Noise Propaganda

Manipulation of data by Dublin Airport's consultants greatly understates the likely magnitude and extent of noise impacts on local communities.

Their noise figures are presented as "averages" which means that if a horrific noise-filled minute is followed by a quite one, the average minute is only "half-bad". They have not told the people of North Dublin plainly, or the FCC, what maximum noise levels they could expect from this new runway. That is a distortion of the pain that will result from individual and frequent aircraft overflights. This type of repetitive, discrete, over-head noise nuisance hurts people more than meaningless "averages". The World Health Organisation (WHO) says that intermittent noise events should be measured in terms of maximum levels (LAmax) or sound exposure levels (SEL).

The DAA's selective noise analysis may be related to an EU noise directive requiring governments to reduce the population exposed to aircraft noise. First of all, they present LAeq levels (average 16hrs daytime noise) over Portmarnock, which are bad enough, but the worst levels only touch part of Portmarnock, even though all of Portmarnock is within the 57dBLAeq contour. Applying UK standards, they stop their contours at 57dB, which excludes Malahide and Swords, although WHO defines 50dBLAeq as an annoying level of noise. A 50dBLAeq contour would include most of Swords and Malahide. We added a 50dB contour by extrapolation. Even further, WHO recommends 40 dB LAeq as the maximum allowable level for new developments. This new runway is clearly a new development.

Also, the EIS 57dBLAeq contour represents an average daytime runway usage situation, made up typically of 20% of take-offs to the east. As these are the most annoying for local communities, a chart showing that scenario (easterly take-offs only) would push the 57dB contour itself up over Swords and Malahide. Again, they choose their data presentation conveniently to present the best case.

Even more seriously, for maximum noise events (LAmax) they say: 1) as LAmax is only relevant to night flights and, 2) as the new runway will not be used at night, LAmax figures are not relevant to the new runway. Therefore no maximum noise table or chart is produced for the new runway. Of course, LAmax figures are most relevant to night-time - WHO has tighter standards defined in LAmax terms for night-times - but LAmax levels are also very relevant to daytime - that is what assaults our children everyday, in and out of school. Some guidelines say that nighttime events should get a 10dB penalty over daytime events. This means that a daytime event of 70dB is as annoying as been woken up by a 60dB event at night. (Boeing applied this 10dB distinction to LAmax figures for day and night at a Czech airport: http://www.boeing.com/commercial/noise/ruzyne.html).

The DAA does produce a table (but no chart) for LAmax figures (at night) for the old runway (EIS Table 16.3). This they use to argue falsely that total noise will go down with the new runway at night. They do so by arguing that if the new runway is built, use of the cross-runway (roughly N-S) will be reduced to weather-only situations (2% of the time rather than 10% plus as now). That means that noise (LAmax) over Marino/Clontarf - defined conveniently as "Dublin City" will be reduced dramatically. With the general reduction in the noisiest planes due to improved engine design, the conclusion is that noise will fall (at night) if the new runway is built - assuming of course they will not use the new runway at night. Although, strictly speaking, their conclusion reached for LAmax applies only to night noise - they leave the impression, by often omitting to mention it, that it applies to the whole 24-hour day.

This is accentuated by the fact that they do not admit that noise will increase anywhere during the day, which is obviously the case. The new runway will of course be used during the day and day-time LAmax figures would be at least as bad as those extrapolated using the night-time LAmax figures, as it is generally perceived that some efforts are made to exclude the noisiest planes from night-time operation. Further, as LAmax night-time figures are defined for an 8 hour night period, the probability of a higher level noise event is obviously half that for a 16 hour period. The EIS should have presented daytime LAmax figures specifically for the new runway and for the same scenario as was presented only in terms of LAeq figures. Even if higher LAmax figures (by 10dB) may be acceptable during the day, people are entitled to know what they will be subjected to under this new runway.

The EIS conclusion depends entirely on confining the LAeq noise to a minimal area by not showing (WHO) 50dB, or 40dB, or (UK) 57dB contours for easterly take-offs, and excluding LAmax noise on the grounds that it is only relevant to night flying which will supposedly not take place on the new runway. The people of Portmarnock get it full blast but they are few compared to the thousands in Marino/Clontarf who will be relieved. This is disinformation and a deception of the first order.

UPROAR has made it's own determination of LAmax levels for the new runway based on the obscure DAA figures. We took the EIS figures for LAmax given for the present main runway in Table 16.3 and extrapolated them northwards 1.7 km and 200 meters or so to the east. We then drew contours to represent what LAmax figures would be like at night, if the runway was used at night (as we expect) or what LAmax figures would be at best during the day. We have confirmed them by taking our own noise measurements at Portmarnock of noise due to the present runway and extrapolated them in a similar fashion to the new runway. The chart based on our own data is virtually identical to that based on the DAA's own LAmax figures, as extrapolated.

Noise levels exceeding 90 decibels will impact most of built-up Portmarnock. All Malahide and Swords residents will suffer at least 70dB events, half of them getting 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. With no night curfew in place at Dublin Airport there is nothing to prevent such abuse continuing throughout the night under the commercial pressure that is driving the current explosion in air travel. The WHO says noise levels at night should not exceed 60dB outdoors and 45dB indoors. We do not accept assurances that the new runway will not be used at night.

EU directive

This misrepresentation of noise data in the EIS may be related to the new EU noise directive (2002/49/EC of 25 June 2002) which says that the number of people affected by aircraft noise should not increase. Being defined in terms of population it may have been imperative for the DAA to show that this new runway would not increase the number of people affected by noise.

With Swords projected to reach a population 100,000 by 2025 (from about 40, 000 now) that will be a big increase in population affected by noise, if data were presented properly. As the EU directive does not define the noise level to be avoided, it can be argued that a level recommended by the WHO as a nuisance level would have to be accepted as an undefined level of noise, which should be avoided (more than any UK standard). If the contours were extended even further to the 40dB contour we would include many more people.

All of the figures used in the EIS seem to be based on UK standards. We should not accept that UK standards can be taken as appropriate to the Republic of Ireland. If no Irish standards exist we should have first recourse to the international standards of bodies of which we are members, such as the EU and UN. If there are no standards we are party to, we should reject any attempt to impose UK standards on us and insist that the affected communities should be free to decide what they consider an acceptable level of noise, or other pollutant.

The noise chapter of the EIS, Chapter 16, makes frequent reference to UK standards. The 57dB is defined as "onset of disturbance - low annoyance" according to a UK committee. Their "low, moderate and high annoyance levels, 57dB/63dB/69dB" which they use to determine the small numbers of people they say will be affected by noise, are all UK standards of no validity in this county. They should be rejected out-of-hand and be replaced by WHO standards. Regardless of the noise standard used, the social costs to communities of this noise nuisance cannot be ignored in any assessment of the benefits and costs of this runway proposal.