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

Your Ref:

EmerCasey 4 McDowell Avenue Ceannt Fort Mount Brown Dublin 8

8th October 2015

Dear Madam,

Re: Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at St James' Hospital Campus, Satellite Centres at Tallaght & Connolly Hospitals and Construction Compound at Davitt Road, Dublin.

An Bord Pleanala 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 Pleanrua 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,

I Iife lA~ S\o ~ eran Somers

Executive Officer Direct Line:O 1 ~873 7107

Encls.

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AN BORD PLEANALA TIME t3 0Y BY H~

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The Secretary, An Bord Pleam11a, 64 Marlborough Street, Dublin 1.

October 15\ 2015

EmerCasey 4, Me Dowell Avenue

Ceannt Fort Mount Brown

Dublin 8.

AN BORD PLEfNALA Received: 'l./ IOJ S Fee. cSO Gat;It Receipt No: B l~ \\41:

Re: Planning Application Reference PL29N.PA0043. Health Infrastructure Development comprising National Paediatric

Hospital,lnnovation Centre and Family Accommodation Unit at St. James' Hospital Campus, Satellite Centres at Tallaght and Connolly and Construction Compound at Davitt Road, Dublin.

To whom it may concern,

I write in relation to the above planning application to detail the concerns that I have about the proposed development. I enclose cash to the value of Fifty Euro to An Bord Pleanala in respect of the prescribed fee for making a submission outlining my objections to the application.

Yours Sincerely,

Emer Casey.

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Objections: 1. The Description of the Development:

1.1 Project Development

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Members of my family have lived beside St. James' Hospital for almost 100 years and like them I chose to live here too. The hospital has always worked in harmony with the residents, and indeed in other constructions, has taken into consideration the visual aspect of the neighbouring properties and has sought to blend with them, especially the construction of the Private Clinic and the Speech and language facility, which is to be applauded. Furthermore I would like to state that I am in favour of a project that will bring together three existing children's hospitals, that of Our Lady's Children's Hospital Crumlin, Temple Street Children's University Hospital and the National Children's Hospital, already established at Tallaght, under one roof as it benefits the entire country and most importantly the children themselves.

However as stated in the New Children's Hospital Report submitted on 19/10/2012

(New Children's Hospital: Further assessment of planning issues in relation to proposed sites Report submitted to Dr. James Reilly T.O., Minister for Health, by Simon Clear and John Martin) The Children's Hospital is a major statement by the Government an behalf of the people, setting out a new care structure for children. The new facility will be designed to provide excellence of service into the future for a period of up to 100 years. In strategic national planning terms it is important that a long-term perspective be held on the future suitability for service, adequacy of facilities and capability for change. Change may be technological, collaborative or spatial in nature. It Is essential that the new facility be "future proofed" and that there be significant room for manoeuvre, including spatially, in any new hospital campus arrangement. Therefore, In spatial planning terms, it would be preferable to find a site on a campus that has room to accommodate expansion of building laterally and additional new buildings over time comfortably within the confines of the planning unit. Filling the campus space available from the outset is not recommended for strategic planning reasons including future proofing. 1.2 Site unsuitability

The site at St. James' hospital is an enclosed, bounded site with little room for expansion, manoeuvre or 'future proofing'. Lateral expansion if allowed to go ahead, will not allow for any lateral expansion in the future especially with St. James' own plans for expansion. The open spaces as calculated in the planning submittal appear to take in the LUAS track/park which is not in the ownership of St. James' hospital. If Phase 2 gets constructed the open space of the Meadow Garden will disappear.

The planning application for a maternity hospital which I feel is part and parcel of this development has not been sought with this application. How can a twenty first century maternity hospital fit this already unsuitable site, with no room for expansion? It was stated

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that the Coombe Hospital would be locating here but there has been nothing to prove that this is the case, nor is there any room for this relocation. The St. James' Hospital site is not fit to be the site for a twenty first century Children's Hospital and the sick children of this country deserve better.

2. Signage

The sign age for the New Children's Hospital declares as Gaeilge" Failte chuig suiomh oispideal nua na leanai". This is very misleading as it is not the 'suiomh' but the 'suiomh beartaithe' or proposed site. I submit that the sign should be changed to avoid any more confusion. Furthermore, the by-line for the hospital that of 'Working Together for our Children' is also a misnomer as the residents living beside the proposed site ofthe Children's Research and Innovation centre had no consultation with the applicant, as the first time the drawings were ever revealed publicly was on Thursday August th e application on Monday, lOth of August. These drawings were p es~Nd3nraR,r!efaefalttALA accompli' rather than consultation. TIME BY ___ -t

3. Parking 0 2 OCT 2015 3.1. Conflicting statements regarding parking in Chapter 6 LTRDATED FROM

--- --- -1 PL Chapter 6 of the Technical Summary of the EIS states that ''The~~IMA01r.lJ1 services on the StJames's Hospital campus will attract increased trips (staff and patients) to the hospital campus". However, in the same section of Chapter 6 the EIS also states that "the car parking strategy does not include increasing the overall number of parking spaces provided on campus following the completion ofthe 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". I fail to understand how these two statements concur. The predominant method of transport in this country is by car {74% of journeys) according to the National Transport Survey 2014, (CSO, 2014). If there will be increased trips to StJames's Hospital due to the new services, and the predominant method of transport in this country is by car but there will be less car parking spaces provided on the campus than there are currently, then I implore the developer to identify where exactly these additional cars will go? I feel that in an emergency distressed parents will not bring their sick or injured child by bus or luas to the hospital. They will drive as quickly as possible, straight to the hospital and what happens when there are no places to park?

3.2 lnsuf/lclent Parking Spaces In the Locality The availability of parking spaces in this area is already dire with many cars used by hospital staff and visitors already being parked in residential areas surrounding the site. My husband works shift-work and on five occasions in the past two months, when people are supposedly on holidays and traffic lighter than in mid-winter, he has been blocked in and has had to get a taxi to work; he is not alone. Section 2. Table 2.2 of the Design Report states that there will be 48 disabled Parking Spaces and 952 car parking spaces totalling 1000 car parking

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spaces. However with the demolition of part of the site to prepare for the New Children's Hospital, 540 current spaces will disappear, and only 420 new car parking spaces will be available. Is this really enough for a National Children's Hospital? 90% of sick children travel to hospital by car (Families of Sick Children for Safe Access' in association with The New Children's Hospital Alliance, fact sheet). 1.5 car parking spaces is being provided. This is surely not enough and again shows the congested, constrained site of St. James' Hospital.

The above points further strengthen my opinion that this is not the correct location for the new children's hospital.

4. Traffic

4.1 Road Surface Wear Traffic congestion in the area is quite severe. With additional traffic generated by both the construction works and the new development once in operation I fear the road capacity will be pushed to the limit. The extra congestion on the road will increase the amount and regularity of maintenance works to rectify wear and tear on the road surface. This will further increase congestion on the road as the one-way system in operation in Dublin limits the detour possibilities, which will increase the travel time to the hospital and travel time for commuters into the city. I ask the developer to outline to Dublin City Council how many extra vehicles will be on the road and identify the extra cost on road maintenance and inconvenience that this will cause.

4.2 Increased traffic congestion As stated in Chapter 6 of the El5 there are estimates for the lorry movements that will travel to the junction of SCR/Bulfin Road/Suir Road during each of the 3 phases of construction. Per the information provided, the volume of trucks will be in the region of 520 per day for the first 4 months, 460 per day for the next 2 months, 690 per day for the next 18 months and 570 per day for the next 21 months. The total patients attending St. James' Hospital per their annual report is 400,000 annually. The projected figures for the New Children's Hospital is 368,438. Combined, this is in excess of three quarters of a million people travelling to and from the hospital not including staff, visitors nor the significant increase in patient treatment proposed as a result of St. James' Hospital expansion as set out in the Master Plan for St. James' hospital nor the relocation of the maternity hospital. In the planning application it is stated that there will be no through traffic between the New Children's Hospital and St. James' hospital except buses and ambulances.

The consequence of this is that all traffic for Dublin South will have to exit St. James' Hospital and turn onto an already jam-packed Mount Brown, thus urth--N-A ..... LA _ _, co.nge~tion in the area. Coupled with the proposed new routing forA:_!Sffi~rR~Ways, thts wtll have a huge knock on effect, not only for the roads aro iill~et-ton-----t but also for the city in general. 0 1 OCi {Q\S 4.3 Travel Times

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75% of children attending hospital for specialist consultant care come from outside the MSO {Families of Sick Children for Safe Access' in association with The New Children's Hospital Alliance, fact sheet). They account for half of day cases and one third of all admissions. These are the sickest children of all and yet these are the children that will be most inconvenienced if the New Children's Hospital is built in James'. Emergency access is also compromised for children coming by ambulance as the difference of 20 minutes in traffic can be the difference between life and death. This will surely interfere with the functioning of an already busy adult hospital.

According to Chapter 6 of the EIS "As part of the transport appraisal, journey time surveys were carried out by MHC Traffic Ltd. between the 12th and 14th of May 2015 between St James's Hospital campus to both the N4 and N7 interchanges with the MSO Motorway. May is considered a 'neutral' month and recorded traffic data is not influenced by school holidays during the summer period or by Christmas/ weather conditions during the winter period." There were three runs of each journey in order to calculate the average journey travel time. However, I fail to see how recording the traffic on a "neutral" month is representative of the full range of traffic conditions which preside in the area throughout the year. Surely, there should be recording of traffic data during school times, bad weather conditions, and Christmas traffic in order to give a fully representative estimate of what the maximum travel times could be? I find that the method of recording just three runs within 3 consecutive days is not sufficient to identify the full range of traffic conditions which prevail in this area and would implore the developer to collect further data at varying times of year including the Christmas season and school peak times.

4.4 Transport alternatives unsuitable

The Red Line luas which runs through the hospital is already full to capacity at peak times and 'standing room only' at off peak times. As passengers are encouraged to use the park and ride facility at the Red Cow stop, especially when concerts and matches in Croke Park are taking place, this is not a viable option for use by a parent with a sick child. Children are sick at all times, not just off peak times.

5. Public Participation

As my address shows I am a resident of Me Dowell Avenue, Ceannt Fort and will directly be effected by the construction of the Children's Innovation and Research Centre, and the new proposed entrance at Mount Brown behind the houses at Me Dowell Avenue. As stated in section 2, the plans for this centre seem to have been hastily drawn together with no consultation with the residents directly affected. I feel I have been dismissed, disrespected and treated with distain by the development board. There was no opportunity for ''public participation". A Pamphlet through our door on the 20th June 2015, stated that there would be a drop in session in F2 Centre Reuben Street on June 25th 201 eJirst.time.w saw Presentation Boards and the proposed Design. No drawin wer.etavafi8'B~ W~S~th'eA design of the Children's Research and Innovation Centre north fl~Jfv.A,t.omm.o~l~tion---t unit. 0 2 OCT 2015

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The legislation which requires developers to complete an EIS for projects such as this comes from the European Union under the Environmental Impact Assessment Directive (2003/35/EC). This Directive consistently stresses the importance of "public-participation in respect of the drawing up of certain plans and programmes relating to the environment" and was derived from the Arhus Convention. The Directive clearly states that "Among the objectives of the Arhus Convention is the desire to guarantee rights of public participation in decision-making in environmental matters in order to contribute to the protection of the right to live in an environment which is adequate for personal health and wellbeing." The Directive states that "Effective public participation in the taking of decisions enables the public to express, and the decision-maker to take account of, opinions and concerns which may be relevant to those decisions, thereby increasing the accountability and transparency of the decision-making process and contributing to public awareness of environmental issues and support for the decisions taken." However, I feel that in effective public participation has not been achieved so far. The local residents which surround the development who will be impacted both during the construction and operational phases of the development should have been approached and their "opinions and concerns which may be relevant" to the decisions concerning the development taken into consideration during the decision making process. In particular those local residents whose dwellings are located less than 1.98 metres from the development.

6. Historical Area.

6.1 Historical Importance & Impact on Tourism

This is an ancient and historic site with strong links to the 1916 rising, the centenary of which, Dublin and indeed Ceannt Fort, will be celebrating in a few months. No consideration has been given to incorporating the already existing fa~ade which fronts onto James' Street nor in retaining some of this historic, if derelict, building into the plans. This building has been referred to as "an old school house" in the proposed plans but this is incorrect as it was a bake house during the rising, and part of the City Workhouse. (John Rocque's Dublin. A Guide to the Georgian City, Calm Lennon and John Montague, p.73) The old school house was across the road at the top of the 'Forty Steps' and was run by a school teacher named Mr Kelly. Some ofthe older residents attended this school in the 1920's/30's.

The old wall of the 'South Dublin Union' and also referred on the map produced by John Roque of Dublin, in 1756-1762, shows this wall to be an historic wall, delineating the property of the workhouse, now St. James' Hospital, from 'Cut Throat Alley' , where the residential houses of Me Dowell Avenue now stand. This area around St. James's Hospital, The Guinness Store house, Kilmainham Gaol and IMMA are marketed abroad as an historic tourist trail in Dublin bringing financial benefits to the area. Due to the large nature of the development, traffic congestion caused by the construction vehicles will impact on the movement of tourists and visitors to the area from all directions. This wi ~IDL~.a negative impact up local businesses and attractions for the durati n oAtlie:ConstrlitkfO~NALA phase, in an already underprivileged area. TIME BY ___ --t

6.2 Consideration of Buffer Zone

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In the EIS Non-Technical Statement 7.12.2, it declares that 111t is intended that a Childrens' Research and Innovation Centre would be provided on the southern side of James' Street, at its western end, adjacent to the Trinity College buildings associated with St. James' Hospital. This would involve the construction of a building that is portly adjacent to James' Street and would be partly below ground level. This building would be adjacent to a Protected Structure known as the Haughton Institute {RPS ref. 4011{o)) and the below ground element would be close to the Protected Structure. The above ground port of the proposed building would be at a sufficient distance that it would not affect the essential character of the Protected Structure. The construction of the below ground element would have the potential to damage the Protected Structure, though measures would be put in place to ensure that this does not occur." If the construction of the below ground element would have the potential to damage the Haughton Institute, then the same logic should apply to the nearby dwellings. The dwellings at Ceannt Fort which are "one of Dublin's first social housing projects" may not be protected structures yet, but they are still an important part of our capital's social history, which should be protected for future generations. According to Page 49 of Chapter 16 of the EIS there will be "no direct impact" on the built heritage of Ceannt Fort. However, I disagree; the vibrations and digging which will occur Jess than Sm to the gable walls of some of the houses on McDowell Avenue has the potential to damage the dwellings considerably. I would ask that there are some mitigation measures put in place to ensure that there is no damage caused to these buildings. I would ask that the development be moved at least 10m away from the boundary wall, or at the very least the same "sufficient distance" which separates the development from the Protected Structure.

According to page 49 of Chapter 16 of the EIS regarding the views within the area "There would be a moderate impact arising from this new development. It should be stressed, however, that this is not an Architectural Conservation Area, nor is such designation proposed". Further stating that no mitigation is required. However, this estate is a residential conservation area, with the houses on Me Dowell Avenue being in a zone of Archaeological Interest on the current development plan, and surely this should owe it some protection from this development, perhaps in the form of a minimum distance buffer zone? Furthermore this area is zoned Z2 in the development plan the zoning objective for which is "to protect and/or improve the amenities of residential conservation areas" (page 11, Chapter 16). This includes Ceannt Fort, on the southern side of Mount Brown, which is bounded on the east, west and south by the campus of StJames's Hospital, lying to the east of the main site for the new children's hospital and to the west of the site proposed for the Children's Research and Innovation Centre. looking at planning maps of the development this residential conservation area Is surrounded at all sides by the development. This development does nothing to "protect and/or improve the amenities of residential conservation areas", it merely deleteriously impacts upon the surroundin~v.;.;is.ta .. s;.;a-.n .. d.__ _ __ -=:~--. wellbeing ofthe residents. How will the developer amend this? AN BORD PLEANALA

7. Height, Scale, Proximity to Residences and Subsidence.

7.1 Lack of Integration with Surrounding Buildings

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The Design Report Section 3.1 states 'The design of the building has been developed in response to the site context, the proposed integration with the surrounding buildings and the requirements of the brief. Looking at the plans, however, the proposed development is merely 1.89m from the existing boundary wall and Jess than Sm from the gable wall to 1, Me Dowell Avenue (4986mm, CR Ground Floor Plan, NPH-A-OCMA-DR-00-CR-1002), at a height of 32.19 m. The proposed basement is at least 15m in depth {NPH-A-OCMA-DR-XX-CR-3001-PROPOSED-SECTIONS). I fail to understand how this development is integrated with the surrounding buildings?

The houses in Ceannt Fort are zoned as Z2, under the current Dublin City Development Plan 2011-2017, with the houses on Me Dowell Avenue being also houses of Archaeological Interest, 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 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. Since the development of the CRIC is Jess than 2m from the existing boundary wall how can this be achieved? There is no break at all between our houses and the proposed 32.19 metre high building immediately to the boundary of the site. Since our houses are approximately 1.5 metres below the level of the site this structure will appear even more imposing on our skyline.

It offers no transition at all to our home, being at a distance of only 1.89m away, with no space for any landscaping or screening. Indeed the development of the Waste Management Centre offers no transition as the proposal is to build it adjacent to the boundary wall with a height of approx. 23.16m (NPH-A-OCMA-DR-XX-CR-2005-PROPOSED-ELEVATIONS-NORTH-AND-SOUTH), again leading to subsidence to our residences and a loss of light.

Page 13 of Chapter 13 of the EIS states that "The Children's Research and Innovation Centre is a modest building consistent with the prevailing height, nature and scale of existing and on-going development within this developed urban context". However, the height of the Children's Research and Innovation Centre is merely consistent with the height of the Trinity Centre for Health Sciences Building and not with the immediate vicinity of the dwellings of Ceannt Fort. I would suggest that (a) the large amenity area in front of the proposed building as shown in the architectural drawings be reduced somewhat in order to allow for sufficient transition from a building of such a high nature to appear somewhat integrated with the surrounding houses, or (b) the height ofthe building be reduced somewhat in order to be "consistent with the prevailing height, nature and scale of existing and on-going development" i.e. that of the houses immediately adjacent to it.

8. Human Health AN BORD PLEANALA

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I fear that the construction and the operation of the Waste Management Centre (Trinity Waste and Research Waste) will cause major subsidence issues to our homes. No conditioning survey was offered to the residents of Me Dowell Avenue and should be done so as a matter of urgency as our properties have a high risk of structural damage due to the proximity of the development. As already outlined the wall dividing St. James' Hospital and Me Dowell Avenue is an old one, but no survey has been carried out on either side to see if it can withstand the construction impacts such as vibrations and underground demolition.

No indication has been given to the nature of the waste which will be stored behind our houses. The plan says that it will be from the Trinity Centre and the Research and Innovation centre. I believe that information should have been included in the EIS which states the nature of the waste which will be stored in the centre? Is it hazardous or flammable in nature? What procedures are in place ifthere is an incident? What is the probably risk to our dwellings and our health in the event of an incident? I do not believe there was sufficient information included in the EIS. Given the proximity of our houses to this potential risk, I believe that there should be extra mitigation measures put in place.

A Gas Bottle Storage Area, Oil Tank and a 13m2 Attenuation Tank is also proposed directly behind the wall to our houses according to the Architectural Drawings of the CRIC in the Lower Ground Floor and the Ground Floor. These facilities have high risk potential and I cannot understand why they have been located so closely to the dwellings. Coupled with the unknown waste from Trinity and the Research Centre I feel our houses are at risk of a major incident either from chemical spill, flooding from the attenuation tank or fire/explosion from the gas bottle storage area. What proposals have the development put in place for evacuations and rehousing? Is this the ideal location on the campus for such facilities?

8.2 Infestation of vermin A major concern for me is the infestation of vermin which will arise if development of this application is granted. Rerouting sewers and basement constructions may cause vermin to invade both residences and the already existing adult hospital. This will cause a genuine health risk to public and patients, as these organisms are usually vectors for lethal diseases e.g. Weil's disease. I would like to know what plan the development board has in place to deal with this concern.

8.3 Loss of Light The development will also cause a loss of light to our properties. 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, natura/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 height and proximity of the CRIC building will have a negative impact o'\"tft'){~Ces PLEANALA around it and the quality of life of the residents. N ~ u TIME BY ___ _ In the EIS Statement, Chapter 13, Micro Climate the methodology was as fo ows: 0 2 QC1 ~Am

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The assessment of the impacts of the proposed development was prepared using the methodology set out in BRE 209, 'Site Layout Planning for Daylight and Sunlight: A Guide to Good Practice', Second Edition 2011, by P. J. Little/air. This is the non-statutory guide referred to in the Dublin City Council Development Plan 2011-2017, and sets out guidelines that are most commonly used in Ireland and the UK to assess the impacts of development on daylight and sunlight. It provides advisory numerical targets that represent good practice; however, the location specific characteristics must also be taken into account.' However, I disagree that the location specific characteristics were taken Into account in this situation, as no-one entered my back garden to take any such regard of sunlight unless you count one individual who looked over the wall into my property.

The guidelines merely "recommends that loss of sunlight should be checked for main living rooms of dwellings, and conservatories, if they have a window facing within 90 of due south. If the development wholly lies due north, then sunlight loss need not be analysed." However, the development does not lie wholly due north of these houses. In fact this development lies mainly to the East of the dwellings or more specifically East-North-East. Therefore, the sunlight loss to these properties very definitely needs to be analysed and has not been adequately assessed in this EIS. I would suggest a further investigation into the potential sunlight loss and would welcome any such specialist consultant to witness the already dwindling sunlight which reaches the rear of the properties of McDowell Avenue.

8.3.1 Vertical Sky Component As stated on page 4 of Chapter 13 of the EIS the "BRE 209 indicates that if the VSC can be maintained above 27%, then enough skylight should still reach the window of an existing building. If the resultant VSC is both less than 27% and less than 0.8 times its former value after the construction of the proposed development, occupants of the building will notice a reduction in skylight." On page 54 of Chapter 13 the EIS provides an analysis of sunlight to the rear of my own dwelling. The existing VSC was calculated at 23.4% ignoring any trees. After this development is completed the VSC should be 19.9% a reduction of 3.5%. However, neither the existing nor proposed VSC values reach the recommended target of 27%. 3.5% of a reduction in VSC may not effect a property which already reaches the recommended target. However, it will definitely be noticed in my own property and will severely diminish, what little sunlight we receive into our main living space in the kitchen particularly during the winter months. Furthermore, our gardens are so small, 4m 10cm x 4m 60cm approx., that any loss of light, although appearing slight, will have a huge impact on us and our ability to enjoy our only outdoor private area. We cherish what little sunlight we receive and even the slightest loss will have a significant negative impact on our greatest amenity, that of the sun. I would also mention that the height and aspect of the CRIC will also have a negative impact on our privacy as we will be overlooked. The photomontage No.29.2 shows the proposed CRIC building with at least 16 windows facing south over 2 floors. Our second bedroom and garden will be overlooked thus leading to a loss of privacy. I would also mention that the windows which face from the Children's Research and Innovation Centre onto our property will lead us to getting blinds on all the rear-facing windows of our property, leading to even more sunlight loss into our "lain.Jiving.spate..Asa , final point, the proposed VSC value is merely 0.05 away from failing to ~eaol\rth@ORD PLEANALA recommended target in the BRE 209. This is such a small value to prov tlTcltri:be pU:tp.enr v ___ --t

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passes the recommended guidelines, but could easily be achieved through simply rounding up throughout the calculations. I have found that the only solution to this problem is to push back the development from

the boundary wall to our properties. Enabling significant protection of the properties during construction and operational phases and protecting what little sunlight we receive into our minute gardens and rear rooms.

8.3.2 Annual Probable Sunlight Hours The EIS states on page 54 that Point is 15 is a north-east facing window. However this is incorrect; it is an East-North-East facing window and the development does not lie wholly due north of this property and thus does require calculation of sunlight hours as per the BRE 209. Once again the rear of the property does not achieve the recommended target of 25% of the APSH, receiving just 15.10% of the APSH. This means that property is already missing 143.8 probable sunlight hours and this development will mean that a further reduction of 9.5 hours. However, these calculations appear to be incorrect for the property as the paragraph relating to Sunlight on page 54 begins to refer to the calculations of Point 14 and not Point 15. I would like further clarity on whether this is a typo or that these are in fact the calculations for Point 14 and have been switched.

Furthermore the APSH for the property is under the recommended target of 5% between September 21st and March 21st, receiving just 4.27% or 52 hours of sunshine across 6 months. This will be reduced by another hours during the operational phase of the development.

The reductions in sunlight do not appear to have been taken into consideration in the early design stages ofthe development ofthe Children's Research and Innovation Centre. If a property does not reach the recommended target, surely "best practice" for this particular situation, is to prevent any further light loss? As the BRE 209 is a best practice guideline and states that "it provides advisory numerical targets that represent good practice; however, the location specific characteristics must also be taken into account". If the developer is using this document as guidelines for the development then I would suggest that he take the location specific characteristics into account for McDowell Avenue, in particular those properties which receive an already diminished supply of probable sunlight hours below the target threshold.

In conclusion, I believe that the concluding remark for Point 15 on page 56 of the EIS is wholly incorrect "For No. 4 McDowell Avenue specifically, the existing situation almost meets the recommended target, and the post construction situation is no different. The proposed development therefore will have no bearing on the quantity of sun on ground in the rear garden". As they have stated on pages 54 and 55 there will be a significantly different situation post construction. As what little sunlight Point 15 already receives will be further diminished and pushed below the recommended threshold for main living areas.

8.4 Light pollution AN BORD PLEANALA During the operational phase of this property I am concerned abouJtne\'lfgbt pollutioli\tt .... r ..... cx..,.m~-----t the windows ofthe Children's Research and Innovation Centre whicit will entw i"~o...the.rear bedroom and bathroom of my property. I would like to know what 11 easures ~e d~~~IJ#~i-

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has in place to ensure that there is minimal light pollution and excessive lighting which will enter my property during the construction and operational phases.

8.5 Noise pollution Noise during demolition and construction is also a matter of concern. Will construction take place during working hours or will Special licences be granted? As already stated some residents work shift and unsociable hours. Will they come home in the early mornings to the sounds of Kango hammers for twelve hours? Will construction take place during weekends? This would be totally unbearable. The proposed new pedestrian entrance at Mount Brown to the rear of Me Dowell Avenue is also of concern as it increases the risk of break ins and anti-social behaviour. I would like to know what measures will be put in place to minimize anti-social behaviour, particularly along this pedestrian entrance.

9. Anti-Social Behaviour The elderly of our community are gravely concerned about the proposed new development. Many of them are living alone and are afraid of strangers coming into the area and parking outside their homes. This of course will increase as builders, contractors etc. begin to arrive. They also fear that with traffic increasing, muck and dirt on the footpaths, they will not be able to cross the road to access shops, post office, Luas stops, bus stops and the church. This will lead to further isolation in their lives. Many, who worked in St. James' Hospital in the past, contributed to the purchasing of the "Stations of the Cross", for the Catholic Church on the grounds of the hospital, having 6 old pence stopped out their wages each week. The church is now sadly defunct and the elderly residents were saddened and indeed upset at its closing as planning permission has not been granted. As the main method of communication with the public about the development was via the internet, many neighbours of Mount Brown and the surrounding area are old and not computer literate, thus completely excluding them from the public participation aspect of the is development. I would ask that a special meeting be held between the developers and the local people so that their voices may be heard.

10. Conclusion Finally, I wish to draw your attention to the Appendices I and 11. These show CGI pictures of the Children's Research and Innovation Centre, and an Aerial View of the Campus. As seen in Appendix I, this a three storey building with a large amenity area out front with many trees, a pond and a few benches. However, is this area really a crucial part of the functioning of this building? I fail to understand why all the necessary rooms and facilities of the building could not have been fit into a two storey structure which would transition better into the surrounding urban context and still operate to the same degree. Instead I can only conclude that the structure had to be designed as a three storey building to fit around the unnecessary rear courtyard and front amenity area. This is in detriment to the surrounding residences and the wellbeing and safety of the inhabitants.

AN BORD PLEANALA I agree that the building is aesthetically pleasing and appears to transition quite well into

liw1c c V the surroundings in the view of Appendix I. However, as viewed~ Appcml.tDrtt,"the btn1~---t eye view of the campus, the Children's Research and Innovation entre tclWer~~IZOii residences to its rear. I would therefore suggest that the spacio amenity area in the front

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of the building be reduced somewhat, therefore enabling the necessary facilities to be built into a two-storey structure and allowing a sufficient transition into the urban context surrounding the hospital campus.

In conclusion, I wish to reiterate that I am not against the development of a New National Childrens' Hospital. However the site at St. James' is totally unsuitable and not in line with the report submitted to Dr. James Reilly T.D., Minister for Health, by Simon Clear and John Martin, 19/10/2012, which stated 'In strategic national planning terms it is important that a long-term perspective be held on the future suitability for service, adequacy of facilities and capability for change. Change may be technological, collaborative or spatial in nature. It is essential that the new facility be ''future proofed" and that there be significant room for manoeuvre, including spatially, in any new hospital campus arrangement'. This is simply not the case with this site. I implore the developers to respond to my above queries, opinions and concerns.

Is mise Je meas,

~~ Emer Casey.

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National Paediatric Hospital Project - Children's Research & Innovation Centre VIEW OF MAIN ENTRANCE- COURTYARD

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