2 nd October 2015 Prepared by Cunnane Stratton Reynolds for Jack and Jill Foundation CUNNANE STRATTON REYNOLDS Submission on behalf of The Jack and Jill Foundation Ltd In relation to Proposed National Children’s Hospital at St James’s Hospital, Dublin 8
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2nd October 2015
Prepared by Cunnane Stratton Reynolds
for
Jack and Jill Foundation
CUNNANE STRATTON REYNOLDS
Submission
on behalf of
The Jack and Jill Foundation Ltd In relation to
Proposed National Children’s Hospital at St
James’s Hospital, Dublin 8
.
CONTENTS
Executive Summary
1.0 Introduction
2.0 Who are the Jack and Jill Foundation?
3.0 What is their interest in this Planning Application?
4.0 The Proposed Development
5.0 Comments on the Application
6.0 Comments on the Site Location
7.0 Consideration of Alternatives Sites
8.0 Assessment Against Planning Policy
9.0 Traffic, Access and Transport
10.0 Water, Waste Water and Drainage
11.0 Flooding
12.0 Landscape and Visual Impact
13.0 Noise and Vibration
14.0 Air Quality
15.0 Future Expansion Capacity
16.0 Other Concerns
Appendices
Appendix 1: Traffic, Access and Transport Report by Traffic Insights
Appendix 2: Observations on Drainage, Water Supply, Flood Risk Proposals &
Outline Management Plan
Appendix 3: Comment on the Landscape and Visual Impact Assessment and Related
Aspects of the Planning Application for the Proposed National
Children’s Hospital by Cunnane Stratton Reynolds
Appendix 4: Review of the Assessment of Noise and Vibration relating to the
Proposed National Children's Hospital by ICAN Acoustics
Appendix 5: Air Quality Impact Assessment by TMS Environment Ltd
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Executive Summary
This submission has been prepared by Cunnane Stratton Reynolds on behalf of the Jack and Jill Foundation,
against the proposed development of a new children’s hospital at St James’s Hospital. Our client firmly
believes that the proposed site is fundamentally the wrong location for a national children’s hospital. We also
believe there are significant and irredeemable flaws within the process followed by the applicant which has
resulted in an underestimation of the potential impacts of the proposed development.
We believe that:
The statutory notice is inaccurate and that the application should be invalidated.
The consideration of alternatives failed to give proper consideration to the planning and
environmental impacts of the alternative sites, and that the process lacks the transparency and clear
rationale one expects in the consideration of alternatives within the EIA process.
The proposal is contrary to the Dublin City Development Plan 2011 - 2017 in relation to height, plot
ratio, site coverage, the removal of traffic from the city centre and the provision of adequate parking;
The assessment of a number of the environmental impacts within the EIA use inappropriate
methodologies which are not in accordance with best practice, resulting in an underestimation of the
potential impacts of the proposed development.
We have considered the impacts of the proposed development in relation to:
Traffic, Access and Transport;
Water, Wastewater and Drainage;
Flood Risk;
Landscape and Visual Impact;
Noise and Vibration; and,
Air Quality.
Traffic, Access and Transport;
Serious deficiencies in relation to the supporting rationale and robustness of the transport assessment
undertaken have been identified. Amongst the most significant concerns are:
The user needs (hospital patients; visitors and staff) in relation to car parking.
Additional travel needs of staff will not be met by mobility management proposed.
The proposed scheme has an excessive dependency on future delivery of uncommitted public
transport schemes such as DART Underground and Lucan Luas line to accommodate staff travel.
Public transport is not a viable alternative for the various user groups.
The applicant has not demonstrated there is sufficient reserve capacity on the public transport
network (LUAS Red Line in particular) to cater for additional passengers.
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Despite traffic congestion on the local road network and arising from the hospital’s national function
the proposal is highly car dependant.
Demand for car parking is significantly underestimated.
Supplemental parking analysis/surveys undertaken by this third party and review of assumptions used
by the applicant indicate;
o Patient/visitor car parking demand to exceed capacity for potentially up to 10 hours per day.
o Elevated parking changes of up to €5.10 per hour are anticipated.
o Significant overspill parking is envisaged (conservatively estimated at potentially up to 260
cars)
o Parking control measures will have limited effectiveness is managing overspill patient/visitor
car parking demand.
o Increased walking distances, and reduced use satisfaction levels for patients and visitors will
result.
The proposed car parking does not comply with parking requirements for hospitals set out in the
Dublin City Development Plan 2011 – 2017.
The feasibility of transferring 3,000 staff from the other hospitals has not been demonstrated.
The transport assessment undertaken by the applicants does not accord with best practice (the
NRA’s Traffic and Transport Assessment Guidelines May 2014).
Key stages in the transport assessment (trip generation, modal spilt, assessment years, and time
periods, traffic distribution, and assignment and modelling for future traffic impacts) lack the required
level of robustness.
Impaired accessibility by car, bus and emergency service vehicles is anticipated. There is significant
levels of peak period queuing and delays experienced on the local road network.
The suitability of Mount Brown as a major access route to the proposed hospital by patients, visitors
and staff has not been demonstrated.
The Road Safety Audit considers only the site interface with the surrounding road network and not
internal operations.
Water, Wastewater and Drainage;
Our main concerns in relation to water, wastewater and drainage are:
There is insufficient drainage capacity in the realigned Drimnagh Sewer which will surcharge under a
1 in 2 year storm event;
Flow velocities within sections of the Drimnagh Sewer exceed 3m/s and will result in scouring of the
pipe;
There is no attenuation volume calculations included with this application.
Surface water run-off rate has been limited to 2 litres/second per hectare. However in recent years it
has been Dublin City Council’s policy to limit run off to 2 litres/second regardless of site area. It is
unclear if this requirement has been met.
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It is difficult to assess the impact of surface water flows to the Drimnagh Sewer as no information on
flows has been presented.
There is no allowance for future expansion in the surface water system design.
There is insufficient detail on water supply for the site, and no allowance for future expansion in the
water system design.
The Development Impact Assessment is contradictory as it is suggested that the proposed
development will not impact on existing drainage but yet increase in flood volumes and new flooding
are identified within the system.
The increased foul drainage load on the system (from the new hospital) has not been assessed.
The Outline Construction Management Plan is lacking in detail in a number of important aspects:
o No detail on parking provision for construction operatives.
o Image given of proposed demountable hoarding system does not represent a 4m high
hoarding, as purported.
o No specific details on proposed ‘Fire Watch Regime’.
o No specific details on wheel wash and road sweeper provisions.
o No specific details on proposed ground dewatering.
Flood Risk;
We believe that one of the main entrances to the hospital (the Mount Brown entrance) will flood on a regular
occurrence.
The assessment undertaken by the applicant has also failed to take account of the increased flood risk to the
surrounding area if this development proceeds.
Landscape and Visual Impact;
Our main concerns in relation to the landscape and visual impact are:
The inaccurate descriptions of the height of the building as 34.95 metres to ridge level;
The proposed development at 34.95 metres (or greater) contravenes Dublin City Council’s height
policy for the area;
The substantial massing and volume of the proposed development, as indicated by the plot ratio and
site coverage results in a visually intrusive development;
The plot ratio and site coverage have been artificially reduced due to the fact the application boundary
(red line of the application site) has been increased to include areas of the linear park along the Luas
line and parts of South Circular Road which in our view should not be included;
The development would result in a very abrupt and pronounced transition in building scale and design
between the site and the surrounding urban area contrary to planning policy;
The proposed development will have a negative visual impact on the surrounding area, which is not
offset by the modern, light architectural style.
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The inclusion of the private hospital, the planning permission for which has now expired, within the
photomontages, is misleading and contrary to the recognised and industry accepted method for
conducting a Landscape and Visual Impact Assessment (LVIA). Incorporation of the private hospital
represents a wholly invalid alternative baseline to the existing environment and an irrelevant future
scenario to the proposed NCH;
Noise and Vibration;
Our main concerns in relation to noise and vibration are:
The methodology for consideration of the construction noise impacts are inappropriate for a long term
construction projection in a constricted space;
Selective adherence to BS5228, ignoring areas which would pose a problem to the development
Inadequate assessment of vibrations with no examples of calculated vibration provided. It is also
evident that a basic generic third party calculation method is being considered and one that does not
take account of the actual ground strata at the location.
Considering the proximity of the proposed ground works, 10m from residential properties and 7.5m
from clinical areas, we would have expected a more robust prediction method and a vibration risk
assessment.
Inadequate assessment of the impact of noise intrusion from external sources on the naturally
ventilated hospital rooms, which are inherently acoustically weak.
Impact of noise arising from the proposed helipad on both the patients and local residents has been
grossly underestimated, and the applicant has only assessed one type of aircraft (AW-139) rather
than a larger/louder Sikorsky S92.
There is a gross underestimation of the duration of an actual Medevac event.
Any use of the helipad will most likely give rise to sleep disturbance at night.
No attempt to establish if vibration thresholds can be met at vibration sensitive locations (such as
operating theatres or imaging locations).
The number of helicopter take offs and landings is underestimated for a national hospital given known
movements for UCHG in Galway.
Air Quality;
Our main concerns in relation to air quality are:
The assessment fails to comply with best practice through the use of out of date or inappropriate
baseline and metrological data, in particular failure to consider the impact of traffic on the air
quality of the area;
A simple set of baseline air quality data that is representative of the wider Dublin area (including St
James’s Hospital, Tallaght and Blanchardstown) rather than the specific location where the
development is proposed has been used;
Baseline air quality is poorer in the proposed location than almost anywhere outside the city
centre. There is therefore limited assimilative capacity available in the receiving environment to
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accommodate any significant developments and especially developments as significant as the
proposed children’s hospital and future maternity hospital.
Failure to consider the construction impacts, beyond traffic movements, on the nearby residential
properties and more importantly on the existing adult hospital;
There are significant risks associated with the emission of hazardous substances during
construction that are not recognised;
Inadequate management plan for controlling the spread of Aspergillosis, particularly in relation to
the adult’s hospital which is to remain fully operational;
Incomplete on site investigations which have prevented the preparation of complete management
plans for the construction stage;
The impact on air quality during construction of Heavy and Light Goods Vehicles (HGV and LGV)
has not been considered;
Inappropriate use of the NRA “Guidelines for the Treatment of Air Quality During the Planning and
Construction of Major Road Schemes” as the methodology for assessing the construction impacts
of the scheme;
The proposed development will have a significant impact on air quality in the area once operational
due to the dramatic increase in emissions from the energy centre. Emissions to atmosphere from
the Energy Centre could be significantly higher (potentially 300%) if the use of diesel oil as the
primary fuel rather than natural gas is required as highlighted, but not evaluated, in the EIS;
WHO Guidelines have not been formally considered in the EIS which is a major concern given the
National Children’s Hospital will cater for sick children with compromised immune systems and
limited ability to cope with additional stresses such as air pollution.
We have major concerns about the ability of the site to accommodate future expansion including the maternity
hospital, without future damage to the environment and assessments of the area.
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1.0 Introduction
1.1 Cunnane Stratton Reynolds have been appointed by the Jack and Jill Foundation, of Johnstown
Manor, Johnstown, Naas, Co Kildare, to prepare a submission on the proposed development of a
National Children’s Hospital at St James’s Hospital, Dublin 8.
1.2 This submission confines itself to the proposal for the main children’s hospital on the St James’s site.
We have no comments to make in relation to the proposed satellite centres at Tallaght Hospital and
Connolly Hospital, beyond how they relate to the main hospital at St James’s.
1.3 We would state at the outset that our client accepts entirely and fully supports the need for a new
national children’s hospital. There is no denying that the existing hospitals at Crumlin, Temple Street
and Tallaght are out of date and no longer ‘fit for purpose’ in relation to the demands of modern
medical care for children.
1.4 Notwithstanding their support in principle for a new children’s hospital, our client is concerned about
the adequacy of this current proposal in terms of meeting the needs of children now and into the
future.
1.5 The new children’s hospital represents the largest investment by the State in paediatric medical care
since its foundation. It is a ‘once in a generation’ opportunity to completely overhaul how we as a
country care for our sickest children now and well into the future. We all therefore have a moral and
social obligation to ensure that the proposed development is ‘fit for purpose’ and that children’s needs
which are the primary concern, are best met by the proposed development.
1.6 The consideration of the application before the Board exists within an interface between planning,
technical requirements, and medical best practice. We recognise that it is not for the Board to
question the political decisions which have resulted in this application and therefore we will not be
discussing such issues. However we do intend to discuss in sufficient detail the planning and
technical concerns linked to what we perceive to be the deficiencies from a medical perspective.
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2.0 Who are the Jack and Jill Foundation?
2.1 The Jack and Jill Foundation, is a registered children’s charity. It was founded in 1997 by Jonathan
Irwin and his wife, Senator Mary Ann O’Brien based on their own experience caring for their son Jack
at home until he passed away in December 1997, aged 22 months.
2.2 Over the past 18 years, Jack & Jill has supported over 1,900 children (from birth to 4 years old) with
brain damage who suffer severe intellectual and physical trauma. The Foundation also provides end
of life care for all children who require it from birth to 4 years of age.
2.3 The Jack & Jill homecare plan is designed around the whole family, never forgetting the siblings.
There is no waiting list. The nurses provide out of hours service for the families that need it, 365 days
a year, in every community and every walk of life. The nationwide service includes home visits and
care, advice, information, lobbying and bereavement support.
2.4 The children cared for by the Jack and Jill Foundation represent some of Ireland’s sickest children.
These children and their families often spend much of their short lives either in hospital, or attending
regular appointments with specialists in the current national children’s hospitals at Temple Street or
Our Lady’s Hospital, Crumlin. The Jack and Jill Foundation, is therefore uniquely positioned to
understand the needs and requirements of Ireland’s sickest children, and just as importantly their
families, in terms of any new proposed hospital. The Board of the Jack and Jill Foundation is made up
of a number of people with medical qualifications and experience such as Dr Fin Breatnach, former
Head of Oncology at Our Lady’s Hospital, Crumlin.
2.5 Our client feels obliged to highlight their very genuine, and we believe well founded concerns, and if
the Board decides to refuse, grant or grant with modification this proposal, the Jack and Jill
Foundation will fully respect that decision.
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3.0 What is their interest in this Planning Application?
3.1 The Jack and Jill Foundation, as one of the State’s leading children’s charity catering to Ireland’s
sickest children, wish to ensure that this ‘once in a generation’ opportunity to provide a state of the art
children’s hospital, fully meets the needs of Ireland’s children.
3.2 Our client has grave concerns about the suitability of the site in terms of the location and access to
the main children’s hospital at St James’s, its capacity for future expansion, and the absence of a
maternity hospital from the proposal. It is our belief that the St James’s site is unsuitable for the
proposed use and that the new children’s hospital will fail to adequately meet the requirements of
Ireland’s sickest children.
3.3 Our client’s primary concerns can be summarised as follows:
Inappropriate site location;
Inadequate consideration of alternative sites;
Fundamental flaws in the environmental assessment of the proposal across a number of
topics;
Absence of a maternity hospital;
Inadequate expansion space.
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4.0 The Proposed Development
4.1 The National Paediatric Hospital Development Board is seeking permission for the development of:
473 no. bed children’s hospital (up to 118,113 sq.m) at St James’s Hospital;
53 no. bed family accommodation unit (up to 4,354 sq.m) at St James’s Hospital;
Children’s Research and Innovation Centre (up to 2,971 sq.m) at St James’s Hospital;
Construction compound at Davitt Road, Drimnagh, Dublin 12;
Two satellite centres at Tallaght Hospital and Connolly Hospital providing rapid access urgent
care and outpatient services.
4.2 The new children’s hospital at St James’s Hospital will include:
380 no. inpatient beds (of which 60 no. are critical care beds);