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

Your Ref:

Triona Murphy Tallaght Hospital Action Group 19 Woodale Green Ballycullen View Dublin 24

30th September 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 Pleamila

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 Pleaoala 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,

Wl &~&,..._~ \' Kieran Somers

Executive Officer Direct Line:O 1-873 7107

Encls.

ADHOC/P A0043/01

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9/28/2015

Triona Murphy. Tallaght Hospital Action Group, 19 Woodale Green, Ballycullen View, Dublin 24.

The Secretary, An Bord Pleanal~ 64 Marlborough St, Dublin 1.

Dear Sir/Madam,

AN BORD PlEAtl4~ . TIME BY ( ./ t:r;;\ -----....

2 9 SEP 2015 LTR·DATE0.2g { 3 FROM _gf Pl

Please find enclosed our submission in regards to the planning permission sought by the National Paediatric Hospital Development Board and the fee of so euro as required.

Case reference: PL29N.PC0158

Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at StJames' Hospital Campus, Satellite Centres

at Tallaght and Connolly and Construction Compound at Davitt Road, Dublin.

Receipt No: Yours sincerely,

Triona Murphy.

Tallaght Hospital Action Group

Bo~d Ple.anala submission

Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Famiiy Accommodation Unit at St James' Hospital Campus, SateUite Centres at Tallaght and Connolly and Construction Compound at Davitt Road, Dublin.

Case reference: PL29N.PC0158

Triona Murphy

28/09/2015

AN BORD PLEANALA TIME BY

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Bord Pleanala submission.

The Tallaght Hospital Action Group, (THAG), is a community organisation formed in 1991 to lobby actively for the building of the AMNCH Hospital at Tallaght .The action group has a variety of members from the broad Tallaght and catchment area .We are not affiliated to any party political organisation. Many of our members are also part of other community groups involved in promoting and expanding community facilities in Tallaght and the surrounding areas, and some have extensive experience of participation in planning processes either in professional or voluntmy capacities. We were present throughout all the Bord Pleanala oral hearings for the failed Mater site proposal and made written and oral submissions. During the last 20 years TIIAG has been involved in tiying to expand and improve the facilities the Hospital provides to an ever increasing population in its catchment area We are not architects, planners or medical professionals. We, ARE, however parents and grandparents and as such we are as well qualified as any to point out the inadequacies in this project. We now find ourselves making a submission again to the Bord about the proposed Health Infrastructure Development comprising National Paediatric Hospital, Innovation Centre and Family Accommodation Unit at StJames' Hospital Campus, Satellite Centres at Tallaght and Connolly and Construction Compound at Davitt Road, Dublin.

In opposing the planning pennission, our arguments fall under four headlines:

l.Site issues at the James Campus relating to the Model of Care and need for expansion

2. Car parking for the entire campus.

J.Lack of designated funding for parent accommodation.

4. Consultation. -AN BORO PlEANALA

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1. Site issues at the James Campus relating to the Model of Care and need for expansion

In making our submission it is appropriate to lay out the previously published plans for how the hub and spoke plans for children's hospital services. In Oct 2007 Rawlinson Kelly & Whittlestone Ltd (RKW) published its report on the planning of the integration of paediatric hospital services in the Dublin area (appendix 1). We can presume that the National Paediatric Hospital Development Board (NPHDB) used the population analysis in this report as the bed capacity of the James' campus matches the bed capacity numbers in this report. This report however laid out in clear tenns the services which should be provided at what were then called Urgent and Ambulatory Centres and are now simply referred to as "satellite centres". RKW's recommendations state that 28 day case capacity would be required at the Tallaght Campus, 23 consulting rooms for outpatients and 5 operating theatres. It oudined the need for Ambulatory and Urgent Care Centres to relieve the pressures and unwarranted visits to the tertiary hospital and used attendance numbers for day case surgery, outpatient attendances and ED presentations to back this case. It highlights that while all first attendances in outpatients in general surgery, paediatrics and psychiatry should be at the Tertiary hospitals many second and subsequent appointments should be held in the Ambulatory care centres. It draws on the examples of international best practise which universally states that care is best provided as closely to home as possible where it is safe to do so.

RKW supported its decision to locate an Urgent and Ambulatory Centre at Tallaght with population data It was evident from the maps that the areas of highest paediatric population in 2021 are grouped in 4 zones -• North East including North County Dublin

• North West including Dublin 15, Dublin 11 and County Meath

• South West including Dublin 22, Dublin 24 and County Kildare

• South East including South East County Dublin and Wicklow.

-AN BORO PLEANALA

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This model of care was re-iterated in the Frank Dolphin report in June 2012.(appendix 2) It states that Secondmy care which required specialist paediatric input as inpatient or outpatient should be provided at urgent care centres linked to the tertimy children's hospital - examples include gastroenteritis with dehydration (inpatient care) or troublesome asthma (outpatient care).

AN BORD PLEANALA TIME BY

2 9 5£P 2015 THAG would also like it noted that the Irish Associ ~~ergen~~O Medicine in 2007(appendix 3) stated that the opw.llU:IItK:o~.lt'ergeney M __ _, Department service provision would not be best serv~ri~=M~=====::::::::d fully functioning ED department for Children. They stated that approximately 120,000 children attend the three existing Paediatric EDs each year. Therefore, any Emergency Department obliged to receive all children requiring ED care would have to expect to receive similar numbers. Indeed, this number may rise as the population of the greater Dublin region continues to grow.

.. There has been an increase in paediatric attendances in the UK in recent Years, which shows no signs of abating. Quote taken for the report on ED attendances in the UK from the independent research facility in the UK Quality Watch "There has been a sizable increase in the number of A&E attendances, from 16.5 million in 2003/04 to 21.7 million in 2012/13, a rise of32 per cent. However, more careful inspection of the data revealed that this rise was almost exclusively acting on minor A&Es (for example, urgent care centres, minor injwy units and walk-in centres). Although attendances at major A&E departments had also been increasing, this was at a much lower level Gust 13 per cent between 2003/04 and 2012113)"

See appendix 4 for link to full report

A single Dublin paediatric ED would see nearly twice as many patients as any existing ED in the country. It must be designed, built and resourced in line with current best practice and have the ability to be future-proofed for the inevitable increase in attendances over time.

Inter alia, the KPMG report on Maternity services (appendix 5) reconunended were that the Coombe Hospital should be relocated to the Tallaght site. Again detailed population analysis was produced for the location of mothers attending the Coombe. I quote the report "Almost 60% of births originate in Kildare, Wicklow and south Dublin. This represents approximately 13,440 births in 2006." And that for maternity, the demographics clearly support the development of a maternity service at Tallaght Hospital. Almost 20% of the Coombe's activity originated from Kildare. This area is predicted to grow and therefore a service in Tallaght Hospital is the best option for women from this area." It should also be noted that in the 2008 KPMG report St James Hospital was out ruled for the Coombe because the travel times for the vast majority of Mothers (who attend the Coombe) was deemed to be too long. It highlighted that in a majority of cases the travel times would be in excess of 60 minutes as opposed to a majority accessing Tallaght campus in 30 minutes.

The planning applications for the Satellite Centres have been included with the main hospital development. This shows that much of the previous (and agreed) model of care has been ignored. We can see that minimal outpatient care will be provided at Tallaght and Blanchardstowns Hospitals. There will be no day case surgery or any inpatient beds at either location. Therefore all tertiary, lJdjr~,-:~~,.~ .... A'=:~~-~-­

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inpatient activity and Emergency Department presentations will be provided at the James' Campus. The NPDB will assert that parents and children should and will attend the local satellite centre for minor injuries and illnesses. This in effect is asking parents to triage their own injured and sick children. We have seen, in Ireland, in the adult hospital situation that when local smaller hospital EDs have been downgraded that there is a substantial increase in the larger hospital EDs. When faced with a sick child parents will travel to the .. main" hospital and will bypass the satellite centres. Once current paediatric hospital care has been removed (i.e. Our Lady's Hospital Crumlin, Temple Stand the National Children's Hospital in Tallaght) it will be impossible to re-instate. In researching for this submission I have failed to find any hospital in Ireland that has NOT increased bed capacity in the last 10 years. Tallaght Hospital, when planned, was to have a 700 inpatient bed capacity. In 1998 it opened with 520 beds. Today the bed capacity in Tallaght Hospital is 721 beds.The Dolphin Report (appendix 2) stated that the optimal expansion capacity should be in excess 20o/o. International best practise states that expansion capacity should be excess of25%. Neither are achievable at the James Campus.It must also be noted that James Hospital is a tertiary centre for many adult specialities. Adult hospital capacity will need expansion capacity also. The proposed maternity hospital planning application has not been included here. Birth rates in Ireland remain the highest in the EU and shows little sign of slowing. Therefore it can be presumed that in the future the capacity for maternity services will require room for expansion. There quite simply put is not available space at this campus to future proof, for even, the only children's hospital in the Greater Dublin area.

2. Car parking for the entire campus.

We have previously outlined the extent of the services which will need to be delivered at the tertiary children's hospital planned for James' hospital campus. We know that car parking for sick children and their parents will be highlighted in many objections to this planning. It is disingenuous of the NPDB to suggest that parents will avail of public transport to access the new hospital. All reports from the existing children's hospitals and indeed internationally show that the majority will travel by car. Indeed in many cases which the NPDB do not highlight is that in many cases there is little choice for parents of very sick children. These children may be immuno suppressed and/or need to bring medical equipment e.g. oxygen, wheelchairs etc with them to hospital. The NPDHB indeed seem to forget

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that in many cases more than one child will need to be transported to the Hospital i.e. siblings and/or in the case of twins, triplets etc. As we have previously stated St James is the tertimy hospital for many adult specialties including care of the elderly, a variety of cancers etc. While discussing car parking it is vital to look at car parking for the campus in its totality. The extent of car-parking that is proposed with the new hospital is inadequate and the overall number of car-parking spaces which is

intended to be provided for the site to cater for the demands of the

existing hospital, proposed children's hospital & future maternity hospital falls well short of requirements & would result in insufficient car-parking

for patients and extremely limited car-parking for staff of both the existing and new hospitals.

Quote from traffic report (chapter 6 EIS submission) from NPHDB states

"The quantum of parking provided on campus will be capped at approximately 2,000 spaces, serving both staff and visitor/patient parking needs."

Car parking for staff must also be included. It is presumed in planning that staff will travel by public transport. No surveys have been completed to determine whether staff that will move to the new hospital have the capacity to access public transport. We know that many paediatric nurses working in Tallaght Hospital live outside ofDublin and therefore will drive and park at the new hospital. It is fair to presume that staff from temple St and Crumlin will be in a similar position.

Quote from traffic report (chapter 6 EIS submission) NPHDB goes on to

say "The car parking strategy involves the transfer of parking from staff to visitors/ patients as the hospital continues to expand. The additional travel needs of staff will be catered for through the Smarter Travel Programme which will be supported by the Government's continued investment in public transport projects in the Greater Dublin Area (i.e. 'Swiftway' BRT Network, DART Underground, Lucan Luas, etc •• )."

Again the THAG would like to stress that this is based on supposition and

not fact!

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.. Media reports that staff should car pool are ill advise<L unfeasible and not a solution to this obvious problem.

The additional traffic volumes that would be created by the new children's hospital and maternity hospital in this location will further increase traffic congestion on the immediate roads adjacent to the hospitaL in particular at the Rialto gate. This congestion would have a knock-on effect on the surrounding road infrastructure which already has difficulty in coping with existing traffic volumes.

Patients and staff of the existing and new hospitals would be forced to seek on-street parking on the roads in the vicinity of the hospital, due to the inadequacy of on-site car-parking as result of the new development and this would further add to the traffic congestion in the area.

Comparisons to current car parking at the existing children's hospitals used to suggest adequate parking in this proposal are disingenuous. There are vast areas of on street parking surrounding Crumlin Hospital. In Tallaght the adjacent shopping centre provides large numbers of additional car parking space. Temple St Hospital, of course, has little or no assigned car parking. Again I quote the Dolphin report which stated that 1,000 car parking for children's hospital alone car parking would be required.

We are expected to believe that 2,000 car parking spaces will accommodate all patients and visitors to the James St Hospital campus and this is before the proposed tri-location on site of the Coombe Maternity Hospital.

3. Lack of designated funding for Parent Accommodation.

The current provision of parent accommodation is provided in Our Lady's Hospital in Crumlin by the staff and volunteers of Ronald McDonald House.Such accommodation provides vital supports for parents of sick children. The charity is entirely dependent on fundraising and does not receive any state funding.

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.. We note from the Ronald McDonald House Charities Ireland Website (appendix 6) that extensive fundraising has begun to fund the 53 bed parent accommodation to be based in the St James Campus. The webpage estimates that up to 10 million euro will be required to fund the project. The parent accommodation will continue to be run by the charity and its ongoing funding needs will come from their fundraising endeavours. We question then why this is present on the NPHDB planning application. It would appear that this portion of the project will not be government funded but funded via the charity.The NPHDB will have no part or parcel in the running of this house and as such the planning application should be rights be made by the charity. As parents and grandparents ourselves it is very disappointing that this parents accommodation is not state funded and maintain that it should be. It is disheartening and could be said to be dishonest to see the planning permission included with the main hospital as if to suggest that there is state support for it.

4. Consultation.

We hear much from the NPDHB about how widely they have "consulted" parents and staff about this new project. We have had some contact with the residents groups surrounding the St James Campus and we know how disappointed they have been in this regard. We have read commentmy from Jonathan Irwin( CEO Jack and Jill Foundation) about his similar concerns. THAGs experience is no different. Ms Hardim~ as was the case in the past, agreed to meet with us in person and we are grateful for that. At this meeting we were "informed" as to the health care that would be removed from Tallaght Hospital and what would remain.

In the government publication entitled REACHING OUT Guidelines on Consultation for Public Sector Bodies (2004) (appendix 7) it states:

uconsultation for the purpose of these Guidelines means a structured public engagement which involves seeking, receiving, analysing and responding to feedback from stakeholders. "

This was not the form of consultation we would contend that took place and indeed replicates our last dealings with the NPHDB. It is again

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•• disingenuous for the NPHDB to say that it has consulted widely .It is truer to say they have simply informed widely.

Appendix 1.

http://www.hse.ie/englservices/publications/Hospitals/High Level Frame work Brief, National Paediatric Hospital. Part l.pdf

Appendix 2.

http://www .newchildrenshospital. ie/wp­content/uploads/20 15/08/Dolphin Group ReP-ort-1 .pdf

Appendix 3.

http://www .iaem.ie/images/stories/iaem/publications _position_ statements /2007 /iaem_position _paper_ on _provision_ of_ ems_for _children_ in _the __g da _following_ development_ of_ a_ single_ national_ tertiruy _paediatric _hos pital_150607 .pdf

Appendix 4

http://www.health.org.uk/sites/default/files/QualityWatch_FocusOnAEAt ten dances. pdf

Appendix 5.

http:/llenus.ie/hse/bitstream/10147/69303/1/MatemityReport.pdf

Appendix 6.

http://nnhc. ie/wp-content/uploads/20 15/06/RMH C-Ireland-Annua1-Report-2014.pdf

Appendix 7.

http://www. taoiseach.ie/eng!Publications/Publications _Archive!Publicati ons _20 11/Better _Regulation_ Archive.html

Triana Murphy, Chairperson, Tallaght Hospital Action Group, 19 Woodale Green, Ballycullen View, Dublin 24. AN BORO PLEA NA. LA .,

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