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PA0043
P.A.Reg.Ref:
An Bord Pleanala
Your Ref:
James M. Sheehan
The Hennitage
Cross Avenue
Blackrock
Co. Dublin
30th September 201 5
Re: Health Infrastructure Development comprising National Paediatric
Dear Sir,
An Bord Pleamila 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 Pleanala 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,
rC
\I!_Gei'aliSOIDers
Executive Officer
Direct Line:Ol-8737107
En cis.
ADHOC/PA0043/0I
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BY
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28 SEP 2015
LTRDATED.2.8'~
FR
Cross Avenue,
B/ackrock,
Co. Dublin.
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Objection to the location of the new National Childrens Hosoital at St. James site
Submitted By:
AN BORD PLEANALA
TIME
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2 8 SEP 2015
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Application/Submission to An Bard Pleanala in relation to the planning application
for the New Children's Hospital at St. James site.
Development Type: Strategic Infrastructure Development {SID)
Planning Application Reference: PA0043
Date Application Received: 10-8-2015
Expected Date For Decision: 15-2-2016
Person making Submission:
Dr. James M. Sheehan, FRCSI. MB. Ph.D. (Mechanical Engineering) B.Sc. (Anatomy)
MSc (Bioengineering) C. Eng. FIEI. FAEI.
The Hermitage, Cross Avenue, Blackrock, Co. Dublin
Phone: 01-2880707 Mobile: 0878147670 E-mail: jamesmsheehan @icloud.com
Summary
In my view the St. James site is a totally inadequate location for the proposed new
children's hospital. Within this report I have clearly set out my objections to the
proposed location and highlighted suggestions the planning authority may wish to
investigate as part of their decision making process. I have summarized these below:
1. The pre-application consultation process raised a number of queries that
remain unanswered.
2. Inadequate time frame & consideration of the Dolphin report by Cabinet
members. The report was submitted on the evening of November sth, 2012
and signed-off by Cabinet the following morning.
3. Inadequate access of the St. James site to cater for the additional & future
growth nee<;ls of the planned facility.
4. Inadequate location of the proposed helipad.
5. Inadequate parking at the St. James site to cater for the additional & future
needs of the planned facility.
6. Cost benefits of locating the planned hospital on a greenfield site.
7. Site limitations as outlined in the Dolphin report.
8. Inadequate square footage to cope with evolving & future capacity
requirements of a children's hospital, including sub-specialization.
9. Failure to co-locate or tri-locate with a Maternity hospital.
10. Speed of construction & ongoing disruption to business as usual at St. James
hospital compared with a greenfield site.
11. On-going & unnessary Impact on the surronding
site.
TIME
12. Staff considerations.
---13. Construction & demolition impact.
2 8 SEP 2015
14. Satellite Centres.
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15. Attractivenss of a greenfield location.
PL
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16. Visual & streetscape impact on the local & wide~IIIIIZZil=:t~:::::=::::::::::::::::~J
17. Underground infrast ructure.
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Background
After 22 years delay the public are suffering from fatigue awaiting the development
of a new Childrens hospital. When asked, many in desperation mutter "just get on
with it no matter what". I can fully relate to this attitude but unfortunately this is not
an excuse for doing something that is inherently flawed.
To build the new All Ireland Children's Hospital on the St. James site would be the
single worst decision undertaken by any government in the history of the State. The
care of our children will be compromised for future generations and there will be no
turning back or ability to correct this fatal error.
The public understandably are afraid that if the planning application is rejected that
further delays will occur. This is not in fact the case as a far superior hospital could
be constructed on the Connolly site at Blanchardstown in a shorter period, even
allowing for a redes,ign and new planning application. As the Dolphin report rightly
stated "we have a once in a lifetime opportunity to get this right". For this reason
alone, the current application must be rejected.
As both a surgeon & engineer I have planned, designed, and commissioned three
newly built hospitals in the past 33 years (the Blackrock Clinic, Galway and
Hermitage Clinics). I am currently involved in hospital administration. I have also in
the past served on the board of Crumlin Hospital to assist and advise on the
development of a new paediatric hospital. I was a key mover in instigating the
merger of the three existing childrens hospitals. Having experienced all facets of
healthcare over half a century I feel I have an unique perspective that could greatly
benefit both current and future generations of Irish children, parents & their families
in critiquing the proposed location of the new Childrens hospital. I have no conflicted
interests (commercial or otherwise) and have no political affiliation that would in
anyway influence my views on such an important matter.
AN BORD PLEANALA
TIME
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2 8 SEP 2015
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Introduction
After the rejection of the Mater site the Dolphin committee was asked to report on
alternative sites. This 81 page report was submitted to the members of the
Cabinet on Monday evening the 5th November 2012, and the following morning the
Cabinet decided on the St. James site. This begs the question: How much ofthe
report did any of the Cabinet members complete? Did any one member walk the site
either late that night or early the following morning? Understandably cabinet
members may have felt pressurised into a decision or face the consequences of an
enquiring media.
It is difficult to believe how the St. James ~ite was selected. It could only have been
chosen for political reasons, as on almost every parameter it fails the test for a new
National Childrens Hospital.
The St. James site has significant problems, but was chosen as it had eleven national
adult specialities on site. Five of these are laboratory based, can be sited anywhere
and have no relevance to location of a Children's hospital. While St. James's lists
burns, bone marrow transplantation, maxillofacial surgery, reconstructive surgery,
plastic surgery and haemophilia as national adult specialities, Crumlin hospital is
currently the national centre for paediatric oncology, haematology, haemophilia,
bone marrow transplantation, cardiology, cardiac surgey and burns. While currently
there is some cross cover by specialists who practice in both paediatric and adult
sub-speciality areas such as burns, reconstuctive surgery and maxillofacial surgery,
the Dolphin report in 2012 acknowledged that "Paediatric Hospital dependency on
adult specialists will decline as paediatric subspecialties develop". The burns and
plastic surgery services which currently have shared surgeons between St. James's
and Crumlin, if moved to St. James's, would benefit the surgeons but not the
patients. In fact the hospital with the greatest number of specialities under one roof
in Ireland is Crumlin which has 39 specialities.
The Dolphon group was not asked to recommend any one particular site but to
consider the pros and cons of sites adjacent to adult teaching hospitals. The Connolly
site, according to the Dolphin Report, was the site with the lowest planning risk.
Surprisingly the Report, without any supportive evidence, states that even if
substantial investments of human and capital resources were made avilable it could
take "several decades" to achieve " high standards of clinical and research
excellence".
No specific site was recommended, and from a perusal of the Dolphin Report the
Connolly site was undoubtedly the most appropriate. When the report was
presented to Government it was incorrectly informed that the outcomes for children
ho~s~p~it;a~l~
w~it~h~~~-
were better if the paediatric hospital was co-located with an J7tl;N
multiple specialties. There is no scientific evidence published pn t ~
journals to substantiate this claim. For a multiplicity of reaso sTtJW&;jetailed atee
Y_ _ _ __.
Connolly site is greatly superior to the St. James site.
28 SEP 2015
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Both the McKinsey and the Dolphin reports recognised that paediatric healthcare
worldwide was changing rapidly and acknowledged that, within a relatively short
period of time, paediatric dependency on any adult service will become a thing of
the past.
Since the decision to locate the Childrens Hospital at St. James was made, it has
since been decided to relocate the Rotunda Maternity Hospital to the Connolly site.
This is the ideal site, as it has access for all the country including Northern Ireland
due to its proximity to the MSO motorway.lt provides a parkland setting which is
highly desirable for Childrens holistic care. There is space for unlimited parking.
Construction costs will be minimised, and for the same capital expenditure at St.
James a new Maternity Hospital can be included in the plans from the outset. It is
adjacent to a general hospital which is a major teaching centre for the Royal College
of Surgeons. It is incredible that such a suitable site was not chosen as it is ideal in all
respects, including it being in state ownership.
Apart from being an ideal holistic environment the Connolly site permits the design
to place the bedrooms in a south westerly orientation which is recommended
whenever possible in a newly designed hospital.
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2 8 SEP 2015
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Objection to the location of the new National Childrens Hospital at St. James site
As the Pre-Application Consultation Process raised a number of queries that the
Inspector felt needed to be addressed it is appropriate to consider these in some
detail:
These criteria can be summarised under the following headings, (1) Access: both
road and air (2) Parking, (3) Cost (4) Site limitations (5) Inadequate space for the
future expansion of the Childrens Hospital (6) Tri-location of the Maternity Hospital
(7) Speed of construction (8) Disruption of existing adult services at St. James
Hospital (9) Impact on surrounding residents (10) Staffing considerations (11) New
master plan for St. James hospital (12) Construction & demolition impact (13)
Satellite Centres (14) Coombe Hospital & its potential to accommodate future
maternity hospital (15) Visual & streetscape impact on the local & wider
environment and (16) Underground Infrastructure.
I will deal with each of the above briefly.
1. Access
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AN BORD PLEANALA
TIME
BY
2 8 SEP 2015
The current road network is inadequate to handle t tM.a1~ traffic at St. James
adult hospital. Delays of up to 45 minutes are exper cedOy staff au.Efflqlli ng to
exit at certain times. Tom Costello the Chairman of
ittee
contradicted this statement and state(j that it "only" took him 10 mmu
the site. This is before the Children's hospital is built.
The Childrens Hospital will generate significant extra car movements daily. The
resulting gridlock will bring traffic to a standstill. This will cause added stress for
the parents of sick children, both for acute attendees as well as routine
appointments.
Ambulances bringing acutely ill patients, both adults and children, to the
respective Emergency Departments will experience serious delays and this will
jeopardise the care of patients. Avoidable deaths will inevitably occur.
It is a fact that 90% of children attending hospital travel by car. This was
confirmed by the Dolphin Report that stated "Most patients who do attend will
arrive by car, and adequate on site parking needs to be provided for their
needs". The majority of day cases arrive and depart at peak hours. Thus easy
access is vital. Already certain specialties i.e. cardiac patients travel from
Northern Ireland to Crumlin for cardiac Surgery and the new Childrens hospital
will cater for increasing numbers of pa.tients from the Island of lreland.This
arrangement is planned to continue in future years.
Helipad
The plans show this located on a fourth floor building. This is bounded by a four
storey building to the North side (counting the plant room as a floor) and the
high tension cables of the luas are on the south side. It is recommended that
whenever possible a hospital helipad should be located at ground level for safety
purposes. Significant costs are incurred for fireproofing a building if a helipad is
roof located. It should also be as close as possible to the A&E services. The
current location shown is at a significant distance from the Childrens A&E service
and also a significant distance from the planned adult A&E department.
The standard practice for hospital helipads worldwide is to locate the helipad
whenever possible as stated at ground level. If for reasons of
exceptional building density a roof top location is df~~j':~~~~~~-
should be at the highest point of the roof for safe a
takeoff.
2. Parking
2 8 SEP 2015
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This applies both to patients, medical, nursing, and ~a medical starr as We"tt"~--'
deliveries, ambulance parking, and visitors.
The original hospital workhouses on the StJames site had their foundation stone
laid in 1667 with the facility opened in 1772 as an "Infirmary for the sick". Both
Jonathan Swift and Arthur Guinness were early board members. In 1916 it was
christened St. Kevins Hospital.
St. James Hospital resulted from the amalgamation of Sir Patrick Dunnes,
Stephens and Baggot St hospitals with St. Kevins hospital in 1971. Because of its
long and illustrious history many of the buildings on the site are listed buildings.
This creates considerable problems in planning the future development of the
site, and imposes serious restrictions. St. James Hospital has thus evolved in an
ad hoc fashion, without the presence of a master plan. The majority of the
current buildings are now outdated for a modern hospital and create
considerable inefficiencies from an operational point of view. It is now the
largest hospital in the State with 1020 beds. It treats 25,000 inpatients, 95,000
day patients and one quarter of a million of outpatients annually. It has 4,500
staff and has 367 underground parking slots as well as a small number of surface
parking areas, apart from the large car park which will form part of the site for
the proposed childrens hospital. The loss of these 560 parking slots will be
replaced underground in the childrens hospital and will no longer be available to
the general hospital. Traffic chaos exists currently on the site with cars parked up
to three deep in some areas in a totally disorderly fashion.
Dublin Council have clearly stated that cars are unwelcome in the city area.
Hospitals require easy access and parking. Plain common sense would thus
suggest locating the hospital outside the city area. The best public transport
systems cannot compensate for vehicular access. This is an absolute priority in
uired for
the .number of wheelchair and disabled patients atte ~7~~il&llaLc@*NALA
bas1s
E
BY
Failure to provide parking for critical members of sta I and the~ ae~fed~86 on
public transport will ensure significant staff shortage ~ltMr~ bility to kecruit
staff. A recent poll of senior nursing staff in one oft
rrent p"m!dlah i~ OM _ __.
hospitals indicates that at least 25% of the staff will n~o~~~~~~~;;i=:~J
hospital site without onsite parking. I understand that St. James adult hospita
already has a significant shortage of nurses, app 130, and that recruitment is
proving very difficult. I would anticipate a significant exodus of existing staff
when parking prohibition is introduced. The staff have already been notified that
on site parking will not be provided for the adult hospital once construction of
the childrens hospital gets underway. The single lane side roads adjacent to the
hospital will look pretty crowded with cars from the additional 2,300 staff from
the childrens hospital.
Many members of the HSE staff, including many involved in the planning of the
new Childrens hospital already travel by taxi at the tax payers expense, due to
the inability to park on-site.
The new Alder Hey Childrens hospital in liverpool, designed by the same senior
architectural practice as the proposed new National Childrens Hospital has
provided 1,200 parking spaces. The recently built Queen Elizabeth adult hospital
in Birmingham has provided 3.13 car parking spaces per bed. The new Childrens
hospital in Melbourne has provided 6.7 car parking spaces per bed. In the US the
Cincinnati Childrens Hospital has expanded their parking facilities to 13 spaces
per bed. Compare this to 2.1 spaces planned for the new Childrens Hospital at
St. James.This assumes that the 560 spaces removed from the adult hospital will
be reallocated to the Childrens Hospital.
Applying the standard parking needs of a modern hospital, the St. James site
before contemplating the parking needs of an onsite maternity hospital, Trinity
Research and Educational facility, relocation of St. Luke's hospital and the
expansion of the adult hospital as indicated in the Site Capacity study submitted
by the NPHDB requires in excess of 6,000 parking spaces. Dublinc City Council
has limited the total number to 2,000 spaces for the entire site due to the
inadequacy of the local road network.
It is interesting to note that parking has overtime proved a major challenge at all
three hospitals with which I am associated. Blackrock had to add 350 additional
spaces to cater for 165 beds, giving a total of 570 slots. i.e. 3.5 per bed. This
number is still ir'ladequate.
Galway Clinic added 400 additional spaces to the existing 355 spaces to cater for
146 beds. i.e. 5 per bed. The Hermitage Clinic with 494 spaces for 101 beds has
a major traffic problem due to the supply roads being blocked with abandoned
cars. i.e. 5 per bed. A few hundred additional space areA'
! he
Hermitage to satisfy their demands.
TIME
D PlEANALA
3. Cost
ay
28 SEP 2015
The Blackrock Clinic, since its inception 30 years ago, has purchased two
adjacent premises, land for a multi-storey car park, the adjacent garage to
increase its surface parking, the adjacent Sian Hill domestic science school
premises and grounds, and the hospital itself has doubled in size with the
addition of three new floors.
The more recently developed Galway Clinic, now 11 years in operation, has
already undertaken 6 separate building and expansion projects. These
include a 500 multi-storey car park, a 50% addition to its inpatient bed
capacity, a doubling of the day care unit, a trebling of the laboratory space,
an additional radiotherapy bunker to accommodate stereotactic
Radiotherapy which was not available 11 years ago, and an interventional
theatre. Construction is currently underway to provide space for a second
MRI scanner, and plans are at an advanced stage to build a new A&E
department~ and doubling the capacity of the cardiology department with an
additional Cardiac Catheter Laboratory.
The one thing we can be sure of when planning a new hospital is that over a
short period of time new modalities of treatment will become available, yet
at any given moment in time we have no idea what these may be. Some of
these new facilities must be housed in newly built add on facilities as they
cannot be accommodated in existing buildings due to specific requirements,
such as radiotherapy where 9 foot thick high density concrete bunkers are
required for radiotherapy shielding. Such bunkers due to their weight can
only be placed at basement or ground floor level.
Proton Beam therapy which is still in its infancy requires substantial space
and shielding requirements. It can never be accommodated on the present
St. James site due to space restrictions. It will become a standard modality
for the treatment of certain tumours, and already some patients travel
abroad to avail of this treatment.
Hospital and Airport planning share the same need for future proofing.
When one considers the original Collinstown (Dublin) airport 50 years ago it
consisted of the original terminal building with a smal f111"RW1~~~~~-~-
spaces. Who would have considered the extraordina
occur over the next SO years.
6. Co-location or Tri-location with a Materni
2 8 SEP 2015
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The overriding priority in locating the New National lfildrens Hospital is its _ ___,
proximity to a Maternity Hospital. .Hight risk pregnan~c:t.els~,:;r;;;~;;:;;:;;:a:::===d
born children will require immediate access to sophisticated care including
cardiac surgery, should ideally be delivered in an adjacent maternity
Hospital. This need has been unmet in Ireland. The concept of a new National
Childrens Hospital with the exclusion of the Maternity Hospital is
unthinkable. The original proposed site for the Maternity Hospital at St.
TIME
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28 SEP 2015
28 SEP 2015
____...
The two centres designed for Tallaght and Connolly are no~~EfD:IHt~NALA
and can be sited in any general hospital. In fact most h sT/Mfis around th! V
country deal with secondary paediatric problems in a t tally co rrrgt~ru
fashion.
~tP 2015
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14. Coombe hospital & its potential to accommodate the 'JMoposed Tut Ure
Maternity hospital
It is acknowledged by all experts in the field that the maternity Hospital
should be located adjacent to the tertiary paediatric centre otherwise lives
will be lost due to delays in transferring critically ill babies shortly after birth.
Even short ambulance journeys will seriously jeopardise the survival of some
infants due to dislodgment of endotracheal tubes and intravenous and
arterial lines and drips. Thus the Coombe Hospital cannot be considered as a
collocated Maternity Hospital. Designating the Coombe to serve in this
capacity would be a grave error and would result in avoidable infant deaths.
--~
15. Visual & streetscape impact on the local & wider environment
The proposed Childrens Hospital is visually attractive based on the visuals
supplied with the planning application.
These are, however, deceptive as they show large amounts of green areas
when viewed from the air. However, almost all of these areas are on roof
tops and large trees are shown growing out of concrete! There is provision
for 450mm of clay on the rooftops to sustain growth of plants and some
deeper areas for tree planting. Any foliage will at the most be low and
will prove difficult to sustain. A recent visit to the new Childrens Hospital in
Orlando revealed that all the green areas on rooftops were artificial grass.
Grass and planting was confined to the garden level. There is nothing worse
than withered trees and shrubs. Despite the best care with rooftop
planting sustainability is difficult with the exception of sedum roofs when
well maintained, but unsuitable for foot traffic.
The meadow area shown on the plan is designated for expansion and is the
only green area at garden level- some planning for a green future!!
The inner garden will unfortunately be largely overshado "' ........ nfthe
daylight hours due to the steep 4 storey extensions on al sidN.ol. t@QiilNlEANALA
extending four storeys in height fail to be sustained out f "'BMirete despita y
irrigation.
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2 8 SEP 2015
At street level the magnitude of the building grossly ove 1h'R~~ II the FROM
adjacent residential properties, with the building exten~ PB close tlr
--..-..
thepavement. All existing trees at the periphery of the ..~.-~;r:m=zmza:t::===='
16. Underground Infrastructure
Apart from the Drimnagh sewer already mentioned there is a multiplicity of
underground services, many which cannot be accurately localised at this
point of time. Rerouting of these multiple services adds greatly to the cost.
Uncertainty as regards the archeological heritage exists and the possibility of
multiple graves on the site are factors which could seriously disrupt the
programme. On this reason alone the current application must be rejected.
AN BORD PLEANALA
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2 8 SEP 2015
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