application to locate the proposed new Children's Hospital on the St. James's Hospital Campus. We enclose herewith a document in support of our opposition together with the prescribed fee (€50.00). We would request that an oral hearing be held in which not only our views but the views of many of those who will be potentially impacted by this proposed development can be fairly presented.

A number of residents of the surrounding streets who are also opposed to the proposed development have indicated their support for this submission, and have requested that we append their names. The names and addresses ofthese residents are listed in Appendix B of the enclosed document.

We trust that the forgoing request will receive favourable consideration.

Yours faithfully,

Caroline Leaden

L Received: .... 0=~¥-"-1 ~o~o.w.­Fee: G';)Q c.cO,rl Receipt No: !R9.0 2,Q::l

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Submission to An Bord Pleanala

in Opposition to an

Application for Permission

to Construct a

New Children's Hospital

on the

St. lames's Hospital Campus

I

AN BORD PLEANALA TIME_ BY _____ __,

0 2 OCT 2015 LTR·DATED FROM

PL_ -- ---1 Prepared by:

Neil Donnellan and Caroline Leaden 34, Mountshannon Road

Kilmainham Dublin 8

1st October 2015

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Submission to An Bord Pleanala in opposition to an Application for Permission to construct a New Children's Hospital on

St. James's Hospital Campus (An Bord Pleanala Reference Number: PL29N.PA0043)

1.0 INTRODUCTION

It is our view that the proposed location for the New Children's Hospital within St. lames's Hospital Campus, a congested inner city site, is unsuitable for the following reasons:

• Limited space for future expansion for both the NCH and St. lames's Adult Hospital.

• Access difficulties for parents coming with their children from outside Dublin.

• Lack of adequate parking for visitors and staff, due to the confined size of the site.

• Space constraints in providing a co-located Maternity Hospital in the future.

• The adverse impacts of the proposed NCH on the local community, including increased traffic congestion both during construction and when operational.

As residents of the streets adjacent to St lames's Hospital Campus we intend, in this submission, to focus on traffic and parking impacts.

We believe that other interested groups will make submissions on other aspects of the proposed development, including the physical impacts of the building.

We believe that there are alternative locations which would better serve the requirements of the New Children's Hospital i.e. Tallaght or Connolly, and that these locations should be reconsidered. For example, one of the principal reasons for the selection of St. lames's Hospital Campus is proximity of public transport, but this is also true of Tallaght, which is served by the same Luas line, and has the added benefit of being close to the MSO motorway. One of the principal reasons cited against the selection of Tallaght in Chapter 4 of the EIS­Examination of Alternatives is:

'Tn terms of environmental impact the new children s hospital site on Tallaght Hospital is proximate to an apartment complex raising issues in relation to impact on human beings and residential amenity. "

This impact is also true for St. lames's, where ~e dM~~Q,~Wi(~b'e\LA "proximate" to residential streets. TIME BY ___ --1

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1.1 Main Points of the Submission

• The EIS identifies that there is existing traffic congestion in the area. • The EIS identifies that there will be a considerable increase in traffic both

during construction and when the proposed New Children's Hospital is operational.

• The mitigation factors proposed are: The reduction of staff parking on the Hospital Campus, and the claim that this will reduce traffic impact. A Mobility Management Plan will encourage staff and visitors to use public transport/cycle/walk, in line with the National Transport Strategy, and the claim that this will reduce traffic impact.

• We do not accept the validity of these mitigation factors. • There will considerable adverse impact on both traffic and parking in

adjacent residential areas. • The feasibility and impact of the proposed future Maternity Hospital has

not been adequately considered.

Photographs of existing traffic congestion are attached in Appendix A.

The names and address of residents who support this submission are listed in Appendix B.

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2.0 EXISTING TRAFFIC CONGESTION

The EIS traffic surveys carried out in May and October 2014 identified existing traffic congestion in the area adjacent to St. James's Hospital campus. The surveys do not state the prevailing weather conditions, however the likelihood of poor weather conditions from November to March could lead to traffic movements in excess of those recorded in the surveys.

We have taken particular note of traffic around the Rialto Entrance. Traffic congestion has also been identified also at the St. James's Street Entrance.

Chapter 9 of the EIS notes the existing congestion (Page 6-20):

"South Circular Road (R811}, is designated part of the Dublin City Centre 'Outer Orbital Route; and provides one of the primary access routes around the western edge of the city centre for traffic movement In the vicinity of the StJames's Hospital campus the street is a two lane roadway and supports on-street parking between Brookfield Road and Suir Road. The street supports high traffic volumes particularly during the peak hour periods. During the morning peak period, traffic conditions are relatively slow moving in both directions along South Circular Road, with queues and delays experienced at the various traffic signals located on the South Circular Road in Kilmainham, including the recently upgraded Rialto Roundabout During the evening peak period traffic conditions travelling westbound towards Kilmainham and northbound towards Con Colbert Road are also generally very slow with queues extending back through the various junctions located along this route."

And

"South Circular Road remains busy during the evening peak period, with traffic flows in the region of 1,200 to 1,500 vehicles per hour noted on the section of South Circular Road between Mount Brown and Con Colbert Road. The recorded traffic flows on South Circular Road between Rialto Roundabout and Mount Brown was recorded at between BOO and 1,300 vehicles per hour. During the evening peak period, traffic conditions on the surrounding street network can be very busy with congestion evident exiting StJames's Hospital and along South Circular Road travelling towards Con Colbert Road. Generally, traffic conditions are better through Rialto although some slow moving queues are noted on approach to the upgraded Rialto Roundabout .. "

And

"The existing Rialto entrance is located approximately 30 metres from the signal/sed junction of South Circular Road and Brookfield Road. During the morning peak period some queuing is evident approaching this signal/sed junction before accessing the Rialto entrance to the Hospital. During the evening peak period the extent of queuing exite1· pitaLis.mor.e.. pronounced with vehicles queuing within the campus waiti tcMXiB 'l£/Btb 'iifr.thistqueuitJg associated with standing queues on the South Circular Roa "'RfRi!icular!y on qpproach to th junction of Suir Road/ South Circular Road. "

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Local residents in the area will not need to refer to these surveys to be aware of the existing traffic congestion.

Traffic on the South Circular Road from Rialto through to Buffin Road and beyond is frequently at a virtual standstill between 15.00 to 19.00 pm. On occasions, the traffic can back up as far as Dolphin's Barn. It not unusual for traffic to take up to 15 minutes to travel the very short distance from the Rialto Roundabout to the Mayfield Road or Madison Road junctions with the South Circular Road. The No. 123 bus exiting from the Rialto Entrance onto the South Circular Road frequently has to wait for several changes of the traffic lights before it can make the turn at the junction. At times it is forced to take an alternative route towards Rialto, resulting in a lack of service for passengers wishing to alight or board along sections of the South Circular Road.

Refer to reference photographs of traffic congestion in Appendix A.

The EIS traffic study has also measured the existing travel times between the MSO and St. James's Hospital during peak periods.

The survey showed that journey times to the St James's Hospital campus were up to 22 minutes via the N4 interchange and up to 24 minutes via the N7 interchange during the morning peak period.

On the return journey to the MSO the journey time between the StJames's Hospital campus and the N4 Interchange via the Chapelizod Bypass was between 30 and 40 minutes with delays experienced on both South Circular Road and the Chapelizod Bypass exiting the city. The journey times between the StJames's Hospital campus and the N7 Interchange were noted to be between 15 and 20 minutes.

This congestion is due to general traffic volumes leaving town, heading towards the N7 and N4, and is not necessarily directly associated with the Hospital.

We submit that due to the existing traffic congestion around the St. James's Hospital campus that this not a suitable location for a development of the size of the proposed New Children's Hospital, together with the future proposal of a New Maternity Hospital, and any future expansion of the main Adult Hospital.

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3.0 TRAFFIC IMPACTS OF PROPOSED NCH

It is noted that the significance criteria used for the rating of the severity, quality and duration of impacts as set out in the EPA 'Guidelines on the information to be contained in Environmental Impact Statements', 2002, (Section 5 Glossary of Impacts), and widely used in the preparation of Environmental Impact Statements, have not been used in the preparation of Chapter 6 of the current EIS. The impact ratings set out in the above document are as follows:

Severity of Impacts

Imperceptible Impact: An impact capable of measurement but without noticeable consequences.

Slight Impact: An impact which causes noticeable changes in the character of the environment without affecting its sensitivities.

Moderate Impact: An impact that alters the character of the environment in a manner that is consistent with existing and emerging trends.

Significant Impact: An impact which, by its character, magnitude, duration or intensity alters a sensitive aspect of the environment.

Profound Impact: An impact which obliterates sensitive characteristics.

Quality of Impacts

Positive: A change which improves the quality of the environment.

Neutral: A change which does not affect the quality of the environment.

Negative: A change which reduces the quality of the environment.

Duration of Impacts --.!\l\1 BOR~~..._"'-;--__ TIME D PI_£:~ I \lA LA

----8~ Temporary: Impact lasting one year or less

Short-term: Impact lasting one to seven years o 2 ocr 2ots LTR·DATED

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Long-term: Impact lasting fifteen to sixty years

We believe that, for clarity, a rating system should have been utilised to enable all parties to j udge the severity of the various impacts.

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3.1 TRAFFIC IMPACT DURING CONSTRUCTION

Chapter 6 of the EIS predicts the amount of traffic generated during the 3 phases of construction.

Phase 1- Enabling Works (alteration of drains and services, etc.) Duration 6 months The EIS predicts that there will be 260 Heavy Goods Vehicle (HGV) and 200 Light Goods Vehicle (LGV) movements per day. The calculations in the Traffic Report use a multiplier of 2.3 passenger car units (pcu's) per HGV. This results in the equivalent of a total of 798 car unit movements per day.

Phase 2- Basement Works and Superstructure (including associated excavation, etc.) Duration 18 months The EIS predicts that there will be 490 Heavy Goods Vehicle (HGV) and 200 Light Goods Vehicle (LGV) movements per day. This results in the equivalent of a total of 1327 car unit movements per day.

Phase 3 - Main Construction Duration approx 2 years The EIS predicts that there will be 370 Heavy Goods Vehicle (HGV) and 200 Light Goods Vehicle (LGV) movements per day. This results in the equivalent of a total of 1051 car unit movements per day.

The predicted distribution of construction traffic is 30% using the Mount Brown entrance and 70% using the Rialto entrance. This will result in the following Projected Traffic Flows daily for the Rialto Entrance: Phase 1 Construction traffic: 559 Total traffic flow: 6918 Phase 2 Construction traffic: 929

Construction traffic: 946 Total traffic flow: 7288 AN BOR Total traffic flow: 7305 TIME D PLtANAI A Phase 3

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The EIS also states in Chapter 6 Page 6-108: o 2 ocr 20t5 LTR·DATeo

"Construdion Management: I PL ---FRoM As noted previously no parking on site is proposed for constructio~~ -starr ... activity will generate some traffic movements at the construction site relate~ staff drop-off, possible shuttle bus movements etc ... , and it is envisaged that during the~fi.~7rs~~ phase of the project that up to 100 vehicles a day will be generated by construction staff at the construction site. "

In mitigation, it is stated in chapter 6 of the EIS that approximately 600 staff car parking spaces will be removed from the campus during construction and that therefore the traffic impact of construction vehicles will not be significant, as the author's attempt to demonstrate that there will only be 189 extra car units. "The increase in traffic associated with the construction activities is offset by the projected reduction in traffic associated with the removal of approximately 600 parking spaces from

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the StJames's Hospital campus during the construction phase of the project There wl'll be little impact on preval'ling traffic conditions on the surrounding street network, however

there will be an increase in the number of Heavy Goods Vehi'cles on the surrounding street network durlng the construction phase of the project"(Chapter 6- 6.1.7.1)

We do not accept that the conversion of 2.3 passenger car units per 1 HGV is valid. This may equate to the relative lengths of the vehicles, but we submit that the impact of 1 HGV is greater than 2.3 cars, due to bulk, manoeuvrability and time taken to pass through junctions, and delays resulting from the inability of HGVs to pass each other on narrow streets.

It is not realistic to assume that the approximately 600 staff that will have nowhere to park on campus will simply disappear. They will still be using the traffic network in the vicinity to seek alternative parking, and they cannot be subtracted from the equation.

In light of the considerable amount of construction traffic identified in the EIS we do not accept the statement that there will be ''little impact on prevailing traffic conditions'~ This statement immediately contradicts itself by stating that "there will be an increase in the number of Heavy Goods Vehicles on the surrounding street network'~

A contractor's compound is proposed for Davitt Road, approx. 1.6km from the site of the proposed NCH. All construction vehicles will be travelling between the compound and St. James's campus.

There is a stated assumption in Chapter 6 of the EIS that only 20% of construction vehicle movements will take place during peak hours. This will this be difficult, if not impossible to enforce, even if it is made a condition of any grant of permission.

3.1.1 Mitigation Measures Proposed by the Authors of the EIS

The mitigation measures proposed to manage the additional traffic during the Construction Stage consist of a Construction Traffic Management Plan, as follows:

"The Implementation of a Construction Traffic Management Plan (Chapter~ 6.1.6.1}

A detailed Construction Traffic Management Plan, which will incorporate the relevant traffic management measures included for in the Construction Methodology Report will be finalised for the construction stage of the project This plan will include for the following measures:

· The prohibition of construction staff parking within the campus to mitigate the potential traffic impact during the construction phase of the project.

· No queuing of trucks will be permitted on either the surrounding street network or the internal roadway within the hospital campus;

AN BORD PLEANALA I • The provision of a construction compound at the former Vi . i/elfffE. Site at Dav~Road to allow for the storage of materials. The Davitt Road construct. pn compound will alsv fadHf:tJLr;;; the staging of construction traffic and allow for their orderly ~rrival onf$it.e.Q1J1fs 'fd(6ensure

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that construction vehicles do not need to wait on the public street network near the St James's Hospital campus to access the construction site.

• The provision of a temporary internal access road to facilitate the construction of the new children's hospital maintaining access to StJames's Hospital from South Circular Road for the entire duration of the construction project.

• The management and marshalling of construction vehicles on the public road within the hospital campus by flag men;

• The Contractor will be required to implement a Mobility Management Plan for its staff and co-ordinate with the StJames's Hospital Campus Mobility Manager during the course of the construction project."

The EIS also states, in further mitigation:

Page 6-103: " ... no staff parking for construction workers will be provided within the St James's Hospital campus, with the Contractor required to manage staff movements to and from the site without impacting on the local community"

And

Page 6- 108 " .. The construction site is very accesstble by alternative modes and construction staff will be encouraged to access the site by such modes~~

Our comments on the above:

The estimated number of construction staff required on site daily will be 900-1000. Although

there will be no construction staff car parking permitted within the campus, there will be considerable traffic impact in the area as a proportion of construction staff use the traffic

network in the area to seek parking.

We submit that the foregoing mitigation measures are unenforceable, as they are not within the control of the authors of the EIS, and therefore they should not be taken into account.

For example, it is stated that queuing of trucks will not be permitted on the surrounding street network. It is not realistic to assume that this can be ensured at all times. During concrete pours there will be a requirement for continuous deliveries by concrete trucks to the site, and staged delivery will not be feasible. In any case, staging of deliveries will not reduce the level of construction traffic, and should not aken into account as an additional mitigation measure.

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The following generic and anodyne statement in the Outline Construction Management Plan re ''good relations"is of no value to residents and general road users who will be affected by construction traffic, and should not be taken into account as mitigation.

Public Relations/Community Liaison 3.3.1.2 "The Project Team recognises the importance of the community liaison role in ensuring the smooth running of activities and in relation to residents and public welfare. Important key issues in ensuring good relations are: • Regular community meetings/leaflet drops/information briefings etc.; • Correct points of contact, information and liaison; • Responsiveness to contacts and information; • Good housekeeping in all aspects of the operations. "

Similarly, residents and road users will take no comfort in the statement in Chapter 6, where, having listed the considerable number of additional traffic movements, an attempt is made to justify the impact of construction traffic, by implying that things can only get worse: ''In addition the volume of traffic generated during Phase 1 of the construction works is less than projected during the operational phase of the new children's hospital and the impact during construction phase will be less than that presented during the operational phase" (Chapter 6 Page 6-109)

This statement is repeated for Phase 2 and Phase 3.

3.1.2 Working Hours and Enforcement of Construction Management Plan

The Outline Construction Management Plan states the proposed hours of work are:

"• Monday to Friday - 7. OOam to 7.00pm • Saturday- B.OOam to 2.00pm • Sundays and Bank holidays -Any construction activity, with the exception of emergency

works, will be limited to B. OOam to 2. OOpm and will require the explicit permission of the relevant local authority. We note that certain activities may be required, subject to prior agreement with Dublin City Council, to be undertaken outside of these working hours. It is acknowledged that special events, such as large concrete pours, will require (in addition to the prior agreement with Dublin Gty Councilj liaison with the Local Authority, Garda, Local Community, key Stakeholders and St James's Hospital Management, together with extensive pre-planning and programme management of site operations. "

We regard the foregoing paragraph quoted from the Outline Construction Management Plan in particular the reference to liaison with the Local Community as aosol'ute·nonse, se as we can see no method by which this could be achieved. Also, why wcluJdvit be~~f!~~satfVcto NA-LA

1 11 tt: ,., carry out large concrete pours lasting beyond the normal daily working hmu:sz..__ av

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We submit that 8.00am starts at weekends are not acceptable in a residential area, and further submit that Sunday working should be ruled out completely. With regard to the enforcement of Construction Management Plans in general, it is relevant to consider the experience of the residents of the North Quays area of the city during the construction of recent major developments. During a presentation at the oral hearing for the Dart Underground Project, the residents' group produced evidence that included dated and timed videos of the construction activity on previous projects, taking place throughout the night, with noise and bright lights clearly evident. This out-of-hours activity continued despite conditions contained in the Permission, and despite a 24-hour residents' helpline to the Contractor and Dublin City Council which had been established in a "Construction Management Plan" specifically to deal with such transgressions. The residents were unable to achieve any satisfactory outcome.

This experience is likely to be repeated during the construction stage of the proposed National Children's Hospital.

It not clear how this would be dealt with in the proposed NCH construction phase, particularly if the construction team choose to ignore the conditions and strategy contained in the application documentation

3.1.3 Summary

We submit that there will be an unacceptable impact from construction traffic, in excess of that stated in the EIS, on the surrounding area for the 4 years of the proposed project.

The construction of a development of this size on a congested city centre site, surrounded by residential streets will have a detrimental impact on both local residents and all road users of the adjacent road network.

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3.2 TRAFFIC IMPACT WHEN NCH IS OPERATIONAL

The predicted additional traffic generated when the proposed NCH is operational has been assessed in the EIS in Tables 6.54-6.58.

The traffic generation figures are based on the following: (Chapter 6 Page 6-124) Inpatients: 380 beds Day care: 93 beds Out patients: Annual outpatient appointments: Annual non-consultant clinics: Annual urgent care cases:

197,400 98,800 72,238

There will be 1131 car parking spaces provided to cater for the above.

The predicted change in traffic generation associated with the visitor car park is 4410 extra movements per day.

The total predicted change in traffic generation, taking into account a reduction of 244 in staff parking spaces is 3444 extra movements per day. Between the hours of 16.00 and 19.00 the projected traffic generation from NCH will be 486 extra cars. In the previous hour, from 15.00 to 16.00, the prediction is for 347 extra cars.

The EIS admits: "Following the construction of the new children's hospital, it is acknowledged that the surrounding street network will continue to experience traffic queues and delays at peak periods on a typical week day. "

This level of additional traffic will have a serious affect on all traffic passing through the area on the way to the N4 and N7 and also on local residents attempting to access their own streets.

The traffic surveys were carried out in May and October 2014 before a real upturn in the economy was apparent. The level of existing traffic has already increased and this increase is likely to continue.

The reduction in staff parking spaces is cited as the principal mitigating factor to the increased traffic generated. However, we submit that reducing parking spaces will not stop all staff using cars, and that there will still be staff-generated traffic, as they seek to park

elsewhere in the vicinity of the Hospital. f-~A~~~';;":~~--:~--The proposed reduction in staff parking should therefore not b!ftM~~d~P~h'! itrga'tioniALA measure. - BY -----1

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3.2.1 Comments on the Proposed Mitigation Measures

The mitigation measures proposed by the authors of the EIS to manage the additional traffic generated by the proposed New Children's Hospital are as follows:

''Ameliorative, Remedial or Reductive Measures (Chapter 6 -6.16) Operational Phase

Reduction in Staff Parking at the StJames's Hospital Campus The removal of 244 staff parking spaces from the StJames's Hospital campus, bringing the total number of staff parking spaces down from 1124 spaces to 880 spaces, will reduce the volume of traffic generated by staff during the morning and evening peak hour periods. This reduction in staff traffic will assist mitigate the projected increase in traffic associated with family 1 visitor and outpatient appointments during peak periods. "

Our comment: The point of the reduction of the number of staff car parking spaces is the principal argument put forward, and reiterated again and again throughout the EIS, in an attempt to convince that the impact of the new development will be minimal.

Chapter 18-Interactions &. Potential Cumulative Impacts states in this regard: "The car parking strategy does not include increasing the overall number of parking spaces provided on campus following the completion of the new children's hospital. This will result in no material increase in traffic during peak periods on the surrounding street network and will ensure that the delivery of additional development on campus can be accommodated without impacting on prevailing traffic conditions on the surrounding road network. "

Our comment: This "strategy" may reduce the number of cars entering the campus, but will not reduce the number of cars on adjacent roads as staff/visitors seek parking elsewhere.

"Extension to the On-street Pay Parking System The reduction in staff parking spaces within the StJames's Hospital campus will reduce the overall volume of traffic generated by the StJames Hospital campus following the construction of the new children's hospital. To ensure that staff parking does not overspill onto the surrounding street network it is recommended, in consultation with local residential communities and in conjunction with Dublin City CounCJ1, to extend the existing pay parking system in the vicinity of the Hospital campus. The extension of the pay parking system will deter long term parkers from occupying residential streets in the immediate vicinity of the Hospital campus, ensuring that the impact the proposed development has on the residential amenity of the local area is mitigated. These measures are proposed to be implemented, where required, in advance of construction activity on the campus. "

Our comment: This proposal is outside the control of the Hospital Authority (the Applicant). It is a recommendation only. It is not clear how it would be implemented.

.----~-~~~~~-----There is already pay parking on many of the surrounding str ets,t'intludJI'lg:Mo!!.t!_~~~A~ -Road, Mayfield Road, Madison Road and South Circular Roa TIME BY ___ _,

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There are signs of some long term parking taking place on Mountshannon Road, exceeding the maximum length of stay permitted. It is likely that this will increase when the staff parking on campus is reduced.

The charge for on-street pay parking in the vicinity is €1.00 per hour. The cost of visitor parking at present in St. James's is €2.50 per hour. It is clearly a more attractive option to park on the surrounding streets, rather than in the Hospital car park.

''StJames's Hospital Campus Smarter Travel Programme The implementation of a Mobility Management Plan for the entire StJames's Hospital campus will provide both existing and future staff (and visitors) with realistic sustainable alternatives to the private car to access the hospital. The implementation of the Mobility Management Plan will assist reduce the volume of traffic generated by the new children's hospital mitigating the potential impact the development will have on the surrounding road network."

Our comment: This programme proposes to encourage staff and visitors to use public transport, cycle or walk. It is aspirational, and should not be used as a mitigation factor in reducing traffic impact.

"The Provision of a New Access from Mount Brown The provision of the new access to the children's hospital from Mount Brown provides users of the basement car park with an alternative access to the wider street networtv thereby reducing the potential volume of traffic generated through the Rialto Entrance. The provision of the Mount Brown entrance will mitigate the potential increase in traffic along South Circular Road between Suir Road and Mount Brown and to a lesser degree, along South Circular Road between Suir Road and the existing Rialto Entrance. "

Our comment: The provision of a new access from Mount Brown will not reduce the overall increase in traffic generated in the area. It should be noted that Mount Brown/Old Kilmainham already suffers from traffic congestion in the evening peak period.

"Provision of Sufficient Family Parking The new children's hospital includes for the provision of 675 parking spaces for patient famJ1ies and visitors. This level of parking will accommodate the peak parking demand expected at the new children's hospital and will ensure that visitors and families do not need to use either the existing supply of on-street parking spaces or the existing public spaces provided at the Adult Hospital. The provision of sufficient family parking will ensure that patients and their famt1ies are provided with convenient access to the Hospital's fact1ities and will also ensure that residential parking in the immediate vicinity of the Hospital campus is not occupied by visitors to the Hospitals. "

Our comment: There is no guarantee that this aspiration will be realised. See1bei6\ASin1seEt:i!m q~lin~o.wi Parking Impacts. TIME BY

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"Provision of Improved Pedestrian Permeability The proposed children s hospital includes for new pedestrian routes serving the StJames's Hospital campus. Two new pedestrian entrances are proposed. The first is directly from the Rialto Luas stop and the measures will also include improved public realm at the Luas stop addressing the new southern entrance to the building. The second new pedestrian entrance is from Mount Brown via the existing stepped access to Cameron Square. This new pedestrian entrance will provide improved accessibility to the existing bus services which operate along Mount Brown including Dublin Bus services No. 13 and No. 40. In addition to the new pedestrian entrance proposed as part of the new children s hospital, StJames's Hospital will shortly open a new entrance to the campus opposite the Fatima Luas stop. This entrance will improve access to the campus for Luas users and will also provide improved accessibility to the bus services along Cork Street Cork Street is served by a number of high frequency Dublin Bus services including the No. 27, No. 151 and No. 77a. Finally, the pedestrian network along the main internal road within the StJames's Hospital campus will be upgraded as part of the proposed development The works will provide a continuous footpath within the campus and provide improved pedestrian connectivity between the existing Adult hospital and the proposed childrens hospital. II

Our comment: This will have no impact on existing and future traffic congestion. This is not a mitigation measure.

•-rmprovements to the Local Street Network The following measures are suggested to improve conditions for both traffic and pedestrians on the local street network:

· The provision of an off-line loading bay along South Circular Road between the junctions of Mount Brown and Suir Road;

• The connection of the traffic signals controlling the existing mtd-block pedestrian crossing along South Circular Road to the traffic signals at the junction of South Circular Road/ Mount Brown;

• The provision of CC7V cameras to monitor traffic conditions on the surrounding street network; and

· The provision of a new outbound bus stop on Mount Brown, OJ..a&~/tffrD:ItliJP/anB~e'ff~-1 ,::---... pedestrian entrance to the campus and the provision of a new, igh'llf.<;Qntrolled PS~~),.A crossing. II -

0 2 ocr 201s Our comment: J LTR. These measures are outside the control of the Applicant, and paoui~Ge.he used:.~M mitigation. L ---.1 --­It is not clear who will be responsible for the installation and monitoring of cctv cameras on the surrounding street network.

None of these measures will have an impact on traffic congestion generated by the new development.

Note: There is no junction of Mount Brown and South Circular Road as stated in the EIS (the junction of South Circular Road and Old Kilmainham was probably intended) .

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''Improvements to the existing St 1ames's Hospital Campus Entrances The following measures are proposed to improve conditions for both traffic and pedestrians at the existing entrances serving the StJames's Hospital campus.

Rialto Entrance • Setting back of the Hospital campus boundary to make provision for the provision of cycle lanes along South Circular Road immediately adjacent to the new children's hospital near the Rialto Entrance;

• The relocation of the Rialto Entrance to the north to improve the interaction between it and the neighbouring signalised junction;"

Our comment: These measures will have no impact on traffic congestion generated by the new development. The provision of cycle lanes is outside the control of the Applicant. There would not appear to be sufficient room for cycle lanes on the existing Luas Bridge.

''StJames's Entrance • The provision of improved pedestrian and cycle facilities at the existing StJames's Hospital Entrance;

• The provision of a two lane exit to provide additional exiting capacity for patients of the St James's Adult Hospital. "

Our comment: These measures will have no effect on the traffic congestion in surrounding streets.

"Through Traffic Restrictions within the StJames's Hospital Campus The National Paediatric Hospital Project proposals include additional restrictions to through traffic within the campus. The restrictions will prevent all through traffic with the exception of buses, cyclists, emergency vehicles and other authorised users (including staff). The implementation of restrictions wJ11 reduce the volume of traffic within the campus with a corresponding reduction in traffic at the Rialto entrance and its neighbouring junctions. The removal of through traffic will assist mitigate against the projected increase in traffic associated with patients arriving/ leaving the new chl'ldren's hospital. "

Our comment: These traffic restrictions have already been taken into accoliiitill-catculating.tlle..to al projected change in traffic generation of 3444 traffic move~~n~ 'per~W/not:eccaqp~ They should not be introduced as an additional mitigation r~~ I:Jote that t~re are alrea through traffic restrictions in place at the Rialto Entrance. O

2 OCT 2D15 "The provision of Wayfinding Signage LTR·DATE A wayfinding strategy will be introduced to provide famili8fi/.nd visJ9Gf.S wJfbFfPfNifmation fl guide them to the new children's hospital at St James's Hospltaf_71Je-~nding_ strateg will include signage on the road network and traveller information on the Nationaf Paediatric Hospital Project website"

Our comment: This measure consists of proposed road signs which it is planned to erect. This should not be used as mitigation, as it will do nothing to reduce the impact of additional traffic.

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3.2.2 Summary:

There is already serious traffic congestion in the area, as identified by the EIS.

The additional estimated 3444 car movements per day associated with the proposed new NCH will have a detrimental impact on both local residents and all road users of the adjacent road network.

A congested city centre location, surrounded by residential streets, is not a suitable location for a development which will generate the predicted level of new traffic.

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3.3 TRAFFIC IMPACT OF FUTURE PLANS

Future plans to build a new Maternity Hospital within St. James's Hospital are projected for 8-10 years into the future. It is estimated that the Maternity Hospital will require 120 additional car parking spaces for visitors. It is proposed to provide these by further reducing the number of staff spaces. There is no information on the size of the proposed Maternity Hospital or the basis of the calculation of the required additional spaces, or of the number of new staff members.

It is stated that because no extra parking spaces will be provided, there will therefore be no impact from visitor traffic on the surrounding residential streets.

There is no assessment of traffic impacts for the staff of the Maternity Hospital, as no parking spaces will be provided.

Chapter 6 Page 6-95 '!4ccess to the campus for all staff on campus (including the future Maternity Hospital) w1ll be provided through the St James's Hospital Campus Smarter Travel Programme. " This means the use of public transport, walking and cycling.

There is a stated assumption that '7t is expected that car usage will reduce slightly over the period reflecting the proposed improvements in public transport facilities in the Greater Dublin Area"

There is no study assessing the feasibility of potential sites for a Maternity Hospital within the campus, as patently no brief has been finalised.

The Non-Technical Summary (Page 25) confirms this, as follows:

Future Maternity Hospital The St James's Hospital campus will also potentially support the emerging proposals for the Maternity Hospital to the east of the proposed new children's hospital, although it does not form part of this planning application. The Maternity Hospital proposals are at an early stage and there is no permission to build them. Given the absencef Nnformi!tion. it is not possible to assess the impact of this development, either singly or cu. ula'tively,cotp,,i ifi!1!J.C1ra ver.)'.-. high level. This matter is referenced in Section 6.14 below. TIME -t.:l-\ I\JA LA In terms of staff at the future Maternity Hospital, their travej demaiias Will-be ~Ylllti for through the expansion of St. James's Hospital Campus Smatter Trave!J l!togramme5" ._., . . LUI

LTR·DATED as does Chapter 18-Interactions & Potential Cumulative Im ~: - _FROM

---J '!4t this early stage with no design of building form to consider it is not possibleto7:ake'7JR cumulative impact assessment of the Maternity Hospital any further. Future investigations of the potential site options will inevitably involve consideration of appropriate design and mitigation measures to minimise any loss of amenity and/or other environmental impacts upon adjoining residential areas. The provision of a clinical/ink between the three hospitals may give rise to impacts relating to soils and geology in terms of excavations required.

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Clearly, the potential of the campus to accommodate tri-location of the children~, adult and maternity hospitals will require substantial additional detailed work (well beyond the Draft Site Capacity Study) once the emerging Maternity Hospital proposals are confirmed and available. "

It is regarded by the applicant that co-location with a Maternity Hospital is imperative, to the extent that a new Maternity Hospital must be provided within the St. James's Hospital Campus within 8-10 years. If this is the case, the proposal for the new Maternity Hospital should have been included in this application for the proposed new Children's Hospital, and predicted cumulative impacts should feature in the current application. This omission should be sufficient to invalidate the current application for the new Children's Hospital.

It could be assumed that the cumulative impacts that would result would put the entire project at risk and therefore the applicant has chosen to avoid the inclusion of the Maternity Hospital component for the present, for strategic reasons. We must therefore assume that permission for the Maternity Hospital component would only be sought if the application for the proposed New Children's Hospital is granted, thereby forcing the planning authority to also grant permission the proposed Maternity Hospital regardless of the resulting cumulative impacts.

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4.0 IMPACT ON PARKING

The EIS identifies a Transport Strategy for St. James's Hospital as being the core framework which will allow the existing and proposed hospitals to function. The key objectives of the strategy are:

• "To manage the potential traffic impact the development proposals have on the receiving environment to ensure that surrounding street network is not significantly adversely impacted on.

• To provide staff, patients and visitors with a choice of travel modes to the Hospital ensuring their healthcare experience is as comfortable and convenient as possible."

Among the core principles underpinning the Transport Strategy as listed, the following are of o particular interest:

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• ·~ balanced car parking strategy - the provision and management of car parking is critical to the success of the Strategy and functionality of the Hospitals. It is important to provide adequate car parking to cater for the variety of needs that will be generated by the Hospital campus, in particular for patients and their families, while limiting the amount of employment or commuter car parking provided This strategy provides commitment to both national and regional transport planning policies through the minimisation of car parking provision on campus, particularly for commuters.

• Mobility management planning - The StJames's Hospital Campus Smarter Travel programme has been established and is currently being implemented The Smarter Travel programme is underpinned by realistic and deliverable measures, supported by key stakeholders including the National Transport Authority, Dublin O"ty Council and public transport service providers, and will be actively monitored to ensure success. It will also be externally focused in terms of continued engagement with the local community to ensure that any travel demand impacts, including parking issues are addressed as they arise. "

In relation to car parking, the key numbers extracted from the EIS are:

Staff Car Parking

Existing staff in adult hospital Total Staff when proposed NCH is operational

This equates to a staff increase of

At present, based on a recent survey, there is a 57% staff car

The Mobility Management Plan sets out a target of staff car u

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In the operational phase, there will be a requirement for 1,350 staff car parking spaces (based on an aspirational target of 27% of 5,000 staff). The total proposed provision for staff car parking is set at 880, a shortfall of 470. It is unclear where these 470 staff going to park.

Note that the reduction from 57% staff car usage to the proposed 27% is aspirational only, and cannot be enforced, regardless of the National Transport Strategy or other policies. It can therefore be assumed that the number of staff seeking parking in the vicinity will exceed the shortfall of 470 as detailed above.

Furthermore, the existing 3,000 core hour staff, with an identified 57% car usage, equates to a current parking requirement of 1710 spaces. The existing staff parking provision is 1124, a shortfall of 580. It can be assumed that some, if not all, of these staff are already parking in the surrounding streets.

The statement under Mobility Management Planning that there will be engagement with the local community re parking impacts is not realistic. There is no clarity as to how this would be managed.

The EIS states:

"The new children s hospital includes for the provision of 675 parking spaces for patient fam1/ies and visitors. This level of parking will accommodate the peak parking demand expected at the new children s hospital and will ensure that visitors and families do not need to use either the existing supply of on-street parking spaces or the existing public spaces provided at the Adult Hospital. The provision of sufficient family parking will ensure that patients and their families are provided with convenient access to the Hospitals facilities and will also ensure that residential parking in the immediate vicinity of the Hospital campus is not occupied by visitors to the Hospitals. "

"The measures included for within the St Jamess Hospital Campus Smarter Travel Programme are fully committed to by StJames's Hospital and the Childrens Hospital Group, including any requirements for corrective action. The modal split targets will be monitored into the future and oversight will be provided by the Steering Group established as part of the Smarter Travel Programme. As part of the monitoring process, regular travel surveys will be undertaken at the St Jamess Hospital campus to identify the change in modal split over time. The appointed Mobility Manager will regularly review the impact the management of parking within the StJames's Hospital campus has on the surrounding street¥ie~Jfi!.rk to ensure the level of on-street parking is controlled and instigate any necessar;lcorre(Jfive(!dioas in conjunction with Dublin City Council. " TIM€ c.) Ro P ... ~4/V ~

We submit that the above measures cannot be realistically impl.lnented~ a~ 4'-A

I LT. ocT 2{!J.lj We submit that there is no guarantee that visitors, hospital sta~ arfaoc0 tlstruction stafiwill not park on the surrounding residential streets. PL -........_FROM

The calculated visitor parking provision of 1.5 cars per bed appears very low when compared to similar hospital facilities in other countries. Therefore there are likely to be severe impacts on local parking by the demands of the new development.

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We do not consider that on-going reviews of parking and corrective actions are likely to be implemented.

There is no spare parking capacity on the residential streets around St. James's. The house frontages are approx. 4.5 -5.5 metres in width, the equivalent of a single car space.

The EIS recommends that the existing pay parking system should be extended to other streets in the vicinity of St. James's. We do not agree that this is sufficient.

It is clear that if the NCH is to proceed, measures would have to be put in place to avoid the surrounding streets being overwhelmed by the demand for parking by staff that have been denied the facility on site, by visitors, and by construction staff. We submit that the necessary measure to alleviate the situation for residents would be to change the designation from the current general pay parking/resident permit holders to parking restricted to residents and their visitors only, on a 24 hour basis.

This measure would require a legally binding undertaking by the Local Authority prior to any planning decision. It would also be essential that rigid enforcement would be required once implemented.

Also proposed would be an alteration to the signage at the Junction of South Circular Road/Mountshannon Road where presently no left turn is permitted. It is proposed that this be altered to: "Access for Residents only", as a way of easing access for residents, who currently add to the congestion on South Circular Road in the evening peak period, while waiting to enter Mountshannon Road via Mayfield Road.

4.1 Summary:

The EIS admits that the viability of the location for the proposed new Children's Hospital is dependent on parking and mobility management:

"the provision and management of car parking is critical to the success of the Strategy and functionality of the Hospitals. "

This highlights the fact that a congested city centre location, surrounded by residential streets, is not a suitable location for the proposed NCH, because it cannot accommodate the car parking demand.

The Mobility Management Plan, whereby hospital staff and visitors convert from car usage to public transport/walk/cycle is aspirational only, and should not b en into account in assessing the suitability of the location for the proposed NCH. AN BORD ,_ .-.

TIME PLr:;f..livA;;;=-For example, the EIS states, under "Future Infrastructure Impr emen'tS1el'YEhc/P~ · 6 6.1.1.13) that: 0 2 ocr 20t~5-

LTR·DAT£:D "The following infrastructure projects have already ob!._iqed plannif19..1Jji,rftfiSS.(on or are under active consideration. They are likely to have an--iiTI!tJ~flGJ!.:..~e.:_"!J _

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environment into the future and improve even further public transport accessibility to the StJames's Hospital campus.

DART Underground Dart Underground is considered an integral part of the future planned Dublin integrated public transport system and has received planning permission from An Bard Pleanala . .......... "

Note that the Dart Underground Project, while having been granted a Railway Order in 2011, was 'shelved' soon afterwards. It has recently been announced by the Government that this project will not proceed in its present approved form, but will rather be subject to a redesign. This would seem to be an example of an aspirational project (now effectively defunct) being used in support of the NCH proposal.

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5.0 CONCLUSIONS

The EIS identifies that there is existing traffic congestion in the area.

The EIS identifies that there will be a considerable increase in traffic both during construction and when the proposed New Children's Hospital is operational.

The mitigation factors proposed are: The reduction of staff parking on the Hospital Campus, and the claim that this will reduce traffic impact. A Mobility Management Plan will encourage staff and visitors to use public transport/cycle/walk, in line with the National Transport Strategy, and the claim that this will reduce traffic impact. We do not accept the validity of these mitigation factors.

There will considerable adverse impact on both traffic and parking in adjacent residential areas.

The feasibility and impact of the proposed future Maternity Hospital has not been adequately considered, and should have formed part of the current application, with the cumulative impacts being taken into account.

This submission to An Bord Pleanala in opposition to the proposal to locate the New Children's Hospital in St. James's Hospital Campus has been prepared by:

Neil Donnellan and Caroline Leaden 34, Mountshannon Road Kilmainham Dublin 8

AN BORO PLEAN , TIME ALA

- BY - ------1 0 2 OCT 2D15

And supported by the residents listed in APPENDrk:if·DATEo ___ FROM l!_L- - -----..~

==

~bdat/ Neil Donnellan Caroline Leaden

1st October 2015 1st October 2015

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APPENDIX A

PHOTOGRAPHS OF TRAFFIC CONGESTION ADJACENT TO THE RIALTO ENTRANCE

TO ST. JAMES'S HOSPITAL DURING THE EVENING PEAK PERIOD

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Aerial View of St. James's Hospital, South Circular Rialto Entrance to St. James's Hospital circled in red

"-"g"'"'· Brookfield Road, Mountshannon , Mayfield and Madison Roads.

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Aerial View of St. James's Hospital, South vlf{;UIHI

Rialto Entrance to St. James's Hospital circled in

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Mountshannon , Mayfield and Madison Roads.

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View West on South Circular Road adjacent to junction with Mayfield Road, looking towards Bulfin Road/Suir Road Junction. Recorded at 17.55, on 22"d September 2015.

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View East on South Circular Road adjacent to junction with Brookfield Road, looking towards St. James's Hospital. Recorded at 17 .55, on 22nd September 2015.

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View West on South Circular Road adjacent to junction with Brookfield Road, looking towards Bulfin Road/Suir Road Junction. Recorded at 17.56, on 22nd September 2015.

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View North on South Circular Road adjacent to junction with Brookfield Road, looking towards St. James's Hospital (Rialto Entrance) Recorded at 17 .58, on 22nd September 2015.

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View North on South Circular Road adjacent to junction with Brookfield Road, looking St. James's Hospital (Note bus unable to make right turn) Recorded at 17.58 on 22nd September 2015.

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View South on South Circular Road adjacent to junction with Brookfield Road, James's Hospital on left (Note bus travelling off-route towards Rialto) Recorded at 17.59, on 22nd September 2015.

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View North on South Circular Road adjacent to junction with Brookfield Road, looking towards St. James's Hospital (Rialto Entrance) Recorded at 17 .59, on 22nd September 2015.

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View West on South Circular Road adjacent to junction with Mayfield Road, looking towards Bulfin Road/Suir Road Junction. Recorded at 17.51, on 23rd September 2015.

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on South Circular Road adjacent to junction with Mountshannon Road (on left), looking towards St. James's Hospital (Rialto Entrance) Recorded at 18.03 on 29th September 2015.

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View North on South Circular Road adjacent to junction with Mountshannon Road (on left), looking towards St. James's Hospital (Rialto Entrance) Recorded at 18.03, on 291h September 2015.

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L' ' 'o'ieW-Nenti on South Circular Road adjacent to junction with Mountshannon Road (on left), looking towards St. James's Hospital (Rialto Entrance) Recorded at 18.04, on 29th September2015.

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on South Circular Road adjacent to junction with Brookfield Road, Mountshannon Road on right. ~~ ..... ~.,~at 18.05, on 291h September 2015.

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West on South Circular Road adjacent to junction with Mayfield Road, looking towards Bulfin Road/Suir Road Junction. IW.. .R~d at 18.05, on 291h September 2015.

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West on South Circular Road adjacent to junction with Mayfield Road, looking towards Bulfin Road/Suir Road Junction. Recorded at 18.06, on 29th September 2015.

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on South Circular Road adjacent to junction with Brookfield Road , (buses exiting St. James's Hospital (Rialto Entrance) IRPI"nrrlt~rl at 18.09, on 29th September 2015.

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on South Circular Road adjacent to junction with Mayfield Road, looking towards Bulfin Road/Suir Road Junction. Recorded at 18.09, on 291h September2015.

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orthwest on South Circular Road adjacent to junction with Brookfield Road, (bus about to make the right turn to South Circular Road) '""'"'~"~"~"~"'n at 18.11 on 291h September 2015.

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u_ J...:Ju.::: on South Circula; : :::·: djacent to junction with Brookfield Road, (bus completing the right tum to South Circular Road, 2"" bus waiting) Recorded at 18.12, on 291h September 2015.

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.. rded at 18.12, on 29th September 2015.

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APPENDIX B

RESIDENTS OF MOUNTSHANNON ROAD, MAYFIELD ROAD AND MADISON ROAD

WHO SUPPORT THE FOREGOING SUBMISSION

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The following residents of Mountshannon Road, Mayfield Road and Madison Road are opposed to the location of the proposed New Children's Hospital within the St. James's Hospital and support the foregoing submission to An Bard Pleanala.

1. Anne Lowen, 10, Mayfield Road, Kilmainham, Dublin 8.

9. Pauline MacNamara & John McHugh 1, Mayfield Road,

2. Lorraine and David Higgins, 47, Mountshannon Road, Kilmainham, Dublin 8.

3. Angela Malone and Shay Timmons, 23, Mountshannon Road, Kilmainham, Dublin 8.

4. Kevin and Maire Devine, 20, Mountshannon Road, Kilmainham, Dublin 8.

Kilmainham, Dublin 8.

5. Gerry, Deirdre, David, Emma and Lauren Dignam, 11, Madison Road, S.C. Rd., Kilmainham, Dublin 8.

6. Monica Tyrrell and Miriam Tyrrell, 22, Mountshannon Road, Kilmainham, Dublin 8.

7. The Slowey family, 5, Mountshannon Road, Kilmainham, Dublin 8.

8. Susan MacNamara and Seamus Helferty, 59 Mountshannon Road, Kilmainham, Dublin 8.

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Al\1 BORD PLEANALA TIME BV ----J

D 2 OCT 2015 LTR-DATEO FROM PL ---

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