UPROAR
STRATEGIC & CAPACITY OBJECTIONS REGARDING DEVELOPMENT OF A SECOND PARALLEL RUNWAY AT DUBLIN AIRPORT

1. NATIONAL & STRATEGIC CIVIL AVIATION POLICY ISSUES

Development of significant additional capacity at an airport, especially where that additional capacity requires a major long term capital investment, must always reflect both the intended role of that airport in a national context, and a specific capacity need that is consistent with national policy towards air transport sector growth and development. However, Ireland has no national air transport policy in place to define how the state wishes its air transport sector to develop, or how it wishes the supporting infrastructure, such as the national airports, to develop in support of the sector in the future. Any decisions, therefore, to invest heavily in infrastructure at the Dublin Airport, to increase its capacity for aircraft movements and passenger and cargo volumes, are therefore being made in a vacuum and without any firm justification at the national level.

The extent to which national air transport policy for Ireland has been addressed is contained in Minister Cullen's "Aviation Action Plan". This proposes:
- the sale of a majority shareholding in Aer Lingus;

- appointment of financial advisors to Government on the Aer Lingus sale transaction;

- construction of a new Pier at Dublin Airport, available from 2007;

- construction of a new passenger terminal (Terminal Two) at Dublin Airport to open in 2009;

- a triple safeguard approach (consultation, verification, regulation) to ensure maximum efficiency and cost effectiveness of the building of Terminal Two;

- an open tender competition to select the operator of Terminal Two;

- examination of the current legal and regulatory framework governing Dublin Airport, identifying and making any changes necessary to facilitate a third Terminal, to ensure that when passenger volumes determine the need for additional capacity beyond that offered by Terminals One and Two, extra capacity can be brought on stream;

- delivery of Terminal Three in the most cost efficient and timely way, with this outcome being underpinned by an open competitive process.

Clearly, the Minister's Aviation Action Plan, if this represents the level to which national policy has progressed, leaves much to be desired. It addresses the minutae of an Aer Lingus sale prospect, and specific terminal development projects, including a 3rd Terminal in the future, but no mention is made of the runway project, nor is the promise of additional terminal capacity in the future related to the development of the runway system, or to all of the other infrastructure investments that will be needed to support this additional capacity. Sadly, the Aviation Action Plan reveals a myopic view of national air transport development, and fails to show the nation a vision of the 'bigger picture' into which all this is to fit.

The Irish public, the residents of Fingal County, and of nearby communities affected by the growth of Dublin Airport in one way or another, are being asked to approve the proposed runway investment, as if this is a single isolated project, directed only at meeting a relatively near-term capacity need at the airport. Indeed, government and the Dublin Airport Authority may also view this proposal in the same way, rather than an investment commitment that may have far-reaching implications for air transport service policy for the Dublin Region, and implications for the utility of the capital investment as well.
From a national strategic perspective, any major capital investment at the Dublin Airport, such as for a new runway or a new passenger terminal building, that have long economic lives, must always be questioned as to whether they will:

be consistent with other strategic initiatives of government, such as the 'decentralisation' of government to the regions or, in the air transport context, the separation of Cork and Shannon Airports from Dublin Airport to develop in a self sufficient manner;

be sufficient, but not excessive, to meet the needs of the airport right through to the end of their useful lives, and so deliver the full capacity for which they are planned, and for which investment is to be made.

be consistent with the long term, as well as the very long term, strategy for development of airport facilities to serve the Dublin Region;

The approach being taken by Government to the development of the second parallel runway, as to the future terminals, suggests that the above questions have not been addressed.

At the stage of a planning application for a project, it would be normal to expect that the 'high level' policy considerations, the national interest, and the very long term strategic implications of the project, would have been clear and settled. Normally one would expect that the planning authority would then need to deal with matters of modification to the proposal, impact mitigation, and matters relating to implementation and compensation. In this case, though, the issues surrounding the project are not just to do with the potential impacts of the runway, or questions requiring a modification to the proposal, but are actually of a much more fundamental nature. The real issue is to do with the direction for development of the Dublin Airport as an air transport service centre, rather than its runways or its terminal buildings.

What is emerging from all of the discussion is that the runway development proposal has not been viewed in the very long term context by Government, and statements regarding a future Terminal 3 suffer from the same short range vision.
Seen in the light of the actions of government with on-going de-centralisation of government services to the regions, the splitting of Aer Rianta into 3 commercial companies, the boosting of Dublin Airport at the expense of possible development of other regional airports, is clearly contradictory.

Before any highly significant, and far-reaching, decisions are made to add a new runway or a third Terminal at Dublin Airport, there has to be in place a national plan of government to define how the government intends national air transport to develop in the future, and the roles that the national and regional airports will play in that development. The precise infrastructure requirements for each of the airports that will make that policy happen, need to be defined as a consequence of defining the development objectives and mechanisms for national air transport policy.

It is important to point out that in recent years the UK government studied its own national airports requirements, and as a result of these studies determined how future air transport demand is to be satisfied, which airports are to be expanded, and how this is to be done. Optioneering studies established the capacities, as well as the opportunities, available at the various airports of the UK, and determined how future capacity needs might be satisfied, and particularly where the focus for any new airport capacity should lie. For instance, for the London area the capacity limit for Heathrow was determined, and major expansion proposed for London-Stansted was been approved as a result of these national policy studies. The importance of this example, in the context of the Dublin Airport case, is that the government of the UK took the approach of studying its national air transport needs, and from this defined a policy for development of the national airports. By doing this, it explored all of the options available, assessed all of the impacts and costs, and defined a clear path for the future.

By contrast, the proposal by Dublin Airport to do the same for that site as is immediately proposed for London Stansted, but without any national plan of need and justification to support decision-making, suggests an inadequate planning process.

Essentially, therefore one can conclude that:

a) Ireland has no national air transport policy to define how the air transport sector is to be developed in the future, what airport infrastructure is needed to achieve national policy, where this should be located, and how far Dublin Airport should, or could, be developed in terms of long term capacity;

b) Policies are being enacted by government that would not be supported by a continued concentration of the national air transport services and capacity at the present Dublin Airport site;

c) Addition of very major infrastructure and airside capacity has not been subjected to a study of its need and justification in the national context. Given that this proposal for a second runway is the single largest capital investment currently planned for any of Ireland's airports, a high level endorsement of need and justification is a fundamental requirement that is plainly lacking;

d) 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 necessarily served, and that the runway investment may be jeopardised if the infrastructure cannot be fully utilised to the end of its useful life.


2. DUBLIN AIRPORT CAPACITY ISSUES

It is, of course, possible that in the national context the Dublin area should be the focus of the nation's air transport services and infrastructure, so long as this conclusion is supported by proper study. However, having determined the future role of Dublin as the air transport focus, the question of whether all of the air transport services and infrastructure should be directed to the present Dublin Airport still has to be addressed. In the planning of the second runway, the assumption has been made that all future airport capacity will be provided at the present Dublin Airport, although some parties have promoted other alternatives in the greater Dublin region.

There are options available for accommodating future air transport needs in the greater Dublin area, and these might be summarised as:

a) Focus all future airport capacity at the present Deblin Airport site, including construction of the proposed 2nd parallel runway, with acquisition of additional lands in the west infield for future passenger terminal development, and to the south for future air cargo facilities and new highway access;

b) Cap the existing Dublin Airport at its present stage of development and capacity, and construct a new replacement international airport further from Dublin on new lands, where airport and aircraft impact can be managed, and ultimately close the existing airport site and relocate all services to a new airport;

c) Cap the existing Dublin Airport at a passenger capacity in region of 25 to 30 million annual passengers, but with the existing runway and airside infrastructure optimised for operations to support the proposed passenger capacity, and expand and enhance one of the other regional airport sites in the Dublin Area (Baldonnel etc.) to act as a supplemental airport facility, to which some of the air transport sectors presently located at Dublin Airport might be shifted (eg the Low Fare Carriers, air cargo, specific airlines etc.), so that the long term air transport capacity is then split between two (or more) airports in the greater Dublin region.

The above possible options have not been subjected to a full and proper study. Indeed, in the EIS (text) document for the second runway planning application, the possible options are dismissed in a cursory manner in 3½ pages, with the arguments against any other option couched in vague and weak terms. This indicates very clearly that the issue has not been the subject of a full technical, economic, financial, and environmental assessment. Without a full and proper study of these options, it is not possible for the Government of Ireland to confirm that, by focussing all of its immediate airside capacity development at the present Dublin Airport, it is taking the most appropriate and cost-effective path to providing for the long term air transport needs of the capital city, and for Ireland as a whole.

It is fundamental to address the question of where, and how, should future airport capacity be provided, since failure to do so will have very long term implications for the Dublin region, and for the state. Construction of the second runway will be a significant marker in this regard since, once built, this 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. What a full review could expose, however, is just how long the provision of a new runway would satisfy future air traffic demand, as this is not addressed in the EIS. It is quite possible that the longer-term satisfaction of air transport demand in the Dublin area will require an alternative, or replacement, airport at some time within 20 to 25 years, regardless of whether a new runway is built at Dublin Airport. A thorough planning review of the options available for alternative airport developments in the Dublin area is vital, as the present level of assessment of this issue has not demonstrated that the proposed new runway is the best direction for government to take, given post-master plan demand and capacity considerations. Consequently, the public cannot be assured that all possible alternatives have been given due consideration from all perspectives, especially the very long term airport capacity requirements.

However, there is a fundamental flaw in the master planning for the Dublin Airport, and with foresight this would force a different direction to be taken, even for the second runway project. This arises because of a 'capacity crunch' that will affect the Dublin Airport if the air traffic forecasts of the DAA/Aer Rianta are realised, whether or not the Second Runway is built.

The EIS for the Second Runway project placed considerable weight on the airport capacity work carried out by the UK National Air Traffic Services (NATS). Using the NATS studies, the capacity of the existing runway system in the design hour is 44 aircraft movements per hour. NATS suggests that adding a second parallel runway would add a further 43 movements per hour, for a total of 87 aircraft movements per hour.
This may significantly overstate the gain in movements to be had from the proposed runway. The NATS studies, only accounted for arrival delay in the airspace but not on the ground, while for departing aircraft, accounted only for aircraft delay incurred at the departure holding point prior gaining access to the runway. This resulted from the limitations of the simulation model employed by NATS for this work, and a lack of appreciation that level of service indicators must account for all delays, not just some of them. The results obtained by the NATS work therefore enabled a higher theoretical runway throughput to be declared as being possible, as this method did not account for all of the airside ground delays incurred by aircraft, and assumed a somewhat lower level of service to the airlines. This is a flawed approach, since an airport authority must attempt to offer a specified level of service, and must ensure that all of the airport ground system is rendered as efficient as possible to minimise ground delays.
Even so, based on the DAA/Aer Rianta forecasts, the projected level of air traffic would be reached by 2029 under a high GDP growth scenario, or by 2035 under the DAA/Aer Rianta "Centreline Forecast". What this means is that, if the second runway is built in 2010, it will only offer capacity up until 2029 or 2035 - i.e. for between 19 to 25 years after construction, and the new runway will therefore reach 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 mouvements are overstated by the failure to take full account of ground delays.
While the prospect of constructing a major pavement investment that will reach capacity before its useful life is expended is illogical enough, the fundamental fatal flaw in the plan, and the factor that makes the second runway investment unsound, is that once the second runway is at capacity, there is no space left in which to build a 3rd or 4th runway. Consequently, at the time that the second runway approaches capacity, the government will then be faced with having to construct a new international airport elsewhere, as the present Dublin Airport site will be incapable of further airside expansion. By the time this capacity crunch is realised, lands on which to develop a new international airport, capable of supporting 3 and 4 runways, will have risen in cost and may even be unavailable due to urbanisation and growth.

A further issue must also be addressed in the context of the Dublin Airport runway capacity issue. This concerns the corresponding passenger terminal capacity that would apply at the time that the runway system reaches its limiting capacity for aircraft movements. From the DAA/Aer Rianta forecasts it is suggested that the terminal capacity in the Eastern part of the airport, estimated at 30 million annual passengers, to which the initial terminal investment referred to by the Minister would be directed, would be reached by 2016 (2004 DAA/Aer Rianta Unconstrained Centreline Forecast). This means that a new terminal building constructed in 2009 (per the Ministers "Action Plan") would reach capacity in only 7 years after completion. Beyond this, a third passenger terminal (Terminal 3) would need to be developed in the infield of the airport (west of the Control Tower), but with heavy additional support infrastructure in road access and services. However, this investment which might come on stream by 2015 before Terminal 2 is saturated, could only offer capacity for growth in passenger traffic for only 13 to 19 years, as the capacity of the 2-runway system would be reached by 2029 to 2035.

Consequently, investment in both Terminals 2 and 3 is questionable, and because of the capacity limitation of the ultimate 2-runway system, the investment in two additional passenger terminals would be under utilised because neither could support long term growth in passenger traffic or be used to the end of their useful economic lives, before a new airport will have to be brought into service by about 2028 (high growth) or 2033 (centreline forecast.

Given the looming 'capacity crunch' in terms of the ability of the second runway being able to accommodate growth in aircraft operations beyond the period ranging from 2029 - 2035 (depending on which forecast is realised), along with the sheer inability of the site to accommodate a 3rd or 4th runway, any investment in long life facilities, such as in large passenger terminals and especially in highway access and servicing to the infield, has to be examined carefully. Clearly, in the rush to deal with a near term capacity issue for the present runway system, the DAA and the Government have not 'seen the wood for the trees' and overlooked the fact that investment in the runway system at Dublin Airport, rather than at a new site elsewhere, could be very short sighted indeed. Having committed to a new runway, the natural progression to provide matching capacity in the terminal system will then cause the investment in the terminals and support infrastructure to be under utilised as well.