The Dublin Docklands Development Authority is "seriously concerned" about the £1.2 billion high-rise scheme proposed for Spencer Dock on the grounds of over-development, poor civic design quality and impact on traffic from too much car-parking on site.
Although the DDDA stressed that it welcomed moves to develop the 51-acre site - particularly the proposed National Conference Centre, which it sees as an essential element in the regeneration of Docklands - it wants to see the development scaled down.
In a detailed submission to Dublin Corporation, which is currently considering the planning application from a development consortium headed by Treasury Holdings, the authority said the addition of leisure facilities, creches and pre-school provision was also "critical".
"The proposed height and density of development will produce a poor-quality environment for both neighbouring property and for the future occupants of the proposed buildings, especially future residents," the DDDA's chief executive, Mr Peter Coyne, said.
"The building heights adopted also create a serious injury to the amenities of the local residents through overlooking with consequent loss of privacy," he said.
In the DDDA's view, Mr Coyne said the proposed development "fails" on a number of grounds. For example, it "ignored" one of the critical factors in urban design - that the quality of space between buildings was as important as the quality of the buildings themselves.
Many of these spaces would be in shadow, all but one of them lacked a sense of enclosure and wind turbulence would create "unpleasant conditions" at ground level. Overshadowing would extend to the Royal Canal, on the western perimeter, as well as nearby housing.
Studies carried out by the DDDA had shown that any building above 42 metres would also have an impact on the wider city skyline. With buildings of 80 metres or more, the impact would be "very significant".
The authority's submission to Dublin Corporation, which must take it into account in making a decision on the planning application, also opposes "fundamentally" the creation of a two-storey podium across much of the site.