CUNNANE STRATTON REYNOLDS

Comment on:
The Landscape and Visual Impact Assessment and
Related Aspects of the Planning Application for the
Proposed National Paediatric Hospital Project, St
Jamess Hospital, Dublin 8

Prepared by Cunnane

September 2015

For The

Stratton Reynolds

Jack and Jill Foundation

CONTENTS

1.0

Introduction

2.0

Comment on Proposed Building Height and Plot Ratio

3.0

Impact on Residential Conservation Areas

4.0

Comment on the Landscape and Visual Impact Assessment

5.0

The Void Surrounding the Building

1.0

Introduction

1.1

This report has been prepared by Cunnane Stratton Reynolds Ltd (CSR) for the Jack and Jill
Foundation to inform and support its objection to the proposed development of a National Childrens
Hospital (NCH) on a site at St Jamess Hospital, Dublin 8.

1.2

The report provides comment on various aspects of the planning application and the design which
pertain to the proposed developments potential landscape and visual impacts. It also provides
comment on the Landscape and Visual Impact Assessment (LVIA) submitted in support of the
planning application as Chapter 14 (and Appendix 14.1, the photomontages) of the Environmental
Impact Statement (EIS).

2.0

Comment on Proposed Building Height and Plot Ratio

Inaccurate Description of Height

2.1

In the Site Notice the proposed NCH is described as 34.95m tall (to ridge of the roof, above a revised
ground level of Ordnance Datum of 21m at the proposed entrances). In the LVIA chapter (Section
14.1.4.1) the building is described as having a core height of 4-storeys to 7-storeys above ground at
the centre of the development.

2.2

These descriptions are inaccurate. Section AA on Drawing no. NPH-A-BDP-PL-ZZ-00-3203 shows

the height of the building to be 39.15m above ground level at the northern end of the site (or 42.15m
to the top of the flues on the roof). Section AA also shows that at the northern end of the site the
proposed building is a full 8 storeys above ground level (not including the roof which adds a further
storey in height), with the 3 storey ward pavilion (not including the roof) on top of a 4 storey recessed
podium itself sitting on a 1 storey podium (called Lower Ground on the drawings, but entirely above
ground in this part of the site). The roof is 5.1m in depth and Drawing no. NPH-A-BDP-PL-07-00-1200
shows that the floor space/volume created beneath the roof will be used to house Screened Plant.
As a functional floor the roof level should also be considered a storey, in which case the building is 9
storeys in height.

2.3

The height of the building in terms of both measurement in metres and storeys is thus inaccurately
portrayed in the planning application and LVIA/EIS.

Contravention of Building Height Policy

2.4

The policy on building height in the CDP (2007-2011) is informed by the statement on p.245 that:
Dublin City Council acknowledges the intrinsic quality of Dublin as a low-rise city and it is policy that
it should predominantly remain so.

2.5

In Section 17.6.2 of the Dublin City Development Plan (CDP 2011-2017) the site and environs are
categorised as a low-rise inner city area where the permitted maximum height for buildings is 7 storeys
or 28m. The proposed NCH building, at 39.15m and 8/9 storeys, is over 11m (or 40%) taller than the
height permitted by the CDP (2011-2017).

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8

2.6

The CDP (2011-2017) states (p.247): Where a site has a pre-existing height over that stipulated
above [i.e. 7 storeys, 28m], a building of the same number of storeys may be permitted subject to
assessment against the standards set out elsewhere in the development plan. The tallest building on
the St Jamess campus is the MISA building (7 storeys, 28m). This building complies with the height
limit for the area and cannot be considered to set a precedent for the much taller proposed NCH
building.

2.7

However, it is stated in the LVIA: while the proposed development may appear high in the context of
the existing generally low-rise campus; the building height is in keeping with the heights of other
developments already on campus (e.g. MISA building). The proposed NCH is not in keeping with
the MISA building; it is taller by 11m (equivalent to nearly four of the MISA building storeys), and is
not 7 storeys but rather 8/9 particularly deep storeys.

2.8

This is relevant as the lack of acknowledgement of the proposed buildings scale (in the LVIA and the
application documents generally) is carried through into the assessment of its impacts (refer to Section
4 below).

Site Extent, Plot Ratio, Building Height and Mass

2.9

The Planning Report submitted with the planning application states (in Table 8, p.101) that the
proposed development is within the standards for plot ratio, site coverage and open space provision.
This statement is questionable.

2.10

We note that the planning application boundary line (the red line on the drawings) extends to (a) the
walls of the surrounding buildings on the campus, (b) beyond the centreline of South Circular Road to
the south, and (c) as far as the LUAS line to the east. By incorporating the South Circular Road space,
the LUAS green corridor space and the space surrounding the neighbouring campus buildings the
site area is artificially inflated (assuming this red line was used to calculate the site area of 48,350
sqm stated in Table 8 of the Planning Report).

2.11

This may account for the seemingly low plot ratio (1.90) and site coverage (42%), stated in Table 8 of
the Planning Report, for what is clearly a very massive building occupying its site very tightly.

2.12

It is the inherently constrained spatial extent of the site that has forced up the massing and height of
the proposed NCH building, which has implications in terms of landscape and visual impact.

3.0

Impact on Residential Conservation Areas

Residential Conservation Area Zoning

3.1

The impacts arising from the very significant mass and height of the building would be most acutely
experienced on the adjacent residential streets of OReilly and Donnellan Avenue (Residential
Conservation Area), South Circular Road (Residential Conservation Area), Mountshannon Road,
Brookfield Road, Brookfield Street and Cameron Square. The zoning objectives for these areas are
as follows:

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8

3.2

Z1: To protect, provide and improve residential amenities;

Z2: To protect and/or improve the amenities of residential conservation areas.

Residential Conservation Areas are a land-use zoning mechanism used by Dublin City Council where
it is necessary for the preservation of the character of an area due to the important contribution it
makes to the heritage of the city. Policy Objective FC40 of the CDP (2011-2017) states that the
Council will: protect the special character of the citys conservation areas through the application of
the policies, standards and guiding principles on building heights.

Urban/Architectural Transition, and Impacts

3.3

The zoning policy identified above is applied to the Residential and Residential Conservation Areas
themselves to control development in those areas. However, the control of development in adjacent
zones and particularly on neighbouring sites - is of equal importance in protecting these areas
residential amenity and urban character.

3.4

The section drawings submitted with the planning application are unambiguous in revealing the mass
and height of the proposed NCH relative to the buildings in the neighbouring low-rise inner city
residential neighbourhoods. In this regard we refer in particular to:

Section 5 on Drawing no. NPH-A-BDP-PL-ZZ-00-2205. This drawing reveals (a) the difference
in scale between the NCH building and the adjacent houses on OReilly Avenue less than 45m
away, and (b) the difference in ground level between the NCH and OReilly Avenue. We note
that the Lower Ground floor of the NCH building is above ground, has windows in its elevation,
and thus constitutes an eighth storey to the building (although it has not been counted as such
- Refer to 2.1-2.3 above). We note that this section/drawing is cut off at the fifth storey above
ground level, so that the full height of the building relative to the houses on OReilly Avenue is
not displayed.

The sections on Drawing no. NPH-A-BDP-PL-ZZ-00-2204: These reveal the very significant
difference in scale between in the proposed NCH building and the adjacent houses on South
Circular Road (Residential Conservation Area), Mountshannon Road, Brookfield Road and
Brookfield Street. The proposed building is enormous compared to the fine grain and low rise
buildings of the adjacent streets.

3.5

Section 15.9 of the CDP (2011-2017) addresses the transitions between urban character areas: The
land-use zoning objectives and control standards show the boundaries between zones. 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. 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 (own emphasis).

3.6

The proposed developments failure to comply with this policy would result in an abrupt and very
pronounced transition in building scale and design. The residential areas potentially affected are

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8

particularly sensitive (among urban land uses) to such change, and in the case of the Residential
Conservation Areas, designated specifically for the conservation of their urban/architectural character
and amenities.
3.7

The Planning Report submitted with the application states that The NPHDB has equally been
cognisant of the need to protect, as far as practical, local amenities and to this end, the design of the
new childrens hospital and satellite centres has undergone numerous iterations to mitigate potential
negative impacts and take account of community concerns raised during extensive consultations.

3.8

We submit that:
(a) the site is so constrained relative to the spatial requirements of the NCH that no amount of redesign could mitigate these impacts sufficiently, and
(b) it is unacceptable that - for the development in question, or any development - the effort to protect
residential amenities will only go as far as practical.

3.9

It is noteworthy that in the Dolphin Report, regarding planning and design as guiding principles in site
selection, it was stated: the site should be large enough to accommodate a bulky and tall building
without causing adverse impacts on the immediate surroundings or the skyline, and should comply
with relevant development plan/local area plan objectives and standards Ideally, the site should be
large enough to provide a pleasant parkland setting. The site is not large enough to accommodate
the proposed building without causing significant adverse impacts on the surroundings. It does not
allow for the building to comply with CDP objectives and standards in terms of building height. It does
not provide a pleasant parkland setting.

4.0

Comment on the Landscape and Visual Impact Assessment, Chapter 14 of the EIS

Inclusion of Representations and Commentary on Expired Private Hospital Permission

4.1

For each viewpoint assessed in the LVIA (in Section 14.1.7.2) three images are presented, namely
(a) a photograph showing the existing view, (b) the view showing an outline representation of a
previously permitted private hospital on the site, and (c) a photomontage of the proposed
development.

4.2

The planning permission for the private hospital has expired (this was confirmed in a phone call to
Dublin City Council), and it was permitted (in 2010) under the provisions of the previous CDP (20052011) which had significantly less restrictive policy regarding building height than the current CDP
(20112017). Like the proposed NCH (8/9 storeys, 39.15m tall), the previously permitted private
hospital (8 storeys, c. 32m) would be contrary to the policy on building height in the current CDP
(2011-2017).

4.3

It is misleading and contrary to the method of EIA for the LVIA to include representations of the private
hospital and commentary on its visibility and visual effects for comparison with the baseline and the
proposed development. This suggests that the private hospital somehow represents an alternative
baseline to the existing environment or an alternative future scenario to the proposed NCH, when in
fact it is neither.

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8

Difference in Method of Illustration of Expired Private Hospital Permission and the Proposed
NCH Buildings
4.4

The outline representations of the expired private hospital permission illustrate an opaque greybrown building with no material texture or glazing. By contrast the proposed NCH building is gently lit,
lightly coloured and textured, with the proposed planting on the floating garden shown at an advanced
stage of maturity.

4.5

The difference creates a bias when the depictions of the two buildings from any one viewpoint are
compared (and compounds the problem that the two buildings should not be presented for comparison
at all).

Comment on the Assessment of Visual Impact Medium Distance Views

4.6

For a number of medium distance views (Viewpoints 13, 14, 15) the LVIA commentary describes the
expired private hospital permission as a prominent structure. For the same views of the proposed
NCH the commentary states that the building would be visible, but notes that its curving roof profile
allows development to appear lower and more interesting. The impact is being assessed against
another building, rather than the absence of a building, which is the actual baseline. The proposed
building is never described as a prominent structure.

4.7

The result of the commentary (and the photomontages) is an unwritten suggestion that the proposed
NCH would be a better scenario than the other scenario presented (the expired private hospital
permission), as if this were the alternative outcome. This is not the case. We would also submit that,
in a view such as no. 13 from Herberton Road, the NCH building would be prominent, and notable for
its somewhat amorphous shape.

4.8

We suggest that the difference in the LVIAs assessment of the two buildings (as prominent or not) in
the medium distance views stems at least in part from the different methods of depiction in the
photomontages, with the less detailed rendering of the private hospital causing the building to appear
more stark compared to the proposed NCH.

Comment on the Assessment of Visual Impact Close Views, Royal Hospital Kilmainham
4.9

Regarding the view from the Royal Hospital Kilmainham (1st and 2nd floors, Viewpoints 23 and 24),
the LVIA states that the proposed NCH would dominate the view south. This is the view over a lowrise part of the city, for which the policy is to retain this characteristic. However the LVIA assesses the
curving form and architectural treatment of the building positively (describing it as light, varied and
striking, the curved roof presenting an interesting soft skyline) and concludes that the impact would
be moderate/significant and positive. We contend that the effect of introducing a building of such mass
and height in the generally fine grained and (protected) low rise context, blocking from view a large
part of the Dublin Mountains (a key feature of the existing view) would be significant and negative.

4.10

It cannot be the case that policy restrictions on height do not apply to buildings that are considered to
represent good or striking architecture. Various viewpoint assessments in the LVIA including for
Royal Hospital Kilmainham, Ceannt Fort and elsewhere suggest that the light and varied colouring
and curved roof of the building render the proposed NCH so attractive that it can/should be considered
an appropriate/positive intervention in the cityscape.

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8

Comment on the Assessment of Visual Impact Ceannt Fort

4.11

Viewpoints 30 and 31 represent views from the Residential Conservation Area of Ceannt Fort, Quinn,
Donnelan and OReilly Avenues. The LVIA finds that the development presents a significant change
and may initially be viewed as negative but in the medium term (7 years) and beyond the impact will
become moderate and positive. (The LVIA defines moderate impact as: An impact that alters the
character of the environment in a manner that is consistent with existing and emerging trends.) The
reason for this finding is that the author considers the architecture of the building to be modern, light
and appropriate. This finding is questionable. The introduction of the very broad, tall, modern building
to the streetscape the setting of the historic small houses - would have a significant to profound and
negative effect on the local urban character which is distinctive, valued and protected by CDP (20112017) policy. The NCH would become the focal point of views along the streets, diminishing the
architectural presence, status and value of the houses. We contend that the parts of the NCH faade/s
in view (e.g. View 31 please refer to Figure 31.1, Appendix 14.1 of the EIS), when the building is not
seen as a whole, would not necessarily appear light or appropriate. The windows/glazing panels are
extremely large and vertically emphasised. These are divided by large expanses of white coloured
panels. There is a distinct lack of texture and coherence in those parts of the building that visible and
would form the focal point of the view, compared to the foreground architecture. While residents and
other visual receptors may become to some extent immune to the effects of the buildings looming
presence over time, the impact will not be considered positive or even neutral.

4.12

The LVIA has commented only on the impacts that would be experienced in the public realm. The
impacts that would be experienced by the occupants of the properties should also be considered, for
example the residents of the houses at the end of the road in View 31 (i.e. the houses on OReilly
Avenue, backing on to the site). The presence of the NCH in views from the rear windows, back
gardens and on all approaches to the houses would be overwhelming, and the impact on visual
receptors profound, negative and permanent.

4.13

Our assessment above refers to the landscape and visual impacts only. The additional impacts of
overlooking / loss of privacy, overshadowing and loss of sunlight resulting from the tall, broad building
directly to the west of the houses would compound this impact.

4.14

We disagree strongly with the conclusion in the LVIA that the proposed development would ultimately
have a positive impact on (visual receptors in) this area. We refer again to Section 15.9 of the CDP
(2011-2017) which states: 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... particular attention must be paid to the use, scale, density and
design of development proposals in order to protect the amenities of residential properties.

Comment on the Assessment of Visual Impact Close Views, South Circular and Mount
Shannon
4.15

Viewpoints 34-40 assess the impact on the residential neighbourhood to the south west of the site, of
which some of the streets are Residential Conservation Areas, the others zoned for protection of
residential amenities. We note again that the views depicting the expired private hospital permission

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8

confuse the assessment by presenting (in a manner that generates bias) a scenario that is neither
baseline nor alternative future, for comparison with the proposed development.
4.16

For five of these views the LVIA concludes that the impact would be positive, with one neutral and
another negative in the short term but becoming neutral over time. The LVIA dismisses the increase
in visual enclosure and altered urban and visual character resulting from the introduction of the large
building to a landscape designated for protection of its architectural character. The LVIA relies on a
positive opinion of the architectural treatment to form the conclusion that the building, despite its
prominence and non-conformity with the prevailing character, would make a positive contribution to
the streetscape. We submit that this is not the case. Despite its light colouring, curved forms and roof
planting, the development would be too great a change in a low rise area designated for conservation,
and its impact would be significant and negative.

Comment on the Assessment of Visual Impact Close Views, Cameron Square

4.17

For Viewpoints 41 and 42 in Cameron Square, as it does for Ceannt Fort, the LVIA concludes that the
development would have a significant impact, which may initially be viewed as negative but becoming
moderate and positive over time due to the modern, light and appropriate architecture. We contend
that the residents of Cameron Square, particularly the houses backing on to the site, would experience
a significant to profound, negative and permanent impact on their neighbourhood and homes. This
would result not only from the loss of the distinct townscape character and the visual intrusion of the
buildings (no matter the style of the architecture), but also from the loss of sunlight and privacy.

5.0

The Void Surrounding the Building

5.1

The distance between the proposed NCH building and the edge of the footpath on the eastern side of
South Circular Road ranges from 1-2m to nearly 10m. Between the edge of the footpath and the
building there is a void nearly 6m deep. Due to the depth and north-south alignment to the west of the
building, the void will be dark and cold. This void would be the edge to South Circular Road.

5.2

In Section 16.1.9 of the CDP (2011-2017) it is stated: In urban design terms, an important function of
the majority of buildings in the city is to form the enclosure or backdrop to the streets and squares
which are at the heart of public life. Design proposals generally should be well considered in terms of
their interface with public spaces, such as street edges and should demonstrate how proposals will
contribute to the character of the spaces. Their planning and design at these interfaces should deal
with their functions as street walls in equal measure to their internal functions. The proposed
development will in no way function as a street wall to South Circular Road. It is not clear from the
drawings what form of barrier is proposed along the edge of the footpath to stop people falling into the
void.

5.3

The void continues all around the west, east and south facades of the building, in places in excess of
10m deep. The effect is that the building would be surrounded by a deep, empty moat, and would thus
have a poor relationship with its immediate landscape/environment.

Comment on the Landscape and Visual Impact Assessment (EIS Ch. 14) and Related Aspects of the Planning Application for
the Proposed National Paediatric Hospital Project, St Jamess Hospital, Dublin 8