Home Page

150 Heather Walk
Portmarnock
County Dublin

21 August 2005

"Observations on the Response to the Further Information Request by
Fingal County Council regarding planning application F04A/1755 -
Parallel Runway"

On behalf of the Portmarnock Community Association, Uproar and the people of Portmarnock we wish to submit the following observations on the above matter.

Forecasts

The main criticism made by in the (PCA) Portmarnock Community Association's submission in regard to forecasts was that the methodology by which the EIS deduced the difference between the unconstrained and constrained scenarios - the with/without second runway - was vague and confusing. That was critical to the EIS argument that without the new runway jobs would actually decline at Dublin Airport, but that with the runway, passenger numbers would be some 10 million more by 2025 and jobs would increase.

Some useful explanation is given on page 10 of the RPS report, notwithstanding the incomprehensible paragraph beginning with the phrase "It is important to note…" The obscure language used seems to hint that RPS are not entirely happy with what was done. Even though some clarification is made, the critical assumptions made to distinguish the two scenarios are not explained. We are particularly interested to know how the "diminishing returns" problem was handled. This is a reference to the fact that the throughput on the new runway will be restricted due to the limited area available for the manoeuvring of aircraft on the ground. It may be that only 50% of unrestricted capacity can be achieved. How was this problem dealt with in determining the unconstrained scenario, or was it ignored? If it was, then the extra passengers that could be handled by the new runway by 2025 may only be 5 million rather than 10 million for the same cost.

Regardless of the quality of the forecasts for passenger numbers, etc., Uproar (a sub-committee of the PCA formed to oppose the new runway at Dublin Airport) continues to believe that the use made of these forecasts in the EIS is flawed. Our case was put in a MS Word document entitled "Jobs". There we demonstrated that the so-called economic assessment in the EIS was seriously in error. Quite silly assumptions were made. For example, it was assumed that all jobs created by the new runway would be additional. Although the report states that "deadweight" and "displacement" are not taken into account - i.e. the report ignores the question of alternative economic activity that would have continued or that would be displaced. That is an insufficient excuse for a gross methodological error. A serious study would not and could not ignore these factors as to do so invalidates the analysis. In effect the so-called gains in jobs and income are not net gains at all. Uproar pointed out that in a situation of low unemployment, most of these jobs would be diverted from elsewhere and would be likely to drive wage inflation in North County Dublin as well as adding to house-price inflation, road congestion, etc.

Further, the assumption was made that the wages paid to this labour is an economic benefit. They are not. Wages are an economic cost, and a high one, as the opportunity cost of labour is high at times of low unemployment. In addition, jobs at Dublin Airport are made to disappear for the no runway scenario, because the labour productivity growth figures used were heavily distorted by high-tech manufacturing productivity growth, such as that of pharmaceutical companies like Pfiser, who make Viagra. It is simply ridiculous to use these national average labour productivity projections to project the number of future service-type jobs at Dublin Airport. FCC ignored all of these points in calling for Further Information. RPS say in their covering letter that they were "taking account of third party observations and objections in the planning file."

However, no changes have been made to the main Employment and Economics" chapter. Not one figure has been changed. No adjustment has made to the labour productivity forecasts used to make jobs "disappear" at Dublin Airport if the runway is not built. In our submission we pointed out the error and also noted that, on enquiry, the ESRI confirmed to Uproar that the figures used were not even the latest ESRI data available at the time the EIS was submitted.

We were also critical of the lack of sensitivity analysis in the original report. No proper sensitivity analysis was done. Making midline, high and low growth assumptions is not rigorous testing of a model. An Annex A is added to the new report. It claims to constitute a sensitivity analysis but merely repeats the High Growth Forecast figures of the main report to arrive at the following rather obvious conclusion:

"This analysis shows that the economic impact case for the proposed new
East-west runway at Dublin Airport is significantly more robust if passengers and freight grow in line with the High Traffic Forecast."

No sensitivity analysis has been done as required by the Further Information Request.

In summary, our concerns have been ignored. A totally flawed methodology was used by identifying jobs and related income as economic benefits. In estimating jobs created, no account was taken of the impact of more job creation in a low unemployment, congested environment. A gross error was committed by using out-of-date ESRI labour productivity forecasts and applying them to make service-type jobs disappear if no runway is built. No sensitivity analysis was done. This jobs analysis should be completely rejected by Fingal County Council, as it is completely misleading. A copy of our revised "Jobs" report is attached. What is needed is a proper cost-benefit analysis which would also look at alternative locations for a new runway/airport. Such a study is required by the Department of Finance, but so far, has been avoided (see below).

Road Traffic
There have been no changes made to the road traffic predictions made in the original EIS, the model used has not been changed and all comments made in the Uproar Findings report are still valid. Incredibly, the model used did not even incorporate the Port Tunnel. The further information provided confirms observations made in our summary Findings report. The comments by RPS at the top of page 22, effectively that the road junctions will be over-capacity, "regardless of any development impact from the Airport." is an admission of the problems that will be encountered with traffic congestion. How ever bad the situation might be without the new runway, it must be worse with it. In fact the new runway will result in a doubling of car trips to the airport (over 2004 numbers) by 2025 even with the Metro in place. This is stated in the EIS section 13.3.4.2 .
The report goes on the advocate that it is the government's responsibility to fix the congestion problems around the airport. That is asking the taxpayer to pay for the congestion costs created by Dublin Airport. Those costs should be included in a proper cost-benefit assessment of this proposal and added to all the other hidden costs that are being ignored by the DAA. However the EIS has shown that even with all road improvements, junction improvements, and a metro, there will be severe congestion on the M1 motorway, and M50 by 2025 with the airport catering for almost 40 million passengers per annum.
The most important part of RPS comments is on page 20 where it is said:
"The traffic assessment reported as part of the EIS was based on the 2001 model. The DTO are in the process of calibrating and validating a 2004 model. It is therefore recommended that this information be utilised once it becomes available."
This is clearly a recognition that the traffic analysis submitted with the original EIS is inadequate and has to be redone. That is consistent with the findings of Uproar's traffic consultant, Robert Kelly. The summary of his Findings report is attached. He recommends that the EIS traffic analysis be submitted for verification by the DTO. It is clear from the RPS comment above that the DTO would reject it as being based on out-of-date information. It follows that the DAA runway planning application should be rejected by FCC as the traffic analysis, a critical factor in assessing the impact of the proposed runway, is flawed and inadequate.

Aircraft Operations
1. The use of the 30th hour to establish the planning peak hour is a much outdated approach. This method was adopted from the US Highway Capacity Manual of the 1960's in the absence of any other measures but has not been used by ICAO for more than 20 years. DAA has used different other methodologies in earlier submissions which undermines any conclusions drawn from this latest approach to capacity forecasting.

2. Comparisons with other European airports are selective, misleading and far too simplistic. Runway capacity is a product of aircraft patterns, mix, sectors and schedules. It is interesting to note the exclusion of Gatwick which is designed to have a throughput of 40 million passengers on just one runway.

3. On DAA's estimates the new runway will reach capacity in 2030. There are no plans put forward to deal with this situation. This is a fundamental omission and a clear indication of the ad-hoc nature of this planning application. We believe that the Fingal planning authority is not in a position to deal with this application until it is in receipt of a national aviation policy in relation to the delivery of future airport capacity throughout the country.

4. The 10 to 15 million shortfall predicted by DAA for 2030 should the new runway not proceed would not be lost to the country but rather would form the critical mass which could and should be used to sustain the construction of a second Dublin Airport.

5. Repeated references by DAA to preferential runway usage are meaningless and worthless as it is the IAA which operates the runways.

6. The use of diagrams to support this preference (Figure 1) is highly misleading in suggesting that either only light aircraft would use Runway 28R or that there would be a fewer number of arrival operations on this runway.

7. No attempt has been made to factor in the impact of the new terminal on ground movements, runway usage or airspace operations. This is a very serious failure, as the DAA are demonstrably not fully exploring all of the options and impacts.

8. The point is made that approaches by medium and heavier aircraft join the final approach east of Howth Head for Runway 28 and therefore pass to the south of Portmarnock. This is the case today and will remain the same for future operations on Runway 28L. However no mention is made of the approach operations by the same aircraft that would be assigned to Runway 28R and would pass directly over Portmarnock. It is indicative of this planning application and the provision of additional information that only part of the explanation is offered but the critical case affecting Portmarnock is hidden or overlooked.

Environmental Issues

FI 2b. The Sluice catchment consists mainly of small ditches down the sides of fields, some leading into a lake at Kinsealy, which is already subject to contamination from discharges from the airport. The outflow from this lake is the Sluice River, which has already had to be deepened to eliminate flooding.

The runoff of existing car parks within the airport complex contributed to flooding in this catchment. It is likely that the calculated volumes of water involved will entirely overwhelm the Sluice river system. Flooding already occurs within this catchment downstream of the airport facility.

It should also be noted that this river flows into Baldoyle estuary, a Nature Reserve. It is a Special Areas of Conservation, a Special Protection Area, a National Heritage Area and a Ramsar Site and is protected under the Wildlife Act, 1976 and the Habitats Directive (92/43/EEC).

The reserve is rated as of international importance for Greenland White-fronted Geese, an Amber listed species
FI 2d. It is indicated that the portion of the runway within the Ward River catchment will be directed into the Sluice River Catchment. This will further exacerbate the problem of the volume of water involved by effectively increasing the catchment by 18.706ha.
FI 3a. The monitoring of all runoff is commendable, however the nature of the BOD test does not lend itself to a speedy assessment with a time scale of 5 days for the test.
Automatic diversions of waste streams are subject to error especially without continuous oversight by trained personnel. Some evidence from existing discharges would be useful to show that such monitoring is possible.

FI 3b. Forest Little/ Sluice River Catchment.

There is no additional evidence supplied to show that the water discharging from the new runway and its environs into this catchment will achieve the national limit values. Simply stating what is expected does not make it correct. Evidence of the quality of the water discharged from the existing runway could have been supplied to support the statement. In the absence of this evidence is could be assumed that it would not support the statement. The BOD is not the sole measurement of these limits. (See Appendix 1)
It is likely that the temperature of water discharging from the expanse of runway especially in summer will '(a) exceed the unaffected temperature by more than 1.5°C,'
There will undoubtedly be a significant amount of petroleum oils, caustic hydraulic fluids and other materials continuously carried by rainwater being discharged from the facility. This is a recognised problem with motorways however the concentration will be higher from a runway due to the 'point source' of the discharge.
There is no plan to monitor these discharges.
Since the discharge will constitute a major part of the flow of the river this will have a detrimental effect on the nature of the river and to Baldoyle Bay.
FI 3c. There is no evidence that the foul sewer and the sewage treatment plant will have the ability to cope with a pulse of contaminated runoff from de-icing. With the low temperatures involved it may be expected to poison the treatment plant leading to major problems for the treatment plant. As the odour problem in Ringsend Sewage Treatment Plant has shown, the biological systems involved have to be maintained in a delicate balance.
FI 7c. It would have been appropriate to have repeated the test to confirm that the test was an anomaly. The glib explanation of the presence of glycol in a borehole from a sample taken in August is very worrying.
The presence of glycol in this August sample could mean that a leakage was occurring from a storage facility at the airport as any material from winter de-icing should have already been attenuated in soil.
It can be expected that there will be contamination in the groundwater, especially since infiltration of runoff is being encouraged (FI 2 (e)). This contamination could be transmitted to wells in surrounding land.
FI 9e. The Sluice River flows into Baldoyle Bay, a Nature reserve, in which Greenland White-fronted Geese, Shelduck, Pintail, Golden plover, Black-tailed Godwit and Bar-tailed Godwit , Amber listed species, winter.
This is the river which will take the total runoff from the Northern Parallel runway. Any contaminated runoff will have a deleterious effect on this important site, especially on over-wintering birds.

Other Matters: Cost Benefit Analysis
Uproar has carried out an illustrative cost benefit analysis of the proposed runway at Dublin Airport and of a new airport on a green-field site, with good communications and away from residential areas. Somewhere in the region of Newbridge, only 35 km from the M50, is one of many possibilities. Consideration might also be given to the recent proposal by John Hourican of Bórd na Móna to provide a site six times the area of Dublin Airport for a new airport less than 30 km from Dublin near the M4.

As Uproar has pointed out there are large costs associated with the Dublin option. These include the cost of congestion to millions of road users and airport users due to the extra traffic generated by the new runway, which it is claimed will generate ten million additional passengers by 2025. There are also the costs imposed on the 10,000 people of Portmarnock by increased noise, air pollution and flooding.

In addition, the huge opportunity costs of the land destined for this new runway cannot be ignored. It is very valuable land, worth about €1 million an acre as development land (maybe twice that if zoned residential). Further, large areas of land will be sterilised or allowed only restricted development because it will be within the inner or outer safety zones under the new runway's flight path. The sub-optimal use of this land is another large economic cost of this project. More than 3000 acres are affected in the outer safety zone where residential and other development will be restricted. According to experts this land will lose on average from €500,000 to €750,000 of value per acre because of these restrictions. In other words if the runway was not built and this land was released for development it would add, at the conservative €500,000 per acre, €1.6 billion to its value. The loss of that development to the Fingal area and indeed to the coffers of FCC is colossal. The main benefit of the project is the increase in business as represented by the extra passengers (10 million by 2025 - adjusted to 2029 because the timing of runway has changed) but only a share of that benefit can be credited to the new runway. There are then the construction costs of the project.

We have made rough estimates of all these costs and benefits and conclude that the Dublin option is a huge economic loss. The ratio of benefits to costs is 2%. I.e. the benefits are only 2% of the costs. Total benefits are €70 million. Total costs are €3 billion. The net benefit is therefore -€2.9 billion, an economic loss of nearly €3 billion. The Internal Rate of Return (IRR) is too negative to be calculated by the Excel program.

The alternative considered is a green-field site for a new airport assumed to be convenient to good road and rail links. A construction cost of some €2 billion is assumed. (The new Kuala Lumpur Airport was built for $2.5 billion). That seems high as Pier D, the second terminal and the new runway at Dublin Airport will cost, according to the DAA, under €500m. There is reason to believe that these DAA estimates are far too low. Also, some additional transport infrastructure will be needed: a rail spur and rail terminal, motorway exits and link roads. For the alternative site there are few costs for noise, traffic congestion, pollution or flooding; land is valued at agricultural prices, and only a few residents (on farms) are assumed to be disturbed, as the site is located away from residential areas. The airport charge is set so as to break even at the Regulator's discount rate of 7.4%. The benefit/cost ratio is then 1.0, as required to break even. Benefits are equal to costs and the IRR, as expected, is 7.4%.

The estimated airport charge per passenger to break even is €6.4 (averaged over an assumed 30 year period). That is comparable to the draft rates proposed by the regulator for Dublin Airport. However, Uproar believes that the draft rates are much too small because they ignore huge costs such as the opportunity cost of the land needed by the new runway (€840m) and of other land subject to restricted development by the runway flight-path (as detailed above). If the rates for Dublin Airport were truly set economically, charges could easily be a multiple of those of the new airport. For example, if it costs €2b just to build an airport (before counting the land) how can Dublin Airport in its entirety (on 2500 acres) only be valued by the regulator at a little over €600m? If charges were set correctly for Dublin (at something like €25 per passenger), the new airport at €6/7 per passenger would be very competitive. Consider what a boon a new super airport would be for the economy of an area 30 km to 50 km southwest of Dublin. No allowance was made for these benefits in our illustrative study, but they should be considered. Some such benefits may also accrue to the runway at Dublin Airport but, in our opinion, they would be limited due to road congestion and low unemployment in Fingal.

In summary, if the runway is built at Dublin Airport we are throwing away about an estimated €3 billion. That is a total write-off. If a new airport is built in a suitable area, even though it will cost about €2 billion to build, we get our money back with 7.4% interest. And users of both airports will get the benefits of real competition.

Uproar's estimates are rough but are indicative of the huge economic disadvantage of the proposed development at Collinstown. We do not propose these figures be taken as definitive but rather to show that there is an overwhelming a priori case for a proper independent cost-benefit analysis to be done as required by the Department of Finance's own guidelines for the appraisal of public capital projects. As these guidelines have been ignored to date, Uproar is calling for a full study to be carried out by specialists independent of the DAA and FCC. Planning permission should be withheld until such a study identifies the best economic option for additional runway capacity.

Other Matters: Health

In the PCA's submission to FCC objecting to the planned runway, observations on the health issues treated or ignored by the EIS were made by Dr. Anthony Staines of UCD. Nothing in this additional information submission by the DAA addresses these comments in any way. In particular there is still no indication of any recognisable health impact assessment having been done. There is a consensus amongst workers in this field that a project on the scale of a second runway requires a full Health Impact Assessment.

The EPA guidelines for EIS also require such an assessment for projects of this scale - see the "Advice Notes on Current Practice in the Preparation of Environmental Impact Assessments", Environmental Protection Agency, September 2003. Planning permission should not be given in the absence of a satisfactory HIA.

Our concerns are heightened by a UCD study carried out for Uproar which shows that, inter alia, levels of Benzene - a cancer-causing agent - are very high in the Portmarnock area. The DAA's explanation of "idling cars" at Portmarnock is ludicrous given that the number of idling cars at Dublin Airport is hundreds of times those at Portmarnock. Fingal county councillors have a duty of care to the people of Fingal. Failure to carry out a Health Impact Assessment will render them individually and collectively liable for any ill heath suffered as a consequence of this runway development.

Other Matters: When is this runway needed?

On page xiv, the EIS says:

"It is envisaged that the scheme would be constructed over a period of
approximately three years (between January 2007 and January 2010)."

It is stated on page 5 of the FCC Planning Officer's Report (Ref P/0436/05) of 10 February 2005:

"It is anticipated that the proposal will take three years to build, with construction proposed to commence in January 2007."

On page 7 of the DAA's Annual Report and Accounts 2004 we have the following:

"Based on current traffic forecasts it is believed this will be needed in full operational mode by 2012."

In their submission to the Aviation Regulator the DAA present details of their capital expenditure programme (capex), including the new runway. (See Aviation Regulator's Website). The table in Annex 7, Part 3, has no title but indeed it looks like the DAA's capex programme. Under "Stands and Airfield" for the years 2012, 2013 and 2014 we have capex amounting to €141.65 million. A figure of €141 million labelled "runway" in 2013 also appears in a chart entitled "10 Year Capital Plan Elements" in Annex 7, Part 2, "Capital Investment Programme 2005-2014." This seems to confirm that the DAA's capex plan now envisages the runway being built around 2013. Page 19 of Annex 3, the William Hynes & Associates capacity assessment, says: "Therefore, based on the maximum mixed operations runway capacity of 45 aircraft movements per hour …an initial assessment indicates that the hourly capacity of Runway 10/28 will be reached by approximately 2013/14, at which time a second parallel runway will be required."

It appears that the DAA does not know when it needs this runway. Is it 2010? Is it 2012? Is it 2014? Is it later? If Ryanair are to be believe in their submission to the Fingal County Manager dated 9 March 2005, "..there is no requirement whatsoever for a new second runway at Dublin Airport." (See copy attached).

In the DAAs planning application to FCC they say 2010, and all their supporting documentation and analysis, e.g. road traffic analysis is based on that assumption. On page xvi of the EIS they state:

"The traffic assessment has shown that existing junctions can be improved to
provide sufficient capacity for the expected traffic volumes in 2010 with the
opening of the Northern parallel runway."

Yet they later give figures to the Aviation Regulator which say 2014 and their own annual report says 2012. This uncertainty casts doubt on all of their arguments for the runway and FCC should reject the planning application on the grounds that it is confused and misleading.

Conclusion

Fingal County Council is being asked to approve an application by DAA for a major new runway. Their plan is based on out-of-date methodologies, confusing arguments, flawed and misleading information, glaring and significant omissions and a reckless disregard for the health and well-being of Fingal residents.

Their plan is based on the growth in passenger numbers which has caused such chaos and congestion at the airport in recent times. However, it is clear that this chaos is a function of terminal, not runway under-capacity. While passenger numbers have increased by more than 50% in the past six years, aircraft movements have in fact declined over the same period. (See Figure 1, on page 5 of "Scenario Summary: Constrained Forecast 2003" of the FI supplied). What other industry would seek to justify a decision on this scale on such trends? Miraculously, the forecasters have contrived to defy the logic of the growth in aircraft size by producing a trend necessary to sustain the plan for a new runway.

Fingal County Council must see this plan for what it is: a knee-jerk reaction to criticisms and an unnecessary expensive and senseless project which will be a colossal economic loss, a liability to airline customers and a blighting of the quality of life of 10,000 Portmarnock residents.

Fingal County Council must reject this planning application outright.

On behalf of Uproar

____________________

APPENDIX 1
SECOND SCHEDULE

Salmonid Water Quality Standards