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Joe Ruane & Mary Kearney,

501 South Circular Road,

Dublin 8.
The Secretary,
An Bord Pleanala,
64 Marlborough Street,
Dublin 1.

28 September 2015


Planning Application Reference PL29N.PA0043, St James Hospital,

Dublin 8.

Dear Sir / Madam,

We write in relation to the above planning application to detail the concerns that
we have about the proposed development. Our family home at No. 501 South
Circular Road is a minimum of 21.9m to the west of the proposed development
site and accordingly we have a particular interest in any proposals which may
represent a threat to our established residential amenities.

We would like to firstly state that we have no objection to the fact that the area
immediately bounding our property is a hospital. As this has been mine and my
childrens family home all of our lives, and for a significant amount of time for
my parents, we have always welcomed the proximity of St. James Adult
hospital and have always expected that there would be developments to
complement our neighbourhood, as was previously done by St. Jamess
Hospital. The most recent buildings developed on this western side of the site,
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the St Jamess Private Clinic and the buildings that now house the Speech and
Language departments, are of a low height and are in red brick complementary
to our neighbourhood and our adjoining residential homes.

However, the development currently proposed does not complement this

historic neighbourhood. We have asked Sheridan Woods to review elements of
this on our behalf.
Our objections to the proposed development are on the following grounds: -

1. Breaches of Planning Guidelines

o Impact on our home in terms of light
o Impact on our home in terms of overlooking
o The proximity to our home and the abrupt transition to Z2
o Height & Scale of Development in an area not zoned for High
o Lack of sympathy with Zone 2 Residential Area

2. Impact of traffic caused by this proposed development

o Construction phase
o Operational phase
o Impact on Parking

3. Health & Safety Issues

o Aspergillus/Legionnaires Disease
o Sewage
o Vermin Control
o Helicopter landings

4. Other matters of concern

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o Misrepresentation of photomontages at South Circular Road

o Duration of the Planning Application
o Inability of the local area to deal with the size of the construction

As a result of the above we ask that permission for this development be refused
on this site. We would suggest as an alternative that the site behind The
Coombe Women & Infants University Hospital would be more appropriate as
the location for the National Childrens Hospital.

1. Breaches of Planning Guidelines

Impact in terms of Light.

Section 15.10.14 Land Use Zoning Objective for Z15 lands states
development at the perimeter of the site adjacent to existing residential
development shall have regard to the prevailing height of existing residential
development and to standards in section 17.9 in relation to aspect, natural
lighting, sunlight, layout and private open space, and in section 15.9 in relation
to the avoidance of abrupt transitions of scale between zonings.
The main windows to our kitchen face eastwards towards the planned
development site. There are no windows facing southwards. Access to the
early morning sunlight is very important in terms of our enjoyment of that
particular living space. See Fig 1 below. The development of this 12.6m
building due east of these windows of our home will inevitably affect the access
of early morning sunlight throughout the year. Due to the height of the
proposed development and its proximity to the site border, the consequent
overshadowing will cause serious injury, in particular to the amenities of our
kitchen area.
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Fig 1: View from kitchen 01/10/2015 07:58

In addition, we enjoy morning sun to the front bedroom and sitting room in our
house due to the presence of the Bay Window, See Fig 2 this will be completely
blocked due to the 34.95m building to our east.

Fig 2: Sun coming in bedroom window 10/8/2015 07:41

We do not agree with the view portrayed in the EIS that the impact of the
proposed development will not significantly alter the profile of the existing
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sunlight on our property. This view is confirmed by Sheridan Woods in the

adjoining submission. We request that a proper all-year round Independent
Light Survey to review of the shadow castings be undertaken to show the full
impact on our home and that of our neighbours.

Impact in terms of Overlooking.

The lodged drawings indicate that it is proposed to locate balconies and glass
fronted corridors immediately across from home to a height of 12.6m above the
level of our house. The proposed development will therefore result in serious
overlooking of our garden and of the windows of our kitchen, and indeed due to
its proximity, will provide direct views into our kitchen. This will cause serious
injury to the amenities and utility value of these areas of our home.
Section 17.6.3 of the Dublin City Development Plan - Assessment Criteria for
High Buildings sets out the assessment criteria that mid-rise and high buildings
must have regard to. I refer to the section on Social Criteria which states that
the buildings must Minimise overshadowing and overlooking of surrounding
properties and adverse impacts on established or emerging residential
communities. `
We contend that the planned development does not adhere to this criteria as it
overshadows and overlooks an established residential community and thence
should be refused.

The proximity to our home and abrupt transition to a Zone Z2

Recognising the reality of adjacent zoning issues, (we are Zone Z2, while the
grounds of St. James Hospital are Zone Z15), Section 15.19 of the Dublin City
Development Plan states the following strategy it is important to avoid abrupt
transitions in scale and use zones. In dealing with development proposals in
these contiguous transitional zone areas, it is necessary to avoid developments
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which would be detrimental to the amenities of the more environmentally

sensitive zone. For instance, in zones abutting residential areas or abutting
residential development within predominately mixed-use zones, 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.
This proposed development does not achieve this objective as there is no break
at all between our period red-brick houses and the planned 12.6 metre high
section of this proposed building immediately to the boundary of the site. The
building, as proposed, comes to the extreme western end of the St. James
Hospital site and as such it offers no transition at all to our home, being at a
distance of only 21.9m away, with no space for any landscaping or screening
between the proposed building and the western boundary of the site as currently
exists See Figs 3 & 4 below. Our home is zoned Z2 Residential
Neighbourhood, Conservation Area and has the stated objective of To protect
and/or improve the amenities of residential conservation areas. This
development does not meet this objective.

Fig 3: Daytime view from kitchen

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Fig 4: Early morning view from kitchen

Height & Scale of the Development

Section 17.6.2 of the Development Plan 'Definition of a High Building
provides a definition of height for the St James Hospital grounds and
surrounding areas as below 19m residential / 28m office. The height of the
main body of this proposed hospital is 34.95m. This is significantly in excess of
the Dublin City Development plan, which has a maximum height of 28m for
this neighbourhood (including the Z15 area). We contend that the proposed
hospital building fails the planning principles in that regard by reason of its
visual incongruity arising from its excessive height in the context that it is not
an area approved for High buildings and due to the proximity to the adjacent
Residential Neighbourhood, Conservation Area Zone. We also contend that this
proposed development does nothing to protect the amenities of the residential
homes opposite and is in breach of Dublin City Councils guidelines. As can be
seen from the photographs of the model Fig 5 and 6 below it is significantly
higher than the local residential neighbourhood.
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Fig 5: Photograph of Model showing impact on Brookfield and South Circular Roads

Fig 6: Photograph of Model showing impact from Mount Shannon Road.

Section 17.6 of the Dublin City Development Plan states Dublin City Council
acknowledges the intrinsic quality of Dublin as a low-rise city and it is policy
that it should predominantly remain so. It also states It is the policy of Dublin
City Council to continue to protect and enhance the skyline of the inner city and
to ensure that any proposals for high buildings make a positive contribution to
the urban character of the city, and create opportunities for place-making
identity in the outer city. The height of this proposed development,
immediately east of our home, rises to a height of 55.95m datum level. This
would leave it as one of the highest points in Dublin and with a length of
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251.3m for the building overall and 178.7m for the oval. It means that the
proposed building will be the largest visible structure on the skyline of Dublin.
We believe that this does not comply with the policy of Dublin City Council.

The proposed development is also in breach of Dublin City Councils Strategic

Policy SC18 To protect and enhance the skyline of the inner city, and to
ensure that all proposals for mid-rise and taller buildings make a positive
contribution to the urban character of the city, having regard to the criteria and
site principles set out in the Development Standards Section (see Chapter 17).
In particular all new proposals must demonstrate sensitivity to the historic city
centre, the river Liffey and quays, Trinity College, The cathedrals, Dublin
Castle, the historic squares and the city canals, and to established residential
areas, open recreation areas and civic spaces of local and citywide
importance This proposed development does not demonstrate any sensitivity
to this historic residential area.
We also object that this development encroaches onto the Z9 Linear Park,
thereby reducing the access to the northern end of this park for residents of this
area for at least the years of the proposed development (Up to 10 years
permission being sought for the Davitt Road Compound).

Section 16.1.4 of the Dublin City Plan states that The height of buildings
relative to the width of a space is an important consideration affecting
sunlighting and also the sense of being in a traditional street. For large
developments (e.g. occupying more than 20m of street frontage) the height of
buildings and how they positively relate to the scale of other buildings along the
whole length and on both sides of the street must be demonstrated.
We believe that this proposed development does not meet this criteria.

Proposed Finishes
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The proposed finish of the National Childrens hospital The prevailing

material proposed is stone with the favourite in terms of colour and grain being
a mottled grey granite is totally unsympathetic to the materials and finishes
which characterise development in the adjacent residential area. Indeed, to date
St James Hospital has been very considerate of this neighbourhood in that all
the existing buildings on this western boundary are finished in red brick to
blend in with this existing historic area.

2. Impact of traffic caused by this proposed development

This is a residential area with many young families and children living close to
the entrance to the hospital. The significantly increased volume of traffic that
this development will generate will indeed negatively impact on our daily lives
and make our living situation worse. We are concerned with additional strains
that access to the proposed hospital will cause in our neighbourhood. This
traffic will not only be at peak hours when employees enter and leave the
complex, which we currently contend with. We understand, but do not know
how it will work in practice, that no more than 728 of the approximate 6,000
staff in the combined St Jamess Adult and National Childrens hospitals will be
expected/allowed to drive (728 parking spaces available for staff). That level of
parking that will be provided is considerably less than the existing levels
provided in St. Jamess Hospital and in each of the three Childrens Hospitals.
However, overall it amounts to a reduction of a mere 244 staff parking spaces
that is meant to mitigate the additional traffic generated by the 350,000 patients
that will be treated in the proposed hospital. That means approx. 1,900 sick
children coming into the site per day, and we do not expect the majority of them
to use Public Transport.
As all residents, commuters and hospital visitors and staff know, this area is at
maximum capacity during the rush hour periods at present (also recognised in
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Page 6-150 of the EIS Section 6). This development is proposing rush hour
conditions in the area during most of the day for all working days. We are
concerned of the impact that this level of traffic will have on urgent cases and
emergency vehicles trying to get to St James Adult Hospital as well as the
proposed National Childrens Hospital on the site.

Construction Phase Traffic

Per Section 6 of the EIS there are estimates for the lorry movements that will
pass our house to travel to the junction of SCR/Bulfin Road/Suir Road during
each of the 3 phases of construction. Our home is very close to the traffic lights
for the entrance to the hospital, and due to this we are very concerned with the
noise and vibration that will be caused by waiting trucks at the junction. Per the
information provided, for each of the phases the volume of traffic generated will
average in the region of the following:
Phase 1
Average 357 per day for the first 4 months (including removal of demolished
buildings), giving an estimated total of 48,654 traffic movements.
Average 322 per day for the next 2 months total 19,504 total movements
Phase 2
483 per day for the next 18 months total movements of 199,672
Phase 3
513 per day for the next 21 months (minimum) total movements of 247,420

We object to this level of development on the site. Well in excess of 490,000

HGVs or LGVs will pass our home and due to the proximity to the junction will
have to wait outside our house awaiting clearance through the lights. It is worth
noting, that based on the estimates provided over 111,000 of those are to
remove the earth and rock from the site to dig the very substantial basement that
will be required for this proposed development. We consider this to be an
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indication that the proposed buildings are much too large for this constrained
site. The level of traffic on the South Circular Road is due to the inability of
these trucks to leave the proposed new entrance at Mount Brown for onward
exit via the Con Colbert Road.

Operational Traffic
Section 6 of the EIS Page 132 states that the expected level of additional
hospital traffic will be in the region of 300 400 traffic movements per hour.
The majority of these will be via the SCR & Brookfield Road entrance. This is
a very significant number of additional vehicles on the road in the region of
1800 to 2400 per day. We contend that the road network in this neighbourhood
cannot sustain this level of additional traffic and will lead to all day congestion
and will seriously hinder the access to the National Childrens Hospital and St.
Jamess Adult Hospital A&E Department for emergency vehicles.

Proposed Bicycle Lane

We note the proposed plan to put a bicycle lane on the portion of the SCR
between Rialto Bridge and the junction with Brookfield Road, to cross into the
middle of the road as it approaches the junction and to continue on into
Brookfield Road. This is not a suitable place for a bicycle lane, and would
indeed be dangerous for cyclists trying to cross this very busy junction. We
consider that the proposal for a bicycle lane on this very narrow stretch of road,
which was built in the late 19th Century, will have even further detrimental
impacts on traffic in the neighbourhood. As planned, the bicycle lane will
effectively reduce the existing two lanes, which allows traffic select its direction
before the bridge to go straight on towards the hospital or to turn left to travel
towards the Suir Road/Bulfin Road junction, down to one lane. This will cause
even more difficult conditions for the ambulance service that use this road
constantly, and who regularly have to switch lanes, or cross to the other side of
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the road to get into the St Jamess Adult hospital at the moment. The
additional traffic generated by the National Childrens Hospital, together with
the cycle lanes that are proposed on both sides of this road, will create an even
more dangerous junction than exists today.

Parking issues for the resident community

Disc parking is in operation in our immediate area from Monday to Saturday
07:00 19:00, with free parking on Sundays and at present it can prove difficult
to obtain parking near ones house. Currently, during Visiting Hours in St
Jamess Hospital quite a number of people park on our streets. This problem
regarding the adequacy of parking is acknowledged by the NPHDB who
suggest in Page 22 of the Non-Technical Summary The extension of the
existing on-street pay parking system in agreement with the local residential
community, where required
They also suggest that the prices in our areas should be increased. This tacit
acceptance that they are not providing adequate parking is totally unacceptable
to the parents of the sickest children of our country. A development location
that does not provide adequate parking for the transport of sick children to
hospital just should not be considered. This fact, further reinforces our belief
that this site is not the appropriate site for the National Childrens Hospital and
should be refused planning permission.

3. Health & Safety Issues

Aspergillus/Legionnaires Disease
The planning application discusses the possible presence of Aspergillus spores
in the site. The application states that While dust from construction activities
tends to be deposited within 200 m of a construction site, the majority of the
deposition occurs within the first 50 m (as shown in Table 12.11). There is no
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mention in the report as to how any potentially adverse impact is going to be

mitigated for properties outside of the boundaries of the site. We live
21.9metres from this site and this is a very worrying feature for us. This is
particularly of concern as the excavation works will be taking place over 18
months at a minimum.

Vermin Control
Due to the extent of the excavations that have to occur as part of this proposed
development, together with the redirection of the Drimnagh Sewer on the St
James campus we have a serious concern regarding the disruption of rats and
their dispersion into the local area i.e. our roads, gardens and houses. This is
not covered at all by the developers and we require same to be controlled, due to
the impact this may have on our children. This is currently a major issue for the
residents close to the MISA building which is under construction on the St.
Jamess Hospital site.

We are concerned that the facility is going to add significant pressure on the
local sewage facilities. The cost of relocating the Drimnagh Sewer is not
covered in the budget for the National Childrens Hospital. We have concerns
that any disruption to this service will have serious impacts on our facilities.
We would request that Dublin City Council Drainage division and Irish Water
be requested to affirm the plans for the rerouting of the Drimnagh Sewer and
that the successful completion of this should be a condition of further work
being carried out on the site.

We are also concerned about the area identified as the entrance to the Basement
Car-park and the fact that there are three underground levels at this site. The
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area identified as the entrance has flooded twice in the past 7 years and is an
area that is recognised as being subject to flooding. We do not see any
mitigation to future events of a similar nature in the plans for this building.

In recent years, this area has been subject to water restrictions. We have
concerns that a development of this size will create serious adverse implications
for water supply in this part of our city and we believe that this also needs to be
taken into consideration and is a reason to decline such a significant project.

Helicopter Landings on proposed Helicopter Landing Pad

As part of this development it is proposed to locate a helipad on the 4 th Floor
Level to the South East of our property. We have serious concerns about the
level of noise that landings on this helipad will cause so close to our residence.
We would like additional information regarding the flight paths for helicopters
and details of the noise impact on our home.

4. Other matters of concern

Misrepresentation of the proposed building size in the Photomontages.

We contend that the representation of the building as shown in the photomontages is very misleading. It is obvious that different photographic angle
views are utilised, and these lead to the impression that the impact on the view
from the South Circular Road is quite limited (See Photomontages37.1, 37.2
and 37.3). These photomontages do not provide the required information
regarding angles of vision or lens focal length. However, using the data
provided, the height of the existing house on the grounds of St. James Hospital
is in the region of 9m and the height of the hospital at 34.95m then the height

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differential should be in the region of 385% not 110% as portrayed in the


We consider this to be in breach of good practice and that it gives a misleading

view of the development which as designed will not look at all like the pictures

Duration of the Planning Application.

The timeframe for this development is well in excess of the normal grant of
Planning Permission. We suggest that any permission for a National Childrens
Hospital should be for a period of 5 years only as it should be possible to build
such an important building in this timeframe if the site were suitable for such a
building. This extended application request would indicate that this site is too
constrained and is unsuitable for a building of this scale and mass. It may also
be caused by the inaccessibility of this site from the perspective of the
movement of construction and demolition materials required to prepare the site
and to build the hospital A more suitable site would allow the development of
the required National Childrens Hospital take place and be fully operational in
a much shorter time-frame.

Site Capacity
We are very concerned with the plans as outlined in the St. James Hospital
Draft Site Capacity Plan that is submitted as part of this application for the
National Childrens Hospital. This amounts to a capacity in the region of
303,000m2 for the site (Table Page 32). According to the Non-Technical
Summary, the site of the National Childrens Hospital amounts to 8.7ha of the
total 19.48ha SJH site, this means that there is 10.78ha left for St. James
Hospital. Given the scale of the increase required by St. James Hospital we do

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not consider that adequate space is left to meet the capacity guidelines set out by
Dublin City Council Development Plans.

Future Traffic
We are also very concerned with the traffic that will be generated by this
additional development. The situation as described above appears impossible
even before the Maternity Hospital and the expansion covered in the St. James
Hospital Master plan are taken into consideration. When all these additional
movements in and out of this constrained site are taken into consideration, it
will not be possible for the two access roads, one of which was built in the
1700s and the other in the 1800s, to deal with the traffic required for the
transport of patients. Is not acceptable that the health of future generations of
Dubliners relying on St. Jamess Hospital, our elderly who will attend the new
MISA building, our cancer patients who will attend the proposed Oncology
Unit, our sickest children and our expectant mothers are put at risk by the
granting of this planning permission on this site when other more suitable sites
are available in our city to disperse this total patient population more

As stated in the Non-Technical Summary Page 26 Section 7.2.2 Following the

construction of the new childrens hospital, it is acknowledged that the
surrounding street network will continue to experience traffic queuing and
delays at some periods through a typical week day. The mitigation proposals
included as part of the Transport Strategy for the St Jamess Hospital campus
and the new childrens hospital will ensure however that the increase in traffic
levels and associated impact during these periods are kept to a minimum. We
do not see these mitigation proposals and again suggest that there is no way that
we can mitigate for the requirements of sick people to be brought to hospital by
either car or ambulance.
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Site Boundaries
We wish to question the site boundaries as set out for this proposed
development. The boundary, per the drawings, on the western side of the
development takes approx. 50% of the South Circular Road into the
Development Site. We object to this, as this is not the property of St. James
Hospital, or the HSE and we do not believe that it can be taken into the site by
the National Childrens Hospital. The same issue applies to the Southern
boundary, which has extended into the Linear Park. This we believe to be
zoned Z9, to preserve, provide and improve recreational amenity and open
space. We as the local community use this space regularly and we object to it
being removed from our use for the many years of this development

Size of the Excavation and support for underground carpark

We are concerned that the excavation that will be required for the foundations
of the new building and for a 2 storey underground carpark and a lower plant
room and attenuation tank will have a detrimental impact on the structures and
foundations on the residential houses on the South Circular Road adjacent to the
site. The impact of the excavation work should be clarified and adequate
measures requested to ensure the protection of the structural integrity of our
home and those of our neighbours.

Considerations requested should this development be allowed.

Without prejudice to the objections raised elsewhere in this submission, we

request that in the event of a grant of permission that the following conditions
be attached to its decision: -

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To mitigate against the shadow and light reduction impact:

In order to mitigate on the impact of the light and shadowing impact on our
home, we request that the development be moved back at least 12.5m from the
western boundary of the site. This would place the building at the same
distance from our houses as the Private Hospital that was once planned for this
area of the site, and which was substantially smaller in mass than this proposed
As stated above, we also request a full light survey, covering all times of the
year as part of this development, as the impact of the proposed development has
not been carried out for all daylight times during all four seasons. We request
that a proper all-year review of the shadow castings be taken to show the impact
on our home and that of our neighbours

To mitigate against the issue of overlooking:

We would ask in the event of a grant of permission that access to the proposed
balconies be removed by way of condition. We would also ask for a condition
that glazed barriers be placed along the front and sides of these balconies, and
that the windows in the western elevation be glazed in obscured glass to a
height of 2m to prevent overlooking of our residence and those of our
neighbours. In addition, we would request that this building be set-back by a
minimum of 12.5 meters to mitigate this overlooking impact.

To mitigate against the abrupt transition.

There is a screen of mature trees behind the existing Hospital wall on the South
Circular Road which has been a constant feature/amenity in the area for the past
30 years at least. We would like to retain this feature because of their
importance as a feature of the areas streetscape and because they will moderate
the visual impact of the development on our residence and act as a screen
between this proposed building and our existing house. Should permission be
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granted, we would request that the building be moved back an adequate distance
to retain these trees, or if this cannot be accommodated, we want trees of a
similar height and density to replace them (e.g. Silver Birch/ Willows). This
will provide a softening between the materials and height of the new building
and our existing red-brick houses in the Residential Neighbourhood,
Conservation Area Zone Z2. We request that the trees be kept especially during
the period of construction, when they will help to reduce the impact of the
construction activity on our amenities, and that adequate measures be
implemented to ensure their protection.

Proposed Finish
We also request that the proposed stone finish on this building be replaced with
Red Brick to blend in with this Z2 Residential Conservation Area. We believe
that the stark contrast between the two different zones are not in compliance
with the aims of the Dublin City Development plans.

Traffic Management Plan:

It is vital that Dublin City Council request submissions of a Construction Traffic
Management Plan prior to the commencement of any form of development, and
to explain how these roads will cope with the Construction traffic in conjunction
with the normal daily use of this major thoroughfare. We note the plans in
Section of the engineering report to use Flagmen Flag Men will be
deployed by the Main Contractor at access and egress points into the site to
assist in the safe egress of construction vehicles from the site and their
integration onto the road network. There will be a requirement for the Flag
Men to be provided on a permanent basis for the duration of the works
regardless of traffic volumes or traffic movements. We request a review of the
planned operation of such disruption to the normal traffic on the route from the
Traffic Department of Dublin City Council. We request that the Head of Dublin
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City Council Traffic Department attend the oral hearing to explain how these
roads, built in the 18th and 19th Centuries will deal with this increased volume of
traffic, and this disruption to their planned flows. We also request the Head of
the National Ambulance Service to attend the oral hearing to explain how their
service will operate in practice during this development and in the future
operational phase.
If this development is allowed to go ahead, given the volume of construction
traffic that will be generated, we would ask that by order of special condition,
Dublin City Council be required to actively maintain the roads of this
neighbourhood for the duration of the construction. We know that pot-holes
can occur during times of such high heavy traffic and ask that the roads be
maintained at least every month.

To allow for Bicycle lanes and to comply with the Dublin City Development
We would contend that the hospital should be moved back from Western
boundary to allow for the bicycle lane within the boundaries of the site, as set
out in the Dublin City Development Plan Section 15.10.14 referring to Zone 15
sites which states With any development proposal on these lands,
consideration should be given to their potential to contribute to the development
of a strategic green network. This would be much safer for cyclists than that
proposed by the NPHDB in their submission, and it would not further constrain
emergency traffic accessing the St. James Hospital campus. It would also
adhere to the Dublin City Development Plans objective.

As we know in this community, there is significant strain on the on-street
parking during visiting hours of St. Jamess Adult Hospital. The total visitor
parking being considered on the site for the St. Jamess Adult Hospital together
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with the National Childrens Hospital is 1,131. This is being provided for the
total population of patients that will be treated at the two hospitals. Based on
current numbers, that would be in the region of 3,400 patients per day. This
level is totally inadequate for what will probably be the two busiest hospitals in
the country. It is an unacceptable solution for the parents, relatives and friends
of sick children and should not be allowed. There is no additional on-street
parking available in this built-up residential area. Please advise how this issue
will be addressed.

Aspergillus/Legionnaires Disease
We would like to know what specific mitigation actions are planned for the
safety of local residents as well as hospital patients for the extended duration of
this excavation work.

Vermin Control
We request that the matter of vermin control be addressed by the developer with
a view to constant monitoring in the local area. Standards should be put in place
in conjunction with the Environmental Health Service, and these should be
agreed with the local community before excavation commences. In addition,
any sightings identified locally should be addressed by the developer. This
should be monitored by Dublin City Council for the duration of this
development to ensure no risk to public health in the neighbourhood.

We also request that Dublin City Council be required to clean the leaves from
the South Circular Road, Kilmainham on a weekly basis during the autumn as
there will be an increased risk of vermin infestation due to this disruption

Sewage, flooding and Water provision

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We request that the relevant departments of Dublin City Council and

representatives of Irish Water attend the Oral Hearing to advise on the
resolution of issues regarding the treatment of sewage and the moving of the
Drimnagh Sewer, the risk of flooding at the entrance to the basement and
adequate water provision for this neighbourhood.

Working Hours
Without prejudice to the objections raised elsewhere in this submission, we
request that in the event of a grant of permission that the following conditions
be attached to its decision: We do not want work to commence before 8.00a.m during the week and we
wish it to finish at 6:00pm. Ideally, there should be no work on Saturdays at the
site, however if there is then we do not want work to commence before 9.00a.m
on Saturday mornings and request that it finish at 1:00pm. No work at all
should be permitted on Sundays, public or bank holidays.

Request for Understanding of the support for underground carpark

We request an understanding of the supporting structures required for the

underground facilities. Will supporting structures be required under the South
Circular Road as the plans bring the buildings and excavation site right to the
boundary of the site - therefore any supporting structures may be under the road.
Can Dublin City Council confirm that they are in support of this plan and
confirm who will be responsible for the maintenance of the road should any
subsidence occur as a result of this work. We would also like confirmation that
no supports will come under our property.

Noise and Dirt:

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We would request that Dublin City Council control the dirt and noise pollution
that will result from this construction and ensure that this is kept to an
acceptable level for the local residents. The regulation of these activities should
be incorporated in a Construction Management Plan. A key objective of any
such plan should be to minimise the impact of the construction project on the
amenities of the neighbouring residents through the imposition of controls on
noise/dust emissions etc.

The submission by the NPHDB recognised that dust will be an issue for local
residents, (Chapter of EIS). Therefore we request that the developer
clean the windows of our property (@21.9m from the construction site) weekly
for the duration of the build.

We request additional information regarding the noise that will be caused by the
helicopter landing and request this to be reviewed by the Environmental
Protection Agency to ensure the safety of our family members.

Issues re the Draft Site Capacity:

We note that there is inadequate expansion capacity for this hospital, to allow it
to last for the next 100 years. The expansion space identified will use up the
only green space at ground level. We consider this to be inappropriate for the
National Childrens Hospital
We note the future development plans included in this document relating to the
development of St. Jamess Hospital. We question the correctness of building
the National Childrens Hospital in a constrained site that will be a construction
site for many years to come. The size of the proposed development for St.
Jamess Adult Hospital, identified as part of this submission is indeed
staggering. It will lead to several years of construction activity, and based on
the lorry movements planned for this phase, the level of construction traffic that
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will be generated and the resultant pollution around this site will be immense.
We do not consider this a suitable environment for sick children. As a result
planning permission for the National Childrens Hospital should not be granted
for this site.

Finally, we are very concerned that if the project as outlined goes ahead, that is
will not be achievable in the expected timeframes and that the costs of same will
overrun significantly. We are concerned that the costs as identified to date do
not represent good value for money given the extent of the demolition and
excavation required. We request that the proposal be reviewed by the Oireachtas
Committee of Public Accounts to ensure that it does provide the best value for
taxpayers money. We need to ensure that we select the most appropriate
location for the welfare of future generations of Irish Children, including the
children of Northern Ireland who will be treated at the All Ireland Childrens
Heart Surgery Unit in the National Childrens Hospital, while at the same time
ensuring a best in class hospital for the treatment of Adults at the St Jamess
Hospital Campus.

Yours sincerely,

Joe Ruane & Mary Kearney

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