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Our Ref: 29N.PA0043
P.A.Reg.Ref:
Your
Ref: Gordon Smyth
Charlotte Sheridan
Sheridan Woods Architects.
10 Adelaide Road,
Dublin 2.
9th October 2015
Dear Madam,
Re: Health Infrastructure Development comprising National Paediatric
Hospital, Innovation Centre and Family Accommodation Unit at St
James Hospital Campus, Satellite Centres at Tallaght Connolly
Hospitals and Construction Compound at Davitt Road, Dublin.
An
Bord Pleanala
An Bord
Pleana.Ia has
received your recent submission in relation to the above mentioned proposed development and will
take it into consideration in its determinationofthe matter. A receipt for the fee lodged is enclosed.
The Board will revert to you in due course with regard to the matter.
Please be advised that
cop
ies of all submissions observations received in relation to the application will be made
available for public inspection at the offices ofDublin City Council, Fingal County Council and South Dublin County
Council and at the offices ofAn Bord Pleanata when they have been processed by the Board.
f you have any queries in the meantime please contact the undersigned officer of the Board. Please quote the above
mentioned n Bord Pleamila reference number in any correspondence or telephone contact with the Board.
Yours faithfully,
Executive Officer
Direct Line:Ol-8737107
Encls.
ADHOC/P
A0043
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SHERIDAN WOODS I architecture I urban design I planning
Submission To An Bord Pleanala
Third Party Submission
In
respect
of
Direct Application To An Bord Pleanilla Under Section 37e
For Permission For A Period Of 10 No. Years For The Development Of The Proposed New
National Paediatric Hospital, Which Is An Integrated Health Infrastructure Development
Comprising 6 No. Principal Elements And Ancillary Development: (I) A 473 No. Bed New
Children's Hospital (Up To 118,113 Sq.M. Gross Floor Area) At The St. James's Hospital
Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (li) A
53
No. Bed
Family Accommodation Unit (Up To 4,354 Sq.M. Gross Floor Area)
At
The St. James's Hospital
Campus, James's Street, Dublin 8 (Which Contains Protected Structures); Iii) A Children's
Research And Innovation Centre (Up To 2 971 Sq.M. Gross
Roor
Area) At The St. James's
Hospital Campus, James's Street, Dublin 8 (Which Contains Protected Structures); (lv) A
Construction Compound At The Former Unilever Site
At
Davitt Road, Drimnagh, Dublin 12; (V)
A Children's Hospital Satellite Centre
At
The Adelaide Meath Hospital Dublin (Tallaght
Hospital), Belgard Square North, Tallaght, Dublin 24 (Up To 4,466. Sq.M. Gross Floor Area); And
(Vi) A Children's Hospital Satellite Centre
At
Connolly Hospital Campus
In
Blanchardstown,
Dubl in 15 (Up To 5,093 Sq.M. Gross Floor Area).
An Bord Pleanala Reg Ref 29N.PA0043
AN BORD PLEANALA
Received
:
o
z l
o/ 1?:
Fee: f so oo
Receipt No
:
6
I
l 2 o :1-
Prepared On Behalf Of
Mr.
Gordon
Smyth
49
Brookfield Road
Kilman ham
Dublin
8
Prepared By
AN BORD
P L E ~ L
TIME \
BY
- - - ~
0 2
OCT
2 15
LlRD TED FROM 1
PL
Sheridan Woods Architects+ Urban Planners,
10 Adelaide Road, Dublin 2
October 1 2015
Date Of Receipt
Of
Application By An Bord Pleanala
Final Date For Submissions
An Bord Pleanala Register Reference
Issue
0028_01 October 2015
Chorlolle
II
RISH
PUNNING
INSTITUTE
10 August 2015
2 October 2015
29N.PA0043
Kevin Woods, SWAUP Architect
and
Ult>an OeslgnM, 0 pArch BArch Sc MSc: Urban Design MRI I
T/A ShDifdan Woods Atc:h lecb + Urban Planners Ltd Registered In
Ireland
Reg
Na.
3752.5.4 VAT
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SHERIDAN
WOODS
1.0
Introduction
This submission has been
prepared by
Sheridan Woods Architects + Urban Planners Ud on
behalf of our
client,
Mr. Gordon Smyth of 49 Brookfield Road Kifmainham Dublin 8 Our client
wishes to
object
to
the
proposed
development
and
we request that the development is
refused
planning
permission. We enclose here a cheque to the sum of 50 .00 being the appropriate
fee.
We set
out
here an over view of the overall development of the proposed National
Children s Hospital, and Family Accommodation Unit
and
set out grounds for refusal in relation
to the overall development,
and
with particular attention
to
the potential planning impacts of the
development on our clients property,
No.
49 Brookfield
Road.
2.0 Context
The
site for
the
proposed
new
children s hospital and associated Family Accommodation Unit
relates
to the western
section of
the
existing st James s Hospital Campus contiguous to the
South Circular Road, Brookfield Road
and
Cameron Square.
The South Circular
Road is
characterised by two storey dwellings, set back
from
the pavement
with front gardens enclosed by railings. The South Circular is lined with mature deciduous
trees and presents a formal appearance. Brookfield Road comprises more
varied
house types
along
the street, principally two storey dwellings, the dwellings to the west of the street are two
storey with the entrance
and
front garden up a number steps above the street, while the
dwellings
to
the east are two storey
and entered
at street level,
also
with front gardens
enclosed by railings.
The
dwellings to the
eastern side
of the road back
onto
the hospital
grounds. There
are
two single storey cottages along the street at the entrance to Cameron
Square.
Cameron
Square is accessed off Brookfield
Road
and comprises two storey dwellings
formally
arrange
in a square,
with
front gardens enclosed
by
railings. All three residential
areas present their
own
distinctive character, and benefit from a strong sense of place.
St. James Campus
presents
a two storey
high rendered boundary
walls to the
South
Circular
Road,
with
an
entrance
to
the Campus
from Brook
Field
Road, and further high walls
and
red
brick hospital buildings facing Brookfield Road. This boundary is characterised by trees,
some
of which are mature specimens, they are located both along sections of the hospital boundary
and
internally which
are
visible from the South Circular Road and Brookfield Road .
3.0 Proposed New Children s Hospital and Children s and Family Accommodation Unit
The
proposed New
Children s Hospital is
proposed as
a rectangular block
facing
St. James
Walk
to
the
south,
the
South
Circular Road,
and
Brookfield Road to
the west,
and the northern
and
eastern facades are internal to
the
campus. It ncludes the replacement of the existing
boundary with a new boundary, a moat separating
the building from
the street
along
the
south fingers, a set
back
building line for the
proposed podium
structure, that further steps
back
to an upper level Pavilion ward
blocks.
The
building
line steps in along the western
facade to
create
an
entrance
to the New Children s Hospital at Brookfield Road.
The
proposed Family
Accommodation
unit will include the replacement of the existing
boundary wall to Brookfield Road, and the development the new building to the street edge.
The
proposed building form returns into
the
campus,
forming the new entrance
to St.
James
Campus. The
Family Accommodation Unit extends to
the
rear of existing dwellings
on
Brookfield Road and
Cameron
Square.
4.0 Key Planning Issues
The relevant guiding planning document is
the
current Dublin City Development
Plan 2011
-
2017.
We have
reviewed
the
proposed
development in the context of the Development Plan.
Based
on this review it is considered that the
proposed
development
by reason
of its
inappropriate scale,
bulk,
mass and layout materially contravenes the Development Plan,
and
as
a result
is
likely
to
seriously and adversely detract
from
the residential amenities of the
South Circular Road , Brookfield
Road and
Came w is as
follows: AN BORD PLEANALA
TIME. Y
___
t
0 2
OCT
2 15
LTR
D TID FNOM
t
Issue 002B_October 1, 2015
2
. . .
ad, Oublin
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SHERIDAN
WOODS
4.1 Land Use Zoning and Transitional Zones
The
subject site is
zoned Z15 in the
Development
Plan, the
objective of which is
To
protect
and provide for institutional and community
uses
and to ensure that existing amenities are
protected. Under this
zoning
buildings for the health, safety and welfare o he public and
Medical and related consultants are permitted in principle, with car park ancillary to main use
open for consideration.
Education
and
Residential Institution are also both permitted
in
principle. Accordingly, the principle of development is acceptable.
The development plan
notes
that while the
zoning
objectives and development management
standards indicate the different
uses
permitted in
each zone, it
is important to
avoid
abrupt
transitions in scale
and
use
zones. The development
plan
indicates that 'In dealing with
development proposals in these contiguous transitional zone areas, it is necessary to avoid
developments which would be detrimental to the amenities o he more environmentally
sensitive zone. Para 19.1 pg 192)
Particular reference is made to zones abutting residential areas or abutting residential
development within predominately mixed-use
zones and
notes that particular
attention
must
be
paid to the use,
scale,
density and design of development proposals and to landscaping and
screening proposals in order to protect the amenities of residential properties.
The
Brookfield
I
South Circular
Road and Cameron Square
land
are zoned as
follows:
Zone 1 To protect,
provide
and
improve
residential amenity
and
Zone 2 To protect and
I
or
improve the amenities of residential conservation areas which are more environmentally
sensitive zones.
The
scale
and
form of development
as
proposed
has
a detrimental impact on
the amenity of these areas and is contrary to the development plan guidance, which is further
outlined below.
4.2
Development
in
Excess
of
Development Plan Standards
The
quantitative measures
to assess
the scale of development include Plot Ratio, Site
Coverage, Building Height and distances achieved between
new
and existing residential
areas.
4.2.1
Plot Ratio
The indicative plot ratio of Z151and is 0.5 2.5 in the Dublin City Development Plan. Plot ratio
is a tool to help control the bulk
and mass
of buildings. It
expresses
the amount of floor space
in
relation
(proportionally)
to
the
site
area.
The NCH
Planning Report
indicates that:
'The new children's hospital building, including the family accommodation unit (excluding the
Children's Research and Innovation Centre), measures 92,031sq.m. (above ground) on a site
o 48,350
sqm
., which results in plot ratio o 1.90'
We contend that the plot ratio expressed for the proposed development is not an accurate
representation
of
the extent of development
proposed.
For
the purposes
of calculating plot ratio, it is conventional,
and
appropriate to calculate the
site
area
to include only such
land
as lies within the - artilage of the related buildings. It
is
inappropriate to include the lands outside
the
site boundary or building line. Including these
lands gives a distorted view of the distribution of the bulk of the
building
forms on the sites.
The
red line boundary indicated in the
proposed
development drawing
extends to
the centre of
the
road
to the
west, and
it incorporates the linear
park to
the south. Furthermore the
cumulative
site area
includes the roads that
separate the
distinctive development areas within
the overall development. Appropriate site boundaries are illustrated in
Figure
1 below.
In this regard
we
submit that the plot ratio
should
e calculated for the distinctive development
parcels independently including the Family
Accom
s ospital.
To illustrate this we have indicated the configurati n of B Q f i t B e
Family Accommodation
site,
and the
new
Childre t ~ i t a l site ~
and
consequent plot
ratios as
follows:
Issue 0028_October 1, 2015
0 2 O T 2 15
LTR DAtf.D
P
Dublin 8
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SHERIDAN WOODS
ROPLEANALA
NewCNidt1 ns Haspital
Sde Cullilage
TIME ev .,.
Blue
-lndlcaleiiiAlfQpriate baUnCierln
IQr
e purposes a1 calculating plot ratio and
. . . .
coo;erage
lor
Ndl eepnte land
pan:el
y
SiteAn a 37
556sqm
. FllmllyAo:arnmodlbanU *
S ~ e C u n u g e
bAn a 2348IIJII
Figure
1111tJstrates
appropriate site boundaries for the purposes
of
calculating pi
site coverage
Source : Extract From New Children 's Hospital Planning Application Drawing BOP O'Connell Mahon
Architects
level
00; Annotated by Sheridan
Woods,
2 15
New Children's Hospital
As
Proposed
Site area within
the
curtilage or
the
site New Children's Hospital Site
37556 sqm
Total
area development
proposed above
ground
NCH
67677
sqm
Plot Ratio 2.3
New Children's
Hospital-
With Extensions within the New
Children's Hospital Site
Total area of
deveiO(l llent_RfopC)Sed
above ground 67677
SQm
Total
area of extensions
above
ground (Children's Meadow site and
2 000
sqm
over
the emeraencv
site onlvl
Total Area 1o1. n
_sqm
Plot Ratio
2.9
Family Accommodation
Site
area within the curtilage of Family Accommodation Site 2346
~
Total area development proposed
above ground Family 4024 sqm
Accommodation
Plot Ratio
1.7
2 O T
2 15
Based on this calculation, the actual plot ratio
for
the
New Children's Hospital
is
the upper level
of the 'indicative plot ratio' indicated in the development plan. This is inappropriate in the
context of a 'transitional zone', and together with the proposed extension to the hospital, the
eventual plot ratio will exceed the development plan standard.
4.2.2
Site Coverage
The development plan indicates that
Site coverage is
a
control for the purpose
of
preventing
the adverse effects of over development, thereby safeguarding sunlight and daylight within
or
adjoining a proposed layout ofbuildings. Site coverage is the percentage of he site covered y
building structures, excluding the public roads and footpaths.
The development plan standard
for
Z15 land use zoning
is
50 of the site. On the basis that
the site coverage excludes public roads and footpaths, the site areas as
calculated in the plot
ratio assessment above apply (Appropriate site boundaries
as
illustrated in Figure 1 above) In
this regard the site coverage standards achieved are as follows:
b s u e 0 0 2 B _ ~ o b e r 1 2 0 1 5
4 49
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SHERIDAN WOODS
New Children s
H o ~ p i t a l
- sPro.stosed
Site area within the curtilage of the slte New Childrens Hospital Site
37 ,556 ~
-
otal ground floor of the NCH
Site
Coveraae
18,381 r:::.A .. ALA
~ onQt l P L ~
r
~ ~ i l l d . ~ 5 H l ~ ~ ~ ~ ~ m s . O M ~ ~ n ; ~
w - - - - - r - - -
1 r ~
-
~ ~
~
New
Children s Hospital- With Extensions
within the
New 1 \
M-.;t-
Children s Hospital
Site 1Q4C.
~ T = ~
~ l ~ g t r ~ o u ~ n ~ d ~ o ~ v ~ e r ~ n ~ o o ~ r ~ o ~ f t ~ h e
N ~ ~ H
~ - - - - - - - - - - - - - - - - - - ; - - -
~ ~
- - - -
~
~
\ l
Q C 1
L
'a
Total area
of
ground cover of extensions (incl Under Croft) (Childrens
Meadow site and over the emergency site only)
sqm f O'-'_____
D -
--. ,_.
15,000
In
buildings ranging from 4 to 6 floor (pg
29
draft capacity
study) say average 5 floors
@
3000sqm ground floor
(5,000 sqm 3-storey building from Level 02 upwards G 1666sqm
Pl
Total Area
23047 ~
Site Coverage
61%
Family
Accommodation
Site area within the curtilage or Family Accommodation Site 2348
~
Total ground cover or Family Accommodation 1388
~
Site Coveraae
69%
Based on
this calculation, the actual site coverage for the
New
Children s Hospital is the upper
level of the indicative site coverage indicated
in
the development
plan and
together with the
proposed extension to the hospital, the eventual site coverage will significantly exceed the
development plan standard. Furthermore, the site coverage for
the
Family Accommodation
also exceeds the Development Plan standard. In the context of the location of the proposed
development in a transitional zone this scale of development is contrary to the development
plan standards.
4.2.3 Building Height
The development
plan ind
i
cates
that
the
maximum height standards set out at section 17.6
shall have precedence over the indicative Site Coverage. Notwithstanding, the contention that
the
proposed
development conforms with
the
Development
Plan Site Coverage
standards in
the development proposals,
building heights will take precedence. Dublin City Development
plan
is prescriptive
in
terms of permissible building heights. The development plan defines the
permitted height for various areas
in
the Dublin context which is as follows - unless otherwise
approved
in
a local area plan: The st. James Campus is located within the
area
defined as the
inner city. This area is categorized as
Low- rise
(relates to the prevailing local height and
context) . The permitted height is
Below
28m
for commercial development.
The development plan indicates that
For
the sake o
clarity, plant rooms
are
included
in
the
height definition. Also that: No height greater than that specified for the inner city category will
apply until a LAP is adopted.
The development comprises a parapet building height of 12.6m, to
14
.1m including the
proposed balustrade above ground level facing the South Circular
Road,
stepping up to a roof
height of
34.95m
and 37.95m to chimney height. Accordingly, the roof height exceeds the
permitted development plan height of28m by 6.95m,
and if
permitted would materially
contravene the Development Plan.
The planning report relies on previous planning permissions as precedence, in particular the
Mercer s Institute for Successful Ageing (MISA) (3607/12),
and
the Co-Located Private
Hospital (Dublin City Council 2751/09 ABP Ref Pl29S.236070). We
have
illustrated the
building alignment and form of the previously permitted Co-Located Hospital
in
Figure 2 below.
The MISA building height to the top of the roof permitted is 28 metres, the proposed height in
metres to parapet is 29.1 metres and for a small section of the stair access core is 30 .85
metres. This development generally conforms with the current development plan standards,
and
given its context opposite existing 6 /7 buildings
at
Herberton, it is more contextual with its
immediate environs. This development is lower in building height than the proposed National
Children s Hospital.
lssue002B_October 1, 2015 - 5 - 49 Brookfield Road, Dublin 8
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SHERIDAN WOODS
2
O T 2 t5
~ R O M
. .
Including tower block and podium block
Source . Extract From New
ChAdren s
Hospital Planning Application
Drawing
BOP O Connell Mahon
Architects Level 00;
Annotated
by
Sheridan
Woods, 2015
The permitted Co-Located Private Hospital located on part of the site o he proposed New
Children s Hospital comprised an eight storey block with roof level at 52 .96 AOD Malin Head
32.85m over ground level. The top of the proposed parapet is set at 54.4 AOD or
34
.29m over
ground. The eight storey block however,
was
set back from the South Circular
Road
by
40
.
5m
. Also the foot print of the podium block was 60m in length along the South Circular
Road, with a set back,
and
further 13.5m length totaling 74.5m length. While the roof height of
the current
proposed
development
is
generally consistent with the previously
proposed
private
hospital, there are notable differences.
The
taller element of
the
previously permitted private
hospital comprised a significantly smaller footprint of
95m
length,
and
20m width presenting a
slender building form that
was
substantially set back
from the South
Circular
Road.
It is also notable that the previously grant of permission for the private hospital development
has expired (Permission granted
in
June 201 0). The application was determined before the
adoption of the current development
plan
where height restrictions are more prescriptive.
There
was
no application to extend the duration of the permission,
and we
submit that it is
unlikely that the development would
have been
granted
an
extension of duration of permission,
on
the basis that it would materially contravene the development
plan
in terms of building
height.
Accordingly the overall height of the proposed national Children s Hospital exceeds the
development
plan.
It is not reasonable or appropriate to rely
on
the precedence of the
previously permitted developments
on
the
basis
that the setting of the MISA contrasts with the
setting of
the proposed
national Children s hospital
and
is accordingly not comparable,
and
also on the basis that the overall configuration of the previous co-located hospital contrasts
significantly with the current proposals in footprint, and building set backs and is also not
comparable.
4 4 Impacton Adjoining Residential Amenity - Overall Context
The
cumulative impact of the higher range of plot ratio, excessive site coverage and building
height suggests overdevelopment of the site. The consequence o overdevelopment
generates adverse overshadowing, overtooking of adjoining residential
areas.
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SHERIDAN WOODS
4.4.1 Overshadowing
The overshadowing analysis carried out in Chapter 13 of the EIS demonstrates that the
proposed development will cause overshadowing along the South Circular Road, and
Brookfield
Road
in the morning from early morning to
mid
morning.
We
note that the
assessment of the previously pennitted co-located private hospital
did
not generate
overshadowing primarily due to the separation
between
residential properties
and
the upper
elements of the development, and the orientation thereof. (As noted in the Inspectors Report
PL29S.236070).
Given the separation distances and the proposed heights, the proposed development will
result
in
generating adverse overshadowing to the
South
Circular Road
and
Brookfield Road
in
particular. The extent of overshadowing will result
in the Joss
of sunlight on the street,
and
consequently the overall appearance, ambi
ance and
amenity of the streets,
and
a reduction
in
the sunlight currently enjoyed by the residents
of
he
South
Circular
Road and
Brookfield
Road
in particular.
4.4.2 Overlooking
The distances proposed between the proposed development and the existing residential
development are set out in the table here.
Location
Opposi
ng
Use Distance Previously pennmed
Setback from existing
buHdlngs
1 2. mhan boundary to
p
linth.
and 40m han boundary
ID
elomenl l
South Circular
Road
32.
6m
Junction with Setback from front
wal
l
Mountshannon of dwellings
to
plinth
level
20m to site boundary,
with 12.5m setback)
80.
6m set back from
front wall of dwelling to
tower
20m to site boundary,
40.5 m setback)
to 'South Fingers' Outpatient (Gnd)
25m
(for 3 noors)
Wards (leve l 1)
Davcare (Level 2l
to Floating Garden Therapies (level 3)
25m
to garden
45m
to accommodation
to
Pavilion Ward Wards
62m
(for 3 noors)
South Circular Road
NIA
Junction with
Brookfield Road
to South Fingers Outpatient (Gnd) 21 .
9m
(for 3 noors)
'
Wards (level
1)
AN BORD
aycare
(Level 21
~
...
L
~ L
to Floating Garden Corporate Services 38m
TIME
_
j
offiCes
to edge of Floating Open Space 21 .9m
0 2 01
.
T 2 15
arden
to Pavilion Ward 49.4m
D
na.Ta n
PROM
Brookfield Road
Pl
.
to Family
Board Room
(Gnd) 14.1m (Street width
-
Accommodation Bedrooms Communal Including front gardens)
Kitchen
(Level1 2)
Oblique bedrooms
Stalr(level
3)
Rear of Brookfield
Road
Bedrooms
Communal
33 .5m
to
Family kitchen Stairwell
Accommodation
Level
1)
Bedrooms Sta irwell
Level
2)
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SHERIDAN WOODS
Cameron Square NIA
to gable of Family
Ground Floor .6m
Accommodation
First Floor
22m
( to main wall of
house
Second
Floor Z76m
to North Flnaers 25.
7m
The development plan requires a separation of 22m between 2 storey dwellings in order to
protect their amenity. This standard is applicable in this context. This standard is not met
along the SOuth Circular Road in relation to the New Children s Hospital, It is not met on
Brookfield Road in relation to the Family Accommodation Unit, and it is not met in relation
to
the rear of Cameron
Square
. Furthennore, this distance
is
a minimum distance,
and
greater
distances should be provided where buildings exceed two storey in height.
The previously pennitted co-located hospital development
on
part of the New Children s
Hospital site was positioned 12.5m
from
the St. James Boundary, which allowed for 32.5m
distances between opposing structures on the South Circular Road . The
proposed
development is a significantly closer than the previously pennitted development.
The proximity of three storey with a roof garden, stepping
to
four story.
and
a further three
storey structure facing the existing two storey structures will cause adverse
over1ooking
that
will significantly detract from the amenity of the existing dwellings on the South Circular Road,
Brookfield Road,
and
Cameron
Square
.
The proposed
development is
below and
just within
the minimum distances required in the development plan for the lower level structures where
over1ooking
is likely. Furthermore. given the height of
the
opposing structures at the lower and
upper levels, there will be a significant altered perception of overtooking generated and
resultant loss of residential amenity of the existing dwellings on the
South
Circular Road,
Brookfield Road and Cameron Square that will be visually obtrusive and have an overbearing
impact on the amenity of the residents
. .
4.5
Impact
On Amenity
Of
No. 49 Brookfield Road
We
have
carried an assessment of the impad of the proposed development on our client s
property. This
includes a review of the
existing amenity,
a description of the location of the
proposed
development relevant to
No. 49, and an
assessment of the impad
of
the
development with
regard
to visual impact, over1ooking and overshadowing .
Location
No. 49 is located to the
north
western side
of Brookfield Road . The dwelling currently
front onto an existing concrete boundary
wall to
the hospital, with set back two storey
brick strudures.
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Existing
The front of the dwelling enjoys early
morning eastern sunlight from sunrise to
mid morning .
The dwelling faces
an
existing concrete
blockwork wall and a two storey structure
that forms part of the hospital.
The street is characterised by two storey
structures.
The proposed Family Accommodation Unit
is located to the east of the dwelling. The
FAU
presents 11 .
95m
high ~ d e facing the
dwelling. The building steps
down
to the
meeting the adjoining terrace and
steps
up
to fonn the entrance to the New Hospital
Entrance Piazza. The separation distance
between
the new
structure
and
the existing
dwelling is 14.16m
A conference
room
is proposed at ground
floor level. The ground floor level is
consistent with the ground floor level of the
d
we
lling. Bedrooms are p
roposed
at the
upper
two
floors.
The
main entrance to the
New
Children's
Hospital is located
south east
in a position
closer
than
the existing entrance
to the
hospital to an large open plaza space.
Landscaping proposals to the front of the
block suggest the inclusion of street trees.
4.5.1
Impact
Of
Proposed Development
Impact
Of
Proposed Development
Visual Intrusion
Given the close position, height and scale of
the proposed Family Accommodation Unit it
will visually dominate the views
from
the front
of the dwelling
at
ground
and
first floor level.
As a result of this it will
be
both visually
intrusive
and
have
an
over bearing impact
on
the residents of No. 49 Brookfield
Road.
The views southwards from the front window
will be further enclosed by the AFU building
stepping up to four floors to the new
entrance plaza.
The overall impact is
an
oppressive
enclosing effect
on
the dwelling, that detracts
from its residential amenity.
Issue 002B_October t, 2015
g
SHERIDAN
WOODS
.
.
: : \ I I I I I J I I . I O c l
:
1;
~ .
.
:
Extract From New Children's Hospital Planning
Application Drawing BOP O'Connell Mahon Architects
Level 00; Annotated by Sheridan Woods, 2015
AN BORD PLEANALA
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LTROAT D
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__
Source:
ChUd
ren's Hospital Planning
Application Drawing BOP O'Connell Mahon Architects
Level
00; Cropped by Sheridan Woods,
20
15
Facades Facing The Rear of No.
49
Brookfield Road
49
Brookfield Road, Dublin 8
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SHERIDAN
WOODS
Overshadowing
The
EIS assesses the impact
of
the development on
No.
49
and
specifically calculates the
Vertical Sky Component,
and
the
access
to sunlight. A reduction in
both
in
noted and
the
proposed Family Accommodation Unit is the primary contributor to this reduction.
While the existing sky component
and
access to sunlight from the front
of
the property is low,
the combination of the proximity of the AFU
and
the reduction in the sky component
and
access to sunlight will represent a serious depreciation in the enjoyment of our client s
property. This significantly detracts from the amenity
of
our clients property.
' -
Source: Extract From
EIS
Chapter 13
Figures
13
Shadow Plans
show
the
Proposed
shadow
plans
for
eac:h
hour
on 21st March September
from
8 OOam
shadow
plan
Jnustrated
-
Loc:atlon
of No . 10 Brookfield
Road
Highlighted - Annotated by Sheridan Woods 2015
Overlooking
The separation distance between the Family
Accommodation Unit and the front facade of
No.
49
is just 14.16m. The proposed ground
floor conference room will directly face the
living window of our clients property, and
bedrooms at first floor.
The separation distance is well below the
development plan separation distances. The
proximity
and
nature of use of the proposal
will generate over1ooking of our clients
property and will result
in
a significant toss
of
privacy to our clients property.
Landscaping
The landscaping plan suggests the provision
of
street trees adjoining the proposed family
Accommodation opposite our client s
property.
There is insufficient space along the foot
path to accommodate the trees and
to
ensure their success.
Issue 002B_October 1, 2015
10
r..,.
11
1
PciW
r .. Ro td .. ... ew11 twJng . . .
I CGIII
Ml llfDW
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lt 1 . : . . 7 f ~ ~ ~ r 1
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=
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Source; Extract
From
EIS Chapter 13 Figure 13.17
Illustrating
Impact
of
Fam
ily Ac:c:ommodatlon Unit
On the sky component
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SHERIDAN WOODS
Based on the above analysis and previous findings
we
submit the following to
An Bord
Pleanala:
The
close
proximity of the Family Accommodation Unit opposite the front facade of our
clients property will be visually intrusive and have an overbearing impact on the
amenity of our clients property.
The proposed development
will
result
in
the loss of sunlight to the property
in
particular
in the morning at sun rise to mid morning
The
proposed development will result
in
the loss of vertical sky component as a
consequent of the proximity and height of the proposed development
and
will
have
a
closing effect
on
the dwelling.
The proposed development will generate adverse overlooking as a consequence of
proximity and separation distance between the proposal and our clients dwelling
and
will result
in
the loss of privacy enjoyed by our client.
The change
in scale of development
along
the street is incongruous and detracts
from
the integrity of the two storey architectural character of the street.
The provision of the new entrance to the hospital northwards to Brookfield
Road
will
result
in
a significant change
of
use
along the
street giving a
sense
of
being
part
of
he
hospital activity will
detract from the existing residential amenity. This will have a
particular impact on our clients property.
The scale of new development along the street together with the intensified hospital
use on
the street will significantly erode the existing
sense
of place currently enjoyed
by the
Brookfield
Road
community.
The increased traffic will significantly alter the character noise levels and
environmental quality of the street.
There is insufficient space along the proposed footpath to accommodate the proposed
street trees to the front of the proposed Family Accommodation Unit.
It is requested that the proposed development is refused permission
on
these grounds.
Mitigation Measures:
If t is intended to permit the
proposed
development
we
request that the Family
Accommodation Unit is redesigned to take account of the negative impact that the structure
has on the amenity of our client property and the provision of additional landscaping. In this
regard
we
request the following:
That the building is set back further to increase the street width that the overall height
of the structure is
reduced
to limit the enclosing
and
overbearing impact.
We request that the street pavement is designed to allow for the successful planting of
new street trees opposite our clients property adjoining the proposed Family
Accommodation Unit.
That the extent of tree planting is increased to the front of the Family Accommodation
Unit to further lessen the immediate impact to our clients.
That landscaping such as the provision of a line oftrees is positioned to the edge of
the proposed plaza to create a separation between the proposed entrance to the
hospital
and
Brookfield
Road.
The purpose of this is to limit the exposure of the
residents on Brookfield
Road
to the activity of the Hospital
and
to block the view of the
main
entrance from Brookfield
Road in
order to maintain the identity of Brookfield as a
distinct neighbourhood and
not part
of
the
overall hospital campus.
Impact On Streetscape
In addition to the impact of the proposed development
on
the residential amenity of
surrounding properties the scale massing and design of the proposed development would
have a considerable negative impact on the immediate streetscape and character of he
area.
The existing South Circular Road Brookfield
Road
and Cameron Square
area
all benefit from
a strong sense of place
and
identity.
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SHERIDAN
WOODS
Paragraph 16.1.8 of the Development
Plan
gives guidance on urban fonn and architecture,
and indicates that urban blocks should
be
designed to promote penneability
and
walkability,
thereby integrating with the existing
urban
fabric. It is reasonable that the hospital
campus
should confonn to this aspiration. The development
plan
indicates that
urban
block lengths
greater than 100m should be avoided. Developments should relate to the local context of
building patterns ortypologies. The photomontage views of the
proposed
development
however illustrate the visual impact of the proposal on the neighboring streets and
demonstrate the vast scale of the proposal relative to the existing local context. The proposed
building 'moat' separating the street edge
and
the building, the
proposed
setback at third floor
with intensive
planted
roof garden level is incongruous,
and
the
curved
three storey fonn is
discordant.
AN
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National Paediatric Hospital Project
local
e g ~ n e r a t i o n
Opponun
es
_ L ; : ; M ; : : : = = = = ~
: ; ; = = : I
Source: Appendix 5:2 or the EIS National Paediatric Hospital Local Regeneration Opportunities
Furthennore. the continuous length of the
urban
block measuring over 1OOm facing James
Walk, and
greater
than 200m along
the
South
Circular
Road, and
Brookfield Road presents
an
building scale that
is
contrary
to the local and city building
block. This is notably Illustrated
in
Appendix 5:2 of the EIS National Paediatric Hospital Local Regeneration Opportunitiesw
where the existing context is illustrated, the regeneration opportunities indicatively illustrated in
careful urban blocks and the proposed Children's Hospital representing the single largest
urban block (Extract included above for illustration purposes). As a consequence the overall
development will overwhelm, detract
from and
result
in
the loss of the existing local character.
4.7 Capacity
of
St. James Campus
The
Capacity study accompanying the application presents
an
indicative layout illustrating
how
it
may accommodate the extent of development required for the three hospitals within
the
St.
James campus. This indicates that further 6 and 7 storey buildings with basement levels will
be required . The study relies on plot ratio assessment only, indicating that the campus is only
just capable of achieving the quantitative extent of development required within the standards
of he development plan with little room for further expansion or enhanced public realm The
plot ratio expressed is 2.2). There is no indication of site coverage and no three dimensional
analysis.
It is reasonable to
assume
that it is likely that in order for the
campus to accommodate
the
development of three hospitals that the remained of the site will be as intensively developed as
the proposed children's hospital portion of the site. If his is the case, this
would
potentially
lead
to the development of
an
urban quarter that
is
so intensively developed that
it
does not
meet Dublin City Councils ambition for the built environment of Dublin to deliver quality urban
environments.
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SHERIDAN
WOODS
The capacity study highlights the shortcoming
of
the St. James Campus, that there Is
insufficient site capacity to accommodate all three hospitals while achieving overall quality of
development and physical environment. The study clarifies why the site apportioned to the
children s hospital
is so
constrained, and why
it
has been necessary
to
develop
the
hospital
with 3 basement levels, and 8 floors above ground, which results in over development
of
he
children s hospital site, and which will set a precedence for the further over development of the
remainder of the site in order to meet the strategic health needs.
We
submit that this does not
represent proper planning and sustainable development.
.....
Figure 4
Extract From
Draft SHe Capacity
Study
:
AN BORD PLEANALA
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r
r
:
-:
.
. I
: :
.
.
.
.
.
.. ._
_
Source: Extract From St. James Campus Site Capacity Study BOP OConnell Mahon Architects 2015
4.8 Traffic And Transportation
The planning report acknowledges that the biggest impact during construction will be as a
result
of
the export of material from site during basement excavations,
over
an approximate
18
month period, and the importation of materials
for the
construction process. This is significant,
and will seriously impinge on the amenity of residents in the area for an extended period during
construction period.
The traffic
analysis during the operation of the development does not Include sufficient stress
tests, including assessments during wet weather etc. and the proposed development relies on
a modal shift from car usage among staff and enhanced public transport provision for staff and
patients. The existing area already experiences traffic congestion and as acknowledged
In the
planning report,
that the surrounding street network will continue to experience traffic queuing
and delays at some periods through a typical week day. The mitigation proposals included
as
part
of he Transport strategy
for
the St amess Hospital campus and the new children s
hospital ensures that the increase in traffic levels
and
associated impact during these periods
are
kept
to a minimum. It is submitted that there is over reliance on the mitigation measures
to ensure that the impact of the traffic proposals will not exacerbate the existing traffic and
transport context. The marginal manner in which traffic is managed to ensure that increased
levels in traffic and associated impacts are kept to a minimum suggests that the site and
adjoining road network does not have the capacity to accommodate the proposed
development in accordance with proper planning and development.
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SHERIDAN
WOODS
In
relation to car parking, there
is
currently significant pressure on car parking
in
the locality.
The reliance on the modal shift
from
car use
to
public transport while commendable
is
ambitious. Furthermore, the development has the potential to result in the loss of existing car
parking spaces at Brookfield
Road in
particular. It is submitted that there will be inadequate
parking available for residents in the area who rely on on-street parking, as a consequence of
the development during the construction period, and the following operation of the
development.
Furthermore, there is
no
assessment of the capacity of the existing infrastructure to support
the potential traffic generated if the extent of development
proposed in
the master
plan
is
implemented,
and no
assessment of the impact on car parking in the area.
The
proposed
helipad and construction traffic are also likely to generate significant noise,
which will detract from the amenity of the area.
We submit that the
proposed
development should
be refused
permission on traffic
and
transportation grounds
and
associated
noise
and environmental deterioration
reasons.
5.0 Concluding Comment
r
_
c..J
0
N
c::.
g
)
Notwithstanding the Strategic Infrastructure Development status of the proposed development
and
its importance to the future development of the City
and
the State, the proposed
development of the
New
Children s Hospital does not conform with the proper planning and
sustainable development of the area and should
be refused
permission.
Having regard
to
the
provisions of
Dublin
City Development
Plan 2011
2017
in
relation to Taller Buildings as Part of the Urban Form and Spatial Structure of Dublin
and in particular to Policy SC17 which seeks to protect and enhance the intrinsic
quality of
Dublin
as a predominantly low-rise city
and
to provide for taller buildings
in
the designated limited locations,
it
is considered that the proposed development would
exceed the
defined height identified for Inner City locations,
and
would contravene
Dublin City Policy
in
this regard.
Having regard to the transitional zone
area,
to the height
and
scale of the proposed
development, its location in close proximity to residential properties adjoining the site
to the west,
and
by reason
of
overbearing aspect, excessive
over1ooking, and
visual
intrusion
and
that the development is an abrupt transition between the
Z15
and
residential land use zoning
zone
1
and
Zone 2, the development does not accord with
the policies
and
objectives of the
Dublin
City Development Plan).
Having regard to the height, scale, massing of the development it would be visually
intrusive in relation to the existing character
and
scale of the immediate local
streetscape along the
South
Circular
Road, and
Brookfield
Road. The
development
would seriously injure the amenities of the
area and
would therefore
be
contrary to the
proper planning and development of
the area.
The
proposed development will seriously injure the amenity of our client s property,
No.
49 Brookfield
Road
in particular through visual intrusion,
over1ooking and
overshadowing as a consequence of
the
location, height,
and
uses proposed within
the
Family Accommodation Unit
opposite
our clients dwelling.
.
- ' .
The capacity of St. James Hospital to accommodate the children hospital
and
future
hospitals is marginal,
and
requires further 6
and
7 storey structures over basement
levels,
without
any
notable enhancement of the public
realm. which
would suggest that
the
site
does
not
have
sufficient capacity
to
accommodate
the
children s hospital or
I
-
future development of two additional hospitals.
The operational and construction impact of the development on traffic
in
the area will
seriously impact on
the
existing road network
and car
parking in
the area,
noise and
deterioration of the environment quality of the area and does not conform with proper
planning and development of the area.
In
the event that
An
Bard Pleanala intend to grant permission, we request that the mitigation
measures presented
in
this submission are included in a condition attaching to the grant of
permission
in
order to protect the amenity of our clients property.
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SHERIDAN WOODS
Our client would welcome an opportunity to present their concerns to the Board
in
the event it
is intended to
hold
an
oral
hearing
in
respect of the proposed development and requests
an
opportunity to
do
so .
We trust
An
Bard Pleanala will take our submission into account.
Yours sincerely
U 1 A ~ t .)-ItA._ ~ V f i V \ . .
Charlotte Sheridan
Sheridan Woods
October 1 2015
Encl
An Bord Pleanala Fee
ESO OO
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