Dublin Airport's expansion plans have to be properly evaluated under the new National Development Plan.

The DAA's new terminal and runway plans for Dublin Airport are included in the new National Development Plan 2007-2013. This means they will be subject to the stringent evaluation procedures that apply to all projects under the new NDP. For example, they must be subjected to a full cost benefit analysis in line with the Department of Finance guidelines of February 2005.

The Finance Guidelines should already have been applied and a cost benefit analysis should have been done before planning permission was applied for, as both the Terminal 2 and the new parallel runway projects will cost vastly more than the €30 million threshold to which this type of rigorous evaluation applies. However, the DAA admitted at An Bord Pleanála in October 2006 that they have not done the required cost benefit analysis. They have managed to avoid being brought to task on this, because under the Finance Guidelines it is a matter for the Boards of Commercial State Bodies, such as the DAA, to certify that they have conformed to the Finance Guidelines. DAA chairman Mr Gary McGann has told Minister Cullen that the DAA's appraisal procedures "reflect" the Finance Guidelines, even though the DAA has admitted it has not done the cost benefit analysis those same guidelines require. The evaluation work done by consultants for the DAA was not a cost benefit analysis and was clearly biased in favour of the DAA's proposal in its lack of rigour
and its feeble consideration of alternatives to the expansion plans of Dublin Airport.

Now that Dublin Airport's Terminal 2 and new runway plans are included under the new NDP it should be more difficult for the DAA to avoid submitting to the new requirements. The NDP's tough evaluation standards are derived from its earlier association with the EU's Structural and Cohesion Funds. Even though very little of the new NDP will be EU-funded, the new NDP claims it "is still largely modelled on
the good practice inculcated in the system by EU requirements." Although new public funds, national or EU, may not be directly required for these projects, as a public body, the DAA is required to justify it's investments. In any case, €1.7 billion worth of public (taxpayers') land will be consumed by the projects.

As spelled out on page 273 of the NDP document, all projects will be subject to project appraisal to ensure that NDP programme objectives and Value for Money are being achieved and all capital projects over €30 million will require a full cost benefit analysis in line with the Department of Finance guidelines of February 2005.

A Central Monitoring Committee, chaired by the Department of Finance, will monitor implementation of the NDP. A new Central Expenditure Evaluation Unit, based in the Department of Finance, will have oversight of all reviews and can carry out spot checks on projects. Minister Cullen has hidden behind confidentiality in refusing to publish cost benefit results for projects such as the Swords Metro. However, the new NDP requires that all evaluations be published and submitted to the various oversight bodies. It will no longer be sufficient for the board chairmen of public bodies to simply claim they have conformed to the guidelines.

Because the DAA failed to carry out a cost benefit analysis as required, Portmarnock Community Association carried out its own evaluation using cost benefit methodology. See: www.norunway.com/t2a/appt2.htm. We found that the expansion proposals for Dublin Airport will lead to a loss of €4.5 billion while a second well-sited airport built on a greenfield site to serve the Greater Dublin Area would yield a real rate of return of 7.4%, as required by the regulator, plus other spin-off benefits we did not quantify and which would not apply to the Collinstown site. An
important factor in this result is the value of land at Dublin Airport affected by the construction, compared with the availability of cheap land elsewhere in the Greater Dublin Area. Dublin Airport land is worth in the region of €2 million per acre while thousands of hectares of cutaway bogland available less than 50 km from Dublin are worth very little. This relative cost was ignored by the DAA. Other costs ignored in the Collinstown option are road congestion costs. It is not widely appreciated that the objective of the DAA is to treble annual passengers to 60 million a year. This will mean an extra 70,000 cars daily and gridlock on the M50/M1 network and huge economic cost. The NRA objects to IKEA's maximum load of 11,000 cars per day on its worst day on the grounds that it will undermine the €1.1 billion M50 upgrade.

We believe these findings to be robust and that a cost benefit analysis following Department of Finance and EU guidelines will confirm them. We will remain vigilant to ensure that the new evaluation procedures are properly followed in the case of the DAA's plans for Dublin Airport's unsustainable and uneconomic expansion.