The plan for Spencer Dock in Dublin is over-developed, of poor civic design quality and will gridlock the area with traffic, according to the Dublin Docklands Development Authority.
The DDDA was making submissions to An Bord Pleanala as observers to the development, having responsibility to bring about the regeneration of the docklands area.
The DDDA said it was broadly supportive of Dublin Corporation's decision to give planning permission to the developers with alterations and conditions.
In particular, the National Conference Centre and the public transport initiatives were welcome. However, They were "seriously concerned" about a number of issues.
The DDDA Master Plan on the Dublin docklands area sets out a maximum of 247 units of residential development per hectare, according to Mr Terry Durney, director of planning and technical services.
Mr Durney said the figure for residential development in the application was 427 per hectare. Overlooking, overshadowing, usefulness of open space, and environmental and climatic considerations were also of concern to the DDDA.
The height of the proposed development would produce a "poor quality environment for both neighbouring property and in particular for the future occupants of the proposed buildings", Mr Durney said.
Mr Durney also said shadow studies showed the development would produce "poor sunlight penetration to many of the buildings".
He said the building heights, if adopted, would create a "serious injury to the amenities of local residents through overlooking with consequent loss of privacy". The DDDA pointed out that the development was the "antithesis of good urban planning" in relation to Dublin as a historic European city. It added that the development ignored the importance of space between buildings, whether they be streets, squares, water bodies or open spaces.
Mr Durney said: "I think as visitors we would be very surprised to hear if Vienna or Amsterdam proposed to import the type of development now proposed here into those cities."
Mr Durney referred to the Environmental Impact Study which concluded that any building in excess of 42.4 m over North Wall would impact on the view of the city. The impact of the development would be "very significant, particularly from the `Georgian mile' and from points along the Liffey".
In relation to traffic impact, Mr Durney said that while the development proposed the provision of 6,805 car parking spaces, a study undertaken by the DDDA showed that "the existing critical junctions are incapable of taking any further traffic beyond those generated by approximately 500 car spaces".
He said that if major work was carried out, especially in the Port Tunnel, more than 3,000 spaces could be provided.
Mr Durney said that while the residential area of the north side of the development area would be suitable for family living, the proposed development would not provide this "because of excessive heights, open-space configuration and lack of residential amenities".