"Objectives should be expressed in a way which will facilitate consideration and analysis of alternative ways of achieving them. They should not be so expressed as to point to only one solution." And

"It is vital that … analysis is objective. Its conclusions should not be prejudged. It should not be used as a device to buttress a case already favoured for or against a proposal."

The EIS, without even attempting to define an objective, starts as follows:

"Dublin Airport Authority proposes to construct a Northern Parallel Runway at Dublin Airport."

In the EIS (Chapter 5) it is stated that runway works will commence in January 2007 and be completed by January 2010. The FCC's planning officer confirmed in (Ref P/0436/05) that 2010 was the operational date he considered in arriving at his conclusions.

Table 6.8 of the EIS also implies that the new runway will be opened by 2010.

The Additional Information report by RPS McHugh still states that 2010 represents the opening year for the northern parallel runway when discussing "A revised Traffic Impact Assessment" (p21).

In the DAA Annual Report 2004, it is stated that the runway will be needed operationally in 2012.

The DAA's CAPEX programme supplied to the Commission for Aviation Regulation (CAR) envisages the runway being built 2012, 2013, and 2014.

Much is made in the EIS of references in the Dublin County Development plan of 1972 to two future east/west parallel runways at Dublin Airport. It is claimed that, because a northern parallel runway was envisaged in the 1972 plan, it validates their current planning application for a northern parallel runway at Dublin Airport. However, many developments were allowed by the Council subsequent to 1972 that are incompatible with the northern parallel runway envisaged in the 1972 plan and thereby overrule any historical validity for the current runway proposal.

The text of the plan states in paragraph 2.18: "The Council is aware of the Airport Authorities' intention to construct new East/West runways and that the use of these runways will confine most of the noise nuisance largely to lands running East/West across the county. Approach noise will in part be absorbed over the open sea. The Council is informed by the Airport Authority that noise will be significant within the East/West strip and it is their policy therefore not to make infrastructure for development available in these lands."

Further, on the General County Map with the 1972 plan, the areas east and west of the airport, and as far west as, and including Portmarnock, are hatched in with the designation "Noise Area". "Development Areas" are designated for Swords and Malahide, but Portmarnock is excluded. It is quite clear that the northern parallel runway envisaged in 1972 was predicated on the condition that Portmarnock not be developed because of noise from its flightpath over Portmarnock.

Subsequent to the 1972 plan, Portmarnock was developed into a town of 10,000 people. In permitting that development in contradiction of the 1972 plan, the Council negated the northern runway component of that plan. It is therefore disingenuous of the DAA to appeal to that same plan in defence of its current runway proposal. If that runway is valid on the basis of the 1972 plan, the modern town of Portmarnock should not be there and, for consistency, would have to be demolished.

The NATS study cited by the EIS said a second runway would add 43 movements per hour to the capacity of the existing runway system of 44 mph for a total of 87 aircraft mph. The method used was flawed, as it did not account for all of the airside ground delays incurred by aircraft.

Experience from Hong Kong Airport is highly relevant. A second parallel runway at Hong Kong, with similar runway separation as proposed for Dublin, delivered only 25 of the expected extra 40 movements per hour on top of the 40 movements per hour from the first runway, due to unanticipated ground movement constraints. Only 63% of the expected gain was achieved. The current proposal for Dublin Airport risks a similar outcome, even further compounded by the continued existence of the cross runway 16/24. Even before a formal investment appraisal, a runway that will only yield two-thirds of its design capacity is evidently a bad investment when a fully usable runway could be built elsewhere.

The EIS high growth forecasts mean that the new runway would only offer capacity up until 2029, reaching capacity before the useful life of the pavement and the investment is realised. And that is before considering the extent to which the expected extra movements are overstated by the failure to take full account of ground delays. Full capacity, on EIS figures, may be reached by 2022.

The EIS did not address how long the provision of a new runway would satisfy future air traffic demand or the 'capacity crunch' that will affect Dublin Airport if the air traffic forecasts of the DAA are realised. The second runway investment is unsound because it allows for no future capacity development that will be required on present trends as set out in the EIS. When the second runway reaches capacity, there would be no space left in which to build further runways. When this capacity crunch becomes obvious, the government will be faced with the construction of a new international airport elsewhere, but lands on which to develop an airport capable of supporting 3 or 4 runways, will have risen hugely in cost and may even be unavailable. It makes far more economic and commercial sense to consider the alternative site now when such land is available.

Construction of the second runway, once built, will force future airport development policy in one specific direction and commit some very long-term infrastructure investment, for which the new runway may not even offer sufficient capacity.

The EIS passenger projections ignored the subsidised nature of the passenger charges at Dublin Airport. The subsidy arises because passengers do not have to pay market value for the use of the public land at Dublin Airport. If this subsidy were removed, charges would rise significantly, with huge impacts on the demand for the services of that airport and consequently on future capacity needs at that site. Much of future growth would have to be met by alternative facilities developed where land is not as expensive as at Dublin Airport. Such alternatives should be considered now. They were not adequately considered in this EIS, which ignored the implications of land values.

Additional Information proposals for "Portmarnock-friendly" use of the new runway, and set as Condition 5 by FCC in granting approval, are not workable.

	In the case of the Convention Centre proposed for the Citywest Hotel near Dublin, the Board decided that it would be inappropriate and impractical to seek to control the scale of the development by a condition limiting its use. We believe similarly that conditions limiting the proposed runway's use are impractical, unworkable and implausible.
	The assignment of aircraft to runways is entirely at the discretion of ATC and the pilots. Pilots' requests will usually be granted by ATC.
	Apart from weather and safety exceptions, the proposal also allows air traffic demand to determine operations. As new runway 10L/28R will be the longest runway at the airport, aircraft requiring a longer runway will always be given permission to use the north runway. This pressure will inevitably grow.
	Heavy, non-stop long-haul departures will be assigned to the new runway and the DAA will not forego marketing its new capability to attract cargo operators and long haul air services.
	Given the existing arrival and departure tracks over the Irish Sea and the unbalanced nature of arrivals and departures, UK traffic (the heaviest route) will dictate departures on the new runway over Portmarnock, when the winds are easterly. The air traffic demand caveat was designed for this common situation. ATC would use 10L for departures for traffic reasons, regardless of any preferential commitments.

No assessment was made of effects of the runway proposal on Material Assets (land and property) as required by EIS Directive 85/337/EEC. This should include an analysis of economic and social impacts. But:

	No assessment was made of the impact of 10L/28R on the value of land and property under the new flightpath.
	No assessment was made of the cost of the buy-out of homes in St Margaret's in assessing 10L/28R.
	No assessment was made of the loss of value to thousands of homes under and near the flightpath of 10L/28R.

No cost benefit analysis was carried out, as required by Department of Finance, updated and reissued in early 2005. Since October 2005, such an analysis is required for all capital projects estimated to cost more than €30 million. Although there was no precise cost threshold at the time, prior to the application for planning approval, when the runway proposal should have been assessed, the scale of the project would have made it eligible for cost benefit analysis under the earlier 1994 guidelines. The term "cost benefit" appears only once in the EIS in the context of a system of internal airport transport.

Fingal's director of planning admitted that no economic case had been made for the runway.

No proper economic assessment was made of alternatives as required by Department of Finance Guidelines. Conclusions were based on false and unquantified assertions. Directive 85/337/EEC, Annex III-2 also requires alternatives to be studied, and the reasons for the option chosen to be spelled out. This was not done in an adequate manner.

Standard analysis procedures were violated when the value of land owned by Dublin Airport was not considered in assessing alternatives within and without Dublin Airport:

The cost of land at alternative sites was not considered when alternatives were rejected on "cost grounds":

Thousands of acres of low value former bogland available for a new runway adjacent to the Greater Dublin Area were ignored in ruling out that option. Costs were assumed to be the same, or greater than 10L/28R, when land costs for 10L/28R are at least €2.5 billion.

While spin-off or multiplier benefits from the Dublin Airport option were grossly exaggerated, those same benefits were not even mentioned in the EIS when a new airport at an alternative site was considered:

	A second airport was rejected by the EIS on assumed and exaggerated cost grounds (€5.5 billion). But, as no benefits were measured for it, the rejection was groundless. Costs alone are not a basis for rejection of a proposal. Benefits must also be measured and compared with those costs.
	The economic return from such an airport, public or private, would be very substantial given its room to grow in an uncongested environment. Good design could ensure that new residential communities would not be adversely affected by noise and air pollution.
	UPROAR estimated that such a new airport would yield a 7.4% return on investment, operating on a passenger charge similar to the subsidised charge at Dublin Airport and before considering realistic spin-off and multiplier benefits.
	If a new airport were planned for an extensive area of state-owned former bogland, land values would increase overnight from a few thousand euros to €0.5 million to €1 million an acre. Land, surplus to airport needs, could be sold for development. This would be largesse for the public purse, which could part-fund a new state airport.
	Under the 1998 Air Navigation Act, Dublin Airport, with ministerial permission, can establish and operate a new airport

Cost benefit methodology was not used.

The methodology used has been criticised by international experts. It employs sophistry, i.e. plausible but misleading and fallacious arguments.

Job creation was used as a measure of economic benefit when it is not a measure of economic benefit in times of near full employment. Job creation in such an economy leads to labour market overheating and is a disbenefit.

Jobs, if the runway were not built, were made to "disappear" by erroneous use of ESRI labour productivity statistics, including assuming that jobs created by passenger and freight growth would be average jobs rather than largely service-type jobs subject to low productivity growth.

Indirect job creation was assumed to be a benefit without considering constraints due to congestion and other infrastructural impediments in Fingal.

No assessment was made of indirect and direct jobs and other economic impacts for alternative uncongested sites.

No corrections to the EIS by way of Additional Information were asked for by FCC, as requested by UPROAR. The FCC is therefore assumed to agree with the flawed methodology and to condone its conclusions.

FCC consultants further exaggerated these erroneous conclusions. The same FCC consultant made dubious assumptions about benefits from tourism, again ignoring the fact that tourism benefits, probably to a greater extent, would apply to less congested alternative sites. Research shows that a single dominant gateway (e.g. Heathrow in the U.K.) is bad for the distribution of tourism benefits to the regions.

DAA and FCC consultants consistently confused the undoubted value to the national economy of Dublin Airport with the assumed value of the proposed runway development, in spite of UPROAR's findings that the runway was itself a bad investment and an economic loss. An investment proposal stands or falls on its own merits. It has to be considered independently of the whole of which it is only a prospective part.

National aviation policy issues are not addressed at all in the EIS, nor is any attempt made in the EIS to place this runway proposal in a national policy context. Policy references are exclusively in a local context.

The proposal for a second runway is the single largest capital investment currently planned for any of Ireland's airports. Before any major and far-reaching decisions are taken to add a new runway at Dublin Airport, a national plan has to be in place to define how national air transport should develop in the future, and the roles that the national and regional airports will play in that development. High-level endorsement of need and justification is a fundamental requirement that is plainly lacking.

Placing the decision to implement the second runway at the level of a local planning authority, without sufficient high-level study of its context in terms of long-range capacity for the airports of the Dublin region, and out of context with national civil aviation development policy, ensures that national interest is not served.

However, there is no adequate national aviation policy in place to guide proper decision-making. UPROAR was directed to the Statement of Strategy 2005 - 2007 as the "best steer" on national aviation policy. A policy document covering a period that runs out years before the runway is built, is useless.

National Spatial Strategy (NSS) is violated by this runway proposal although its proponents, in the EIS (7.2.5) and Dublin Airport Masterplan appeal to selective references in favour of further expansion of Dublin to make its case. There cannot be any question that the whole emphasis of the NSS is on rebalancing development away from Dublin in favour of the regions. If recognition is given in the NSS to the inevitable role of Dublin and the need for Dublin to remain competitive, that cannot be taken to permit the central thrust of NSS to be undermined; i.e. positive discrimination in favour of the regions. That would lead to a preposterous outcome, where all proposals to add further to the expansion of Dublin could be justified by reference to these selectively positive references in the NSS to the need for, and inevitability, of Dublin's continued development.

Further, appeals to the NSS references to the importance of Dublin's continued prosperity, would only have some relevance if the proposal were positive for Dublin. That is demonstrable not the case in economic, social and environmental terms.

The EIS deals inadequately with potential runoff problems. The runoff from existing runways and parking flows into the Sluice and Mayne streams both of which are already "seriously polluted" according to the EPA. It can be expected that there will be contamination in the groundwater, especially since infiltration of runoff is being encouraged.

The Sluice catchment consists mainly of small ditches down the sides of fields, leading into a lake at Kinsaley, which is already subject to contamination from discharges from the airport. The outflow from this lake is the Sluice River, which has already been deepened to eliminate flooding. It is indicated in the EIS that runoff from the portion of the runway within the Ward River catchment area 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.

The attenuation of runoff to green-field rates, of existing car parks within the airport complex contributed to flooding in this catchment. It is likely that the calculated volumes of water involved with the new runway will entirely overwhelm the Sluice system. Flooding in the area will be worsened.

This stream flows into Baldoyle estuary, a Nature Reserves and 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 also rated as of international importance for Brent Geese.

There will undoubtedly be a significant amount of petroleum oils, hydraulic fluids and other materials 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.

The DAA's consultants used an out-of-date, poorly calibrated model to assess the runways impacts on traffic in the EIS.

The EIS did not demonstrate that the existing or future proposed road network and public transport proposals could cater for a much-expanded service to and from Dublin Airport. The Airport will be difficult to access by road with lengthy and unpredictable journey times to and from the airport.

No attempt was made in the EIS to estimate or present the economic costs of road congestion due to the proposed runway, although the Dublin Transportation Office's (DTO) traffic model does measure such costs. UPROAR's estimate of €124 million (NPV) is probably conservative.

The Dublin Chamber of Commerce said: "The cost of congestion to the Greater Dublin Area in 2005 was approximately €2.5bn and is perhaps the single greatest threat to future investment in the region and the competitiveness of the capital city. Congestion affects the quality of life, the cost of doing business and the quality of the environment."

A Metro to the Dublin Airport will not resolve the resulting traffic congestion and the high degree of saturation on the M1 and the M50. At best, public transport (including the Metro) will only cater for 40% of airport trips.

The capacity of the M1 motorway, and the road junctions around the airport will be severely affected regardless of a Metro service to the Airport.

As found by the Board in the case of the Convention Centre proposed for the grounds of the Citywest Hotel near Dublin, the proposed runway development contravenes the policies as set out in the Regional Planning Guidelines for the Greater Dublin Area 2004-2016 to reduce the overall growth in demand for travel and would, therefore, be contrary to the proper planning and sustainable development of the area.

In light of the NRA's objection to the IKEA development at Ballymun near the M50, on the grounds that it will threaten the benefits of the M50 upgrade, there is now an overwhelming case for an independent review of the earlier traffic modelling. This should also include the impacts from IKEA and the Dublin Port Tunnel, the "Airport Box" proposed by FCC, as well as the new northern runway. A DTO 2004 model is now available for this work and the DTO would be the appropriate Government Agency to undertake the work.

The DAA's Additional Information consultant, RPS MCHugh, agreed that computer modelling of traffic in the EIS was outdated and should be repeated with the calibrated DTO 2004 model. This has not been done.

The same author says that the existing junctions will be over-capacity in the "opening year of 2010". As the runway could not open until 2013/14, the road network will be even less able to cope with the additional load by that time.

The estimated cost of €200 million for the proposed Airport Box road network was ignored.

The EIS assertion that reduced delays for aircraft on the ground "would contribute to lower emissions from aircraft on the ground, which would compensate for any slight increase in emissions from the airport area due to higher aircraft movements" is absurd, not least because ground delays will increase. (See: "Engineering and Operations.")

It is likely that the doubling of aircraft movements expected by 2025 will double the volume of pollutants being released. How can that possibly be eliminated by supposed reduced ground delays?

Monitoring of air quality was performed by the DAA with a resulting lack of transparency. Projected air quality, if mimicking UK airport levels, will exceed EU limits.

Portmarnock is downwind of the airport in the path of the prevailing winds. This fact was presented to the St. Margaret's community by the DAA as indicating a lesser impact on them, clearly implying a greater impact on Portmarnock.

No analysis was done in the EIS of the consequences for air quality of the increase of 35,000 airport-related car movements per day by 2025. Modern car engine modifications produce higher NOx emissions per unit of fuel.

Heavier long-haul aircraft which will take off on the longer runway, being more fuel-efficient, will emit more NOx.

The contribution to climate change of the runway development is stated in the EIS to be "negligible" despite the projected doubling of aircraft movements, and an increase of 35,000 airport-related car movements per day by 2025. In addition, modern car engine modifications produce higher NOx emissions per unit of fuel. No quantification of the climate affects of these increases was made in the EIS.

The effects of increased aircraft movements on the emissions of greenhouse gasses affecting the fulfillment of the Kyoto Protocol commitments were wrongly analysed.

The EIS assertion that improvements in aircraft engine design and higher fuel efficiency, "would also contribute to lower greenhouse gas emissions at the airport over the next 20 years," ignores the obvious fact that the impact of a doubling of aircraft movements cannot be offset by increased fuel efficiency, which will not double. Emissions will certainly increase.

Further, NOx, increasingly emitted by more fuel-efficient engines, has a 310 times higher global warming potential than CO2

In assessing aircraft noise impacts on schools only one study was referenced, but could not even be identified with confidence in the literature. All other recent literature was ignored, including two studies by Haines et al, studies by Franssen et al, Hardoy et al, and lastly, the "RANCH study by Stansfeld et al, published in the Lancet in 2005.

Many of the schools in the RANCH study had noise insulation. No analysis of the ameliorative effect of insulation on aircraft noise damage was done.

Noise contours based on estimated average noise and UK standards were presented as definitive.

While previously specifically exempted from noise control, the operation of the airport will in the future have to comply with EU 2002/49/EC transmuted into Irish law by S.I. 140 of 2006 (Environmental Noise Regulations 2006). Although now in effect, that Directive was ignored.

No assessment was made in the EIS of the impacts on vulnerable communities such as Prosper Fingal Training Centre Portmarnock, The Arch Club, and on care homes and nursing homes in the area.

No maximum noise event data was produced in the EIS for the proposed runway.

Although maximum noise impacts are most relevant at night they are also very relevant during daytime hours. For example, repeated high noise events have serious affects on children's development at school and after school hours. LAmax noise profiles are valid for the Portmarnock area and laterally related areas, as an indication of the transitory noise patterns at peak noise level. This option is recognised in the EU procedures now governing noise measurements around airports.

Daily maximun noise levels exceeding 90 decibels will hit most of built-up Portmarnock. All Malahide and Swords residents will suffer at least 70db events, half of them getting hit by 80db incidents. With over 40 planes an hour using the new runway at peak hours there will be a horrendous level of noise for many hours during the day, on top of existing aircraft noise. With no night curfew in place at Dublin Airport there is nothing to prevent such abuse continuing throughout the night. A balanced and objective analysis would have addressed these serious noise implications. The EIS simply ignored day-time maximum noise impacts.

Maximum noise data for the old main runway, 10R/28L, was used in the EIS to make night noise appear to decline for "Dublin City" and in total. That analysis was based on the assumption that 10L/28R would never be used at night. That curfew condition was not mentioned elsewhere in the EIS. This argument is another fine example of EIS sophistry.

The EIS presented average noise data (LAeq) for the new runway. An I.C.A.O. metric was used to produce these figures, without calibrating the model against actual observations; no actual noise measurements were carried out. All results were computer-generated and based on certification of aircraft. Certified levels may differ from actual measurements. It was produced without taking stakeholders views into consideration. This method is not transparent and is vulnerable to easy manipulation.

The actual operational noise will be different for different weather conditions and will also depend on ground cover and contours. Noise mapping needs to be related to actual measurements on the ground, which take land contours and new housing developments into consideration. Model data cannot be used for decision-making because it has not been "ground-truthed" using empirical data.

The maps produced presuppose that all aircraft will follow the exactly define path. In practice, many aircraft deviate from this path by as much as 1 km either side, broadening the noise impact on either side of the approach path. Average noise levels are therefore underestimated.

Given that during the last ten years 82 per cent of the world's jet aircraft fleet accidents occurred during take off and landing phases and accounted for 58 per cent of all onboard fatalities and all third party fatalities, safety is a major issue for local communities. The EIS treatment of this issue was inadequate.

The EIS applied UK standards to hazard analysis and presumed they would apply to the Dublin Airport area. It failed to make any reference to the actual communities in the danger zones or to attempt to assess the possible consequences for them given their specific characteristics.

No account was taken of the fact that Portmarnock is a community of 10,000 people with the highest rate of family occupancy of any town in the country (nearly 80%).

No account was taken of the fact that two of the country's largest secondary schools with over 1000 pupils each and only one kilometre apart, will be under the new flight path. (Portmarnock and Malahide Community Schools). There are also two primary schools with 700 pupils near the flight-path.

No account was taken of the fact that the centre-line of the new flightpath will be over a 120-bed hotel with a capacity of 450 guests and staff, just one kilometre from Portmarnock Community School. There is also a second large hotel 600 metres away.

The ERM Report's Public Safety Zone analysis is accepted without question. The Outer Safety Zone, which would apply to most of Portmarnock, would disallow high-density housing development, and the building of schools, hospitals, hotels and facilities attracting large numbers of people. In The Netherlands no house building is allowed within the outer crash zone because of the risk to human life.

It is quite absurd that new flight-paths with the same dangers can be put over existing ground structures. If new developments under existing flight-paths are ruled out on safety grounds, why are new flight-paths over existing communities not ruled out on the same safety grounds? Why are the former too dangerous and the latter of no concern? It is wholly unacceptable that the EIS and Additional Information ignored these concerns. An objective evaluation would have addressed these unpalatable facts.

In considering options within and without Dublin Airport, the danger to existing communities under 10L/28R's new flightpath was ignored when these options were casually ruled out by the EIS. There are feasible options, which would exclude those dangers, such as a new airport on a well-chosen site away from established communities. No account was taken of these dangers, in shadow-cost terms or otherwise, when opting on false "cost grounds" for the dangerous 10L/28R option.

The methodology used was inadequate. The small-scale desk study done was not remotely adequate for assessing the health impacts of a development of the scale proposed.

In its own term the work done was inadequate: the literature referenced was out of date, and very important recent work was ignored. The discussion of the possible impacts on the population around Dublin Airport was cursory.

There were no references to any literature on the human health impacts of air quality although knowledge of the health effects of air pollution has increased greatly over the last decade.

Large airports have a negative effect on public health. A health study carried out at the Medical Faculty in Gent University 2002 showed that, over a 10-year period, health costs far exceeded economic benefits.